proposed 80 000 tpy galvanizing plant in the coega

121
PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA INDUSTRIAL DEVELOPMENT ZONE (IDZ) FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT DISCLAIMER ILISO Consulting (Pty) Ltd assumes no responsibility for any errors that may appear in this document. The information contained in this document is subject to change without notice.

Upload: others

Post on 15-Apr-2022

5 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA

PROPOSED 80 000 TPY GALVANIZING PLANT IN THE

COEGA INDUSTRIAL DEVELOPMENT ZONE (IDZ)

FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT

DISCLAIMER ILISO Consulting (Pty) Ltd assumes no

responsibility for any errors that may appear in this document The information contained in this document is subject to change without notice

PROPOSED 80 000 TPY GALVANIZING PLANT IN THE

COEGA INDUSTRIAL DEVELOPMENT ZONE (IDZ)

DEDEA Reference ECm1LN2M11-24

Report Title Draft Environmental Impact Assessment Report

Authors Lea September Martin van Veelen Terry Baker

ILISO project reference no 1000196

Status of report Final v10

First issue April 2012

Final issue

Prepared by Submitted to

ILISO Consulting (Pty) Ltd Eastern Cape Department of Economic

P O Box 68735 Development and Environmental Affairs

Highveld Contact Mr Jeff Govender

0169 Private Bag X 5001

Greenacres 6057

Contact Lea September On behalf of

Tel 012 685 0900 Casa Steel Trading (Pty) Ltd

Fax 012 665 1886 Contact Mrs Leoncie Mukundente Director

Cell 082 455 1157 Tel 041 379 4623

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 i

PROPOSED 80 000 TPY GALVANIZING PLANT IN THE

COEGA INDUSTRIAL DEVELOPMENT ZONE

FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT

TABLE OF CONTENTS

ACRONYMS IV

EXECUTIVE SUMMARY V

1 INTRODUCTION 1-1

11 BACKGROUND 1-1

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS 1-1 13 PURPOSE OF THIS REPORT 1-2

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) 1-2

15 PROJECT TEAM 1-3

16 STRUCTURE OF THIS REPORT 1-4

2 DESCRIPTION OF THE PROPOSED PROJECT 2-1

21 TECHNICAL ASPECTS 2-1

211 The galvanizing process 2-1

212 Main inputs and outputs in operational phase 2-3

213 Installations on site 2-3

22 LOCATION OF THE PROPOSED GALVANIZING PLANT 2-4

23 NEED AND DESIRABILITY 2-6

24 ALTERNATIVES IDENTIFIED 2-6

25 CONSTRUCTION ASPECTS 2-6

26 OPERATION ASPECTS 2-7

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT 3-1

31 OBJECTIVES 3-1

32 AUTHORITY CONSULTATION 3-1

33 PUBLIC PARTICIPATION PROCESS CONDUCTED 3-1

34 LEGISLATION AND GUIDELINES CONSIDERED 3-2

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT 4-1

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION 4-1

42 SOCIO-ECONOMIC CHARACTERISTICS 4-3

43 BIOPHYSICAL CHARACTERISTICS 4-3

431 Surface and ground water 4-3

432 Climate and atmospheric conditions 4-3

433 Geology and soils 4-4

434 Terrestrial ecology 4-4

435 Land use and topography 4-7

436 Heritage and archaeological survey 4-7

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED 5-1

51 AIR QUALITY 5-1

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 ii

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS 5-2

53 BIODIVERSITY AND CONSERVATION 5-2

54 WATER QUALITY 5-2 55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES 5-3

56 HEALTH AND SAFETY 5-5

57 TRAFFIC 5-5

58 NOISE 5-9

59 SOCIO-ECONOMIC ASPECTS 5-10

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY 6-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS 7-1

71 IMPACTS DURING CONSTRUCTION 7-1

711 Air quality 7-1

712 Heritage and archaeological resources 7-1

713 Biodiversity and conservation 7-2

714 Water related impacts 7-3

715 Waste management 7-3

716 Health and safety 7-4

717 Traffic 7-4

718 Noise 7-5

719 Socio-economic 7-5

72 IMPACTS DURING OPERATION 7-6

721 Air quality 7-6

722 Water quality 7-7

723 Waste management and hazardous substances 7-8

724 Health and safety 7-9

725 Traffic 7-9

726 Noise 7-10

727 Socio-economic 7-11

73 COMPARATIVE ASSESSMENT OF IMPACTS 7-11

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME 8-1

9 ENVIRONMENTAL IMPACT STATEMENT 9-1

10 CONCLUSION AND RECOMMENDATIONS 10-1

11 REFERENCES 11-1

LIST OF FIGURES

Figure 1 Process flow diagram for proposed galvanizing plant 2-2

Figure 2 Continuous Galvanizing Line 2-3

Figure 3 Location of the proposed galvanizing plant 2-5

Figure 4 Zone layout in the Coega IDZ 4-1

Figure 5 Site location 4-2

Figure 6 Coega IDZ Open Space Management Plan (OSMP) 4-5

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble gravels

exposed by tracks in Zone 6 (Source Binneman 2010) 4-8

Figure 8 Coega IDZ road network layout (Adapted from BKS 2006) 5-6

Figure 9 Coega IDZ road network 5-7

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 iii

Figure 10 Trip distribution for freight and personnel trips 5-8

Figure 11 Morning peak hour Casa Steel development traffic 5-9

Figure 12 Casa Steel organisation chart 5-10

LIST OF TABLES

Table 1 Coordinates of site corners for the proposed galvanizing plant 4-1

Table 2 Hazardous materials to be used on site 5-4

APPENDICES

APPENDIX A List of registered stakeholders

APPENDIX B Notice of AEL application and advertisements

APPENDIX C Notice of comment period for draft scoping report

APPENDIX D Summary of issues raised and responses thereto

APPENDIX E Background Information Document

APPENDIX F Air Quality Impact Assessment

APPENDIX G Traffic Impact Assessment

APPENDIX H Waste Management and Hazardous Substances specialist study

APPENDIX I Water Quality Specialist Study

APPENDIX J Environmental Management Programme (EMP)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 iv

ACRONYMS

AEL Atmospheric Emissions Licence

BID Background Information Document

CCA Custom Controlled Area

CDC Coega Development Corporation

DEA Department of Environmental Affairs

DEDEAT Department of Economic Development Environmental Affairs and Tourism

DWA Department of Water Affairs

EAP Environmental Assessment Practitioner

EIA Environmental Impact Assessment

ELC Environmental Liaison Committee

EMP Environmental Management Programme

GN Government Notice

IampAPs Interested and Affected Parties

IDZ Industrial Development Zone

LNG Liquid natural gas

masl Meters above sea level

MSDS Material Safety Data sheet

NEMA National Environmental Management Act

NEMBA National Environment Management Biodiversity Act (No10 of 2004)

NMBM Nelson Mandela Bay Municipality

OSMP Open Space Management Plan

PoS Plan of Study

SAHRA South African Heritage Resources Agency

TNPA Transnet National Ports Authority

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 v

EXECUTIVE SUMMARY

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone

(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province

Galvanizing consists of coating steel with zinc in order to protect it from corrosion An

Environmental Impact Assessment (EIA) is required as the proposed project involves several

activities listed in terms of Section 24 of the National Environmental Management Act

(NEMA) 107 of 1998 as amended and requires an environmental authorisation The

project also involves activities listed in terms of the National Environmental Management Air

Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008

which respectively require an Atmospheric Emissions Licence and a Waste Management

Licence

The Scoping and Environmental Impact Assessment process underway covers all aspects of

the project and informs all three applications

Scoping was the first phase of investigations and aimed to inter alia identify potential key

environmental issues and impacts to be addressed in the EIA phase

The following environmental issues and potential impacts identified in the Scoping Phase

were investigated in the EIA

Air quality

The galvanizing process generates atmospheric emissions which are regulated in terms

of the National Environmental Management Air Quality Act and appropriate measures

are required in order to adhere to the applicable standards Other sources of impact on

air quality include emissions from the LNG burner emissions and dust from the transport

of steel and other materials in trucks as well as dust and gas emissions related to

construction activities Mitigation measures recommended in the EMP will ensure that air

quality impacts are kept to a minimum and compliance with emissions standards is

maintained

Biodiversity and conservation

Certain types of vegetation in the IDZ are of high conservation importance Protected

species will be rescued as per the CDCrsquos requirements

Water quality

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through spills

or leaks This risk can however be minimized if not avoided altogether through design

choices (bunded areas) and the adherence to best practice guidelines for the handling or

the transport of hazardous substances and waste

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vi

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

Waste management and hazardous substances

The plant will generate a relatively small amount of solid waste which will be re-used

recycled or disposed of in accordance with the EMP recommendations

There will be a wastewater treatment plant on site which will neutralise process water

(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer

Hazardous waste from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site

at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and

removed on a monthly basis is limited to 10 m3

A number of substances classified as hazardous are used in the galvanizing process and

the transport and handling of these is subject to certain rules and guidelines

In addition the permanent storage of a high quantity of liquid petroleum on site (20 000

litres at any one time) is subject to certain specifications and requires approval from the

municipality

Health and safety

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling of the various substances used will be done in

accordance with applicable instructions (cf material safety data sheets)

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as provide

site supervision including executing tests (individual test cold run and hot run) during 3

months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the EMP

Traffic

In the operational phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and from

the Port of Ngqura

The traffic expected to be generated during construction as well as operation is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low and

the total traffic generated by Casa Steel is also relatively low

The impact on port traffic is also negligible and well within the portrsquos capacity

Socio-economic aspects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vii

The proposed galvanizing plant will make a positive contribution by creating jobs during

construction and operation and generating business for the various service providers

Fatal flaws

No fatal flaws have been identified

The significance of these potential key environmental impacts were assessed in the EIA

phase and the findings of this phase of investigations are presented in this report

The main findings of the EIA are as follows

During construction impacts post-mitigation are low with the exception of noise and

biodiversity as the construction of the plant will result in the destruction of habitat

and loss of fauna and flora and noise impacts inherent to construction activities

Mitigation measures have been included in the EMP for these impacts and they have

a medium significance post-mitigation

All impacts were assessed as low during operation after mitigation

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium

to long term similar impacts are likely to occur due to ongoing developments in the

IDZ

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

The CDC has its own requirements regarding the monitoring of certain aspects of the

project such as the quality of the effluent and the noise levels These have been

incorporated into the EMP Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as other

infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified and

assessed No fatal flaws have been identified

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 viii

It is recommended that the project be approved subject to the conditions listed above

and adherence to the EMP recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-1

1 INTRODUCTION

11 BACKGROUND

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)

Nelson Mandela Bay Municipality Eastern Cape Province

The demand for galvanised steel products is high in South Africa and Africa and is

expected to increase in the foreseeable future From an economic point of view the

proposed project has therefore been found to be viable

Casa Steel will source the steel coils from various markets internationally and in

South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is

destined to be exported mainly to African countries

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

An Environmental Impact Assessment (EIA) is required as the proposed project

involves several activities listed in terms of Section 24 of the National Environmental

Management Act (NEMA) No 107 of 1998 as amended and requires an

environmental authorisation

The following listed activities requiring environmental authorisation have been

identified

Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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 metres

Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped

land to industrial use greater than 1 ha but less than 20 ha in size outside an

urban area

Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any

process or activity requiring a license in terms of national or provincial legislation

governing the generation or release of emissions

Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5

hectares or more of vegetation where 75 or more of the vegetative cover

constitutes indigenous vegetation except where such removal of vegetation is

required for

(i) purposes of agriculture or afforestation inside areas identified in

spatial instruments adopted by the competent authority for

agriculture or afforestation purposes

(ii) the undertaking of a process or activity included in the list of waste

management activities published in terms of section 19 of the

National Environmental Management Waste Act 2008 (Act No 59

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-2

of 2008) in which case the activity is regarded to be excluded from

this list

(iii) the undertaking of a linear activity falling below the thresholds in

Notice 544 of 2010

Hot dip galvanizing is a listed activity in terms of section 21 of the National

Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires

an Atmospheric Emissions Licence (AEL)

In addition the treatment of wastewater with an annual throughput capacity of more

than 2000 m3 is a listed activity in terms of the National Environmental Management

Waste Act 59 of 2008 and requires a waste management licence

ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental

Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact

Assessment process in terms of section 24 of NEMA for the construction and

operation of the proposed galvanizing plant The EIA process covers all aspects of

the project and informs all three applications (for environmental authorisation waste

management licence and AEL)

13 PURPOSE OF THIS REPORT

This report builds on the scoping report submitted to the Eastern Cape Department of

Economic Development and Environmental Affairs (DEDEA) and the Nelson

Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It

describes the proposed project and presents the findings of the second phase of

investigations (EIA phase)

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT

PRACTITIONER (EAP)

The EIA was managed by Ms Terry Baker a certified Environmental Assessment

Practitioner with 20 years of working experience She has a MA in Environmental

Management and specialises in Environmental Impact Assessments and Project

Management She has been involved in a variety of different types of EIAs including

for water supply projects dams transmission lines roads and airports in South

Africa Botswana Uganda Lesotho and Mozambique She has been involved in

water resource management and public participation programmes on a number of

projects Terry has also been involved in the use of Geographic Information Systems

environmental status quo reports water quality assessments socio-economic and

institutional development projects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-3

15 PROJECT TEAM

In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen

(water quality specialist) and Lea September (EAP) with specialist input from Renee

von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous

substances) and Seniel Pillay (Traffic Impact Assessor)

The Business Unit Head of the ILISO Environmental Management Discipline Group

Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is

a Fellow of the South African Institution of Civil Engineers a member of the South

African Society of Aquatic Scientists of the Environmental Scientific Association of

the International Water Association of the Water Institute of South Africa and of the

Vaal River Catchment Association He is a certified Environmental Assessment

Practitioner with 30 years experience who specialises in project management

environmental impact assessments and water resource planning He specifically has

extensive experience in water quality especially water quality management water

quality monitoring and water quality assessment Martin has experience in managing

projects that involve multi-disciplinary teams and public consultation and

participation in South Africa and abroad

Lea September is an Environmental Assessment Practitioner with a Masters degree

in Environmental Management She has experience in impact assessment and

environmental management and has been responsible for drafting impact

assessment reports and Environmental Management Programmes and conducting

public participation processes as well as high level environmental screenings for a

variety of projects in the energy water transport and industrial sectors

Renee von Gruenewaldt has nine-years experience in the field of air pollution

impact assessment and air quality management Prior to becoming involved in air

quality consultation she was part of the Highveld Boundary Layer Wind Research

Group based at the University of Pretoria Since joining Environmental Management

Services (the company now Airshed Planning Professionals) she has undertaken

numerous air pollution impact studies and has provided extensive guidance to both

industry and government on air quality management practices

Pieter Smuts graduated as a Civil Engineer and became involved in the field of

municipal engineering and infrastructure construction He has specialized during the

last twelve years in solid waste management He has completed waste management

plans feasibility studies and final designs of waste management facilities in South

Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and

the review of the Mavoco hazardous waste landfill design in Maputo Mozambique

and completed a study on hazardous waste (textile factory sludge) management in

Maseru Lesotho

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-4

Seniel Pillay is a transportation engineer with over 16 years experience in

transportation planning and traffic engineering He has been involved in a wide

range of projects ranging from developing the Transport Operations Plan for the

FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System

for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller

traffic impact assessments for inter alia road improvement schemes Of particular

relevance to this project his experience includes Heavy Goods Vehicle Study for

eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact

Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash

Preliminary Transportation Assessment

16 STRUCTURE OF THIS REPORT

The proposed project and the alternatives considered are described in Chapter 2

Chapter 3 details the approach adopted for the EIA phase

The biophysical and socio-economic environment affected by the activity is described

in Chapter 4

The environmental impacts identified are discussed in Chapter 5

The EIA methodology is described in Chapter 6 and Chapter 7 presents the results

of the impact assessment

The environmental impact statement is presented in Chapter 8

Finally Chapter 9 spell out the conclusions and recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-1

2 DESCRIPTION OF THE PROPOSED PROJECT

21 TECHNICAL ASPECTS

211 The galvanizing process

Galvanizing consists of coating steel with zinc in order to protect it from corrosion

Before steel strips can be galvanized they undergo a pre-treatment in order to

ensure that the steel sheets are free from any surface oxides as they enter the

molten zinc coating Bath This is done by removing the oil from the steel sheets (in

the degreasing unit) and then removing the rust from the surface of the sheet (in the

pickling unit)

The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The

melting zinc on the strip surface will be cooled and solidified through air cooling in the

cooling tower

Finally the galvanised steel sheets are dipped into a water quenching tank in order to

further cool the sheets from about 150degC to 40degC

It is possible to make galvanised steel more durable by chromating it Approximately

50 of the galvanised steel production output will receive chromate passivation

treatment after quenching the galvanised steel sheets will be sprayed with a chrome

solution (3 kgcm2)

After galvanizing and chromating the steel sheets are cut to achieve the desired coil

size and weight and transported to the storage yard

The process flow diagram below (Figure 1) illustrates the main stages of the

galvanizing process and indicates the major inputs and outputs as well as the

resulting effluent and atmospheric emissions

Draft Environmenal Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-2

Figure 1 Process flow diagram for proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-3

212 Main inputs and outputs in operational phase

In view of the above the main inputs will be as follows

Steel coils 85 000 tonsyear

Zinc 870 tonsyear

Electricity 2500 kVA

Water 2000 m3month (of which 400 m3 will be potable water)

Liquid Natural Gas (LNG) 270 NM3hour

Sodium hydroxide (NaOH) 1000 m3year

Hydrochloric acid (HCl) 800 m3year

Chrome (Cr+3) 10 m3year

The main outputs will be

Galvanized steel 80 000 tonsyear

Scrap metal 20 tonsyear

General waste 65 tonsyear

Hazardous waste 2 m3month

Wastewater 012 Mlweek

Atmospheric emissions lt 5 ppm

213 Installations on site

The bulk of the operations involved in the galvanizing process occur along a

continuous galvanizing line (See Figure 2 below) which is the main piece of

machinery required for the proposed galvanising plant

Figure 2 Continuous Galvanizing Line

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-4

Water is one of the major inputs and is used throughout the galvanizing process notably

for rinsing and cooling purposes and as a mixing agent for the various chemical

solutions The plant will have a water treatment plant on site to treat the water used in

the various processes (approx 250 m3

of wastewater per week) The wastewater

treatment facility will be operated by a professional water treatment company as Casa

Steel does not have the required expertise in house to treat its process water Sulphuric

acid (H2SO4) is used as part of the treatment process to reduce caustic soda The

neutralised water is discharged to the sewer while any sludge is disposed of as

hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)

will be disposed of

Some critical areas of the galvanizing process such as the zinc pot require uninterrupted

power It is therefore proposed to install an LNG burner to maintain the zinc bath at a

temperature of between 450 and 460degC

22 LOCATION OF THE PROPOSED GALVANIZING PLANT

The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast

of Port Elizabeth in the Eastern Cape (Figure 3)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-5

Figure 3 Location of the proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-6

23 NEED AND DESIRABILITY

The profitability of the proposed project has been established by Casa Steel and a

pre-feasibility study has confirmed that the proposed project was feasible from a

technical and financial point of view The Coega IDZ is specifically designed to host

facilities such as a galvanizing plant and can provide the necessary infrastructure

and services to its investors It therefore constitutes a very suitable location for the

project

24 ALTERNATIVES IDENTIFIED

Zone 6 has been specifically earmarked for heavy ferrous metal industries and is

therefore a suitable location for the proposed galvanizing plant as such no site

alternatives have been provided for and assessed in this EIA However prior to the

commencement of the EIA process Casa Steel was presented with a number of

different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the

selection of the site were

(a) The dimensions of the land the site should be at least 200 m long and

50 m wide in order to accommodate the galvanizing line and adjacent lay

down area and additional land should be available next to the site for future

expansion

(b) The fiscal arrangements applying to the site the site should be located

within the future Custom Controlled Area (CCA) as the bulk of the

production output of the plant will be exported

The no-go alternative is assessed in this report

25 CONSTRUCTION ASPECTS

The construction phase of the project will take about 12 months and will essentially

consist of erecting a building to house the galvanizing line and other equipment and

preparing a concrete laydown area adjacent to the building

The CDC will provide an access point from the existing tarred road that will lead to

the site

Approximately 100 workers from the surrounding areas will be contracted for the

construction work

The requirements in terms of services during construction are listed below

Water 1000 m3month

Electricity 2500 kVA

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-7

The CDC will provide temporary services for the construction phase including a

conservancy tank for flush toilets Sewage infrastructure will only be provided for the

operational phase

26 OPERATION ASPECTS

Before the plant can become fully operational the equipment and machinery will be

tested for approximately 3 months The supplier will supervise these tests as part of

the transfer of know-how and training of staff on the plant

Casa Steel will start operating the plant at a reduced capacity (about 50 000

tonsyear) for a period of time (mostly determined by market aspects) before bringing

production to full capacity (80 000 tonsyear) This is done by operating the line for

longer hours

Approximately 50 to 60 people will be working on the plant Approximately 6-10 of

these will be unskilled 40-45 skilled and about 5 people in managerial positions

The requirements in terms of services during operation are as follows

Water 2000 m3month

Electricity 2500 kVA

Effluent discharge 24 m3day

The CDC has entered into agreements with the municipality to secure the provision

of services such as water and electricity to its tenants Tenants in the IDZ have their

own agreements with the NMBM for electricity while the agreements for water and

sewage are with the Facilities Unit of the CDC

Regarding discharge of wastewater to the sewer the municipality indicated that the

only requirement is that the water discharged complies with applicable municipal

discharge standards

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 3-1

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT

31 OBJECTIVES

The main objectives of the EIA phase are to

Assess the significance of the environmental issues and impacts identified in the

scoping phase focusing on key impacts

Recommend appropriate measures to mitigate negative impacts and enhance the

benefits and include them in the draft EMP

Undertake a public participation process that provides opportunities for all

interested and affected parties (IampAPs) to be involved

32 AUTHORITY CONSULTATION

The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental

Liaison Committeersquo (ELC) which comprises representatives of various authorities

including DEDEAT the Department of Environmental Affairs (DEA) and Department

of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the

Coega Development Corporation (CDC) and Transnet National Ports Authority

(TNPA) The ELC has been specifically formed to facilitate EIA applications in the

IDZ

Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to

the clearance of vegetation should be included in the application A formal request

was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the

application and all registered stakeholders were informed of the request in writing on

19 October 2011

33 PUBLIC PARTICIPATION PROCESS CONDUCTED

On-site notices were replaced by a notification displayed on the CDCrsquos digital notice

board at the business centre in Zone 1 of the IDZ The eNotice was placed on

13 April 2011 and will remain for the full duration of the EIA process

Registered stakeholders will be notified in writing of the availability of the draft EIA

report and EMP which will also be advertised in a local newspaper Stakeholders

including state departments and the public will have forty (40) days to comment on

the draft EIA report and EMP The draft EIA report and EMP will be sent by email

where possible and made available for download on the ILISO website

(wwwilisocom)

A summary of all issues and comments received during the stakeholder consultation

process as well as of correspondence in that regard will be captured in an Issues

and Responses Report that will form an Appendix to the EIA Report

The list of registered IampAPs is included in Appendix A

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 3-2

34 LEGISLATION AND GUIDELINES CONSIDERED

The following legislation and guidelines were considered in the preparation of this

report

National Environmental Management Act Act No 107 of 1998

NEMA EIA Regulations 2010

National Environmental Management Air Quality Act Act No 39 of 2004

National Environmental Management Waste Act Act No 59 of 2008

Hazardous Substances Act Act 15 of 1993

Occupational Health and Safety Act Act 85 of 1993

Hazardous Chemical Substances Regulations 1995 (GNR 1179)

Major Hazard Installation Regulations 2001 (GNR 692)

National Water Act Act 36 of 1998

National Heritage Resources Act Act 25 of 1999

DEAT Integrated Environmental Management Information Series 1-5 and 12-15

NEMA draft Implementation Guideline

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Public Participation (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Alternatives (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Draft Guideline for Determining the Scope of Specialist

Involvement in EIA Processes (2005)

IAIA guidelines

National air quality standard for thoracic particulates Government Gazette

No 32816

Listed activities and associated minimum standards identified in terms of section

21 of the National Environmental Management Air Quality Act Act No 39 of

2004 Government Notice 248 of 2009

Minimum Requirements for the Handling Classification and Disposal of

Hazardous Waste DWAF Waste Management Series (1998)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-1

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION

The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega

IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay

to the north of the N2 highway between Port Elizabeth and Grahamstown east of the

Coega River

The co-ordinates of the corners of the site are shown in Table 1

Table 1 Coordinates of site corners for the proposed galvanizing plant

Point Longitude Latitude

A 25deg411126E 33deg45587S

B 25deg411156E 33deg45499S

C 25deg411938E 33deg45131S

D 25deg412174E 33deg45481S

E 25deg412508E 33deg45979S

F 25deg412634E 33deg451160S

G 25deg411782E 33deg451560S

H 25deg411692E 33deg451428S

J 25deg411314E 33deg45868S

Figure 4 Zone layout in the Coega IDZ

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-2

Figure 5 Site location

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-3

42 SOCIO-ECONOMIC CHARACTERISTICS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the

NMBM There are no residents within the IDZ

As far as the broader NMBM and Eastern Cape Province are concerned the

following can be noted The NMBM is located within the Eastern Cape Province the

2nd largest Province in South Africa (3rd in terms of population) characterised by a

predominantly black population with low incomes and high levels of unemployment

(CES 2010)

The NMBM has a population of just above 11 million and covers an area of

1 950 km2 It is the main urban and industrial centre of the province and Port

Elizabeth in particular which forms part of the NMBM is the commercial capital of

the Eastern Cape 52 of the NMBM population is female and 37 is below the

age of 20 these two groups are particularly affected by unemployment

43 BIOPHYSICAL CHARACTERISTICS

431 Surface and ground water

No rivers occur in Zone 6 There is however a natural attenuation pond on the

southern most part of the site which will have to be avoided

The IDZ is underlain by calcrete sand and gravel deposits that overlie low

permeability clays These clays limit the vertical infiltration of rainwater and induce a

horizontal groundwater flow towards the Coega River channel which is the most

significant surface water feature in the Coega IDZ Consequently rapid run-off takes

place following precipitation (Jacobs 2008)

Groundwater levels at Coega are generally about 3 to 5 m below surface ie just

above the contact between the permeable sands and the underlying impermeable

clays The groundwater flow direction is to the southeast following the surface water

drainage direction (Jacobs 2008)

432 Climate and atmospheric conditions

Port Elizabeth has a warm temperate climate and the temperature ranges are not

extreme Exceptionally high temperatures may be experienced during berg wind

conditions which occur frequently during autumn and winter Extreme temperatures

also occur during summer with little accompanying wind

The wind regime for the area largely reflects the synoptic scale circulation with

dominant westerly and northwesterly flow fields representing the pre-frontal

conditions and south-westerly flow fields representing the frontal conditions The

south-easterly and south-westerly wind flow (land breeze) increases during daytime

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-4

conditions with westerly and north-westerly wind flow increasing during the night (sea

breeze)

The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of

Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15

km southwest) and Port Elizabeth (~23 km southwest)

An ambient air monitoring network has been established in the Coega IDZ which

consists of three monitors Saltworks Motherwell and Amsterdamplein Although

NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative

impacts due to the proposed Galvanising Plant is PM10 A maximum daily average

PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed

SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3

was exceeded on 17 days in 2007 and 26 days in 2008

Existing sources of emissions in the vicinity of the proposed galvanizing plant include

industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other

fugitive dust sources (von Gruenewaldt 2011b)

433 Geology and soils

Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel

and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly

limestone and conglomerate

434 Terrestrial ecology

This section draws from the EIA report compiled for the Agni Steel (formerly Afro-

Asia) steel processing facility which is adjacent to the proposed site for the

galvanizing plant (Jacobs 2008)

The area consists largely of grasses succulents and scrubby bush with alien

species making up the greater part of the more dense vegetation

Zone 6 falls within the inland vegetation and is characterised by a vegetation type

referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the

Coega IDZ and has been found to have three times the level of endemism of other

vegetation communities in the Coega IDZ Bontveld therefore has a high

conservation status Two Bontveld conservation areas have been identified within the

IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)

Bontveld that will be destroyed as a result of development in the IDZ will be given

conservation status in these two areas

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-5

Figure 6 Coega IDZ Open Space Management Plan (OSMP)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-6

Certain areas in the IDZ are invaded by alien plant species The most common

invader species is rooikrans (Acacia cyclops) which presently forms large

monospecific stands in areas throughout the Coega IDZ There are several other

aliens present that pose a threat to the flora of this area including the prickly pear

(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)

Loss of vegetation and alien plant invasion due to human activity has resulted in a

reduction in the diversity of terrestrial fauna

The majority of mammals present in the Coega IDZ are small or medium-sized Of

the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed

gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of

Algoa Bay however it is not considered threatened The gerbil is common in

foredune and dune thicket habitat in the Coega region and is therefore unlikely to

occur on the proposed site

A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird

species are resident or common to the area Most diversity occurs in the thicket

although the coastal area also supports specialised avifauna Two species of tern

the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well

as the Cape gannet (Morus capensis) and the African penguin (Spheniscus

demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne

caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant

(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser

flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns

are two of the most endangered coastal species in South Africa Other bird species

of conservation concern include the Whitefronted plover (Charadrius marginatus)

African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus

bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus

ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides

paradisea) Breeding pairs of Damara terns and African black oyster catchers have

been observed in the coastal dunes of the IDZ but should not be affected by

developments that fall outside the dune areas

The Eastern Cape supports nearly a third (approximately 133 species) of the reptile

species recorded in South Africa More than half of the Eastern Capersquos endemic

reptile species occur in the Algoa Bay area giving the region a high conservation

value A total of 63 reptile species are believed to occur within the Coega IDZ The

majority of these are found in Succulent Thicket and riverine habitats Only a few

reptile species occur in the coastal dunes and estuarine habitats More than a third of

the species are described as relatively tolerant of disturbed environments provided

that migration corridors of suitable habitat are maintained to link pristine habitats

Twenty two reptiles are of special concern including five endemic species (two of

which may also be endangered) four endangered sea turtles eight species listed

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-7

with CITES one rare species and four species at the periphery of their range

Fourteen of these species of special concern are confirmed as occurring on or within

2 km of the Coega IDZ

A total of 32 amphibian species and sub-species occur in the Eastern Cape

representing almost a third of the species recorded in South Africa However none of

the species are endemic or Red Data Book species Based on previous studies in the

area it is estimated that approximately 17 amphibian species occur within the Coega

IDZ Four species are listed as peripheral but none are threatened internationally

These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog

(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and

the bubbling kassina (Kassina senegalensis)

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated

vegetation has not been extensively studied One grasshopper species Acrotylos

hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue

(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis

pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in

four localities in the Eastern Cape one of which is within the Coega IDZ The Coega

copper Aloeides clarki is endemic to this particular region of the Eastern Cape and

is currently known to occur in three localities two of which are in the Coega IDZ The

localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the

Coega IDZ and their distributions were taken into account when defining Coegarsquos

open space system and Development Framework Plan

435 Land use and topography

The land is currently undeveloped and earmarked for industrial development The

site is relatively flat ranging from an elevation of 66 masl on the northern-most

corner to 59 masl at the southern-most corner

436 Heritage and archaeological survey

Extensive studies have been undertaken in Zone 6 with respect to heritage aspects

Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a

2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond

2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is

currently being finalised

Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing

Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha

in extent and was located next to the R102 road to Motherwell Kaplan conducted

HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi

Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will

now be located in Zone 5)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-8

The various archaeological investigations reached similar observations and

conclusions Stone tools of various densities and types were found throughout the

zone The majority of the stone tools were mainly of Earlier and Middle Stone Age

and occasional Later Stone Age origins (Figure 4)

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble

gravels exposed by tracks in Zone 6 (Source Binneman 2010)

The stone tools which comprised of quartzite flakes chunks flaked pebblecobble

and cores were randomly distributed across the landscape and are in secondary

context There were no lsquoconcentrationsrsquo of tools observed which suggested any

spatial patterning or activity areas although these may be present or covered by soil

and vegetation

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 5-1

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED

The following environmental issues and potential impacts were identified in the

Scoping phase

51 AIR QUALITY

The galvanizing process generates atmospheric emissions with particulates and

hydrogen chloride representing the main pollutants of concern The plant is fitted with

air extraction as well as scrubber systems which are designed to retain the bulk of

pollutants and particles for each of the processes in such a way that less than 5 ppm

of gases and particles will be released into the atmosphere after the fume scrubber

Other sources of impact on air quality include emissions from the LNG burner as well

as emissions and dust from the transport of steel and other materials in trucks

Construction activities will also create dust and gas emissions due to the clearing of

groundcover tipping of material to storage pile levelling of area wind erosion from

storage piles vehicle and construction equipment activity and tailpipe emissions

from vehicles and construction equipment such as graders scrapers and dozers

Overall the air quality impact assessment (Gruenewaldt 2011b) found that

The predicted particulate oxides of nitrogen carbon monoxide and sulphur

dioxide concentrations are all below the National Ambient Air Quality Standards

for all averaging periods

The predicted off-site concentrations of hydrogen chloride are well below the

most stringent effect screening levels

No odour threshold exceedances for hydrogen chloride were predicted to occur

due to routine operations at the Steel Galvanising Plant The South Wales

Environmental Protection Authority stipulates that an odour unit of 20 is

acceptable for urban areas The odour unit would be lt10 directly off-site for

hydrogen chloride

Abnormal emissions can occur in exceptional circumstances Start-up will not

cause abnormal emissions as the scrubbers will be commissioned first and will be

functioning once the plant starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions would be emitted as a

building fugitive

The hourly hydrogen chloride ground level concentrations (directly offsite) were

predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based

on the emission limits as stipulated for listed activities for galvanising processes)

using a screen model which assumes worst case meteorological conditions The

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-2

health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming

abnormal emissions emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset conditions will still

be well within the health effect screening levels

Similarly the hourly particulate emissions from the building fugitives during upset

conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for

listed activities for galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly

off-site

Therefore if emissions are 5 times higher normal they will still be within health effect

screening levels and the daily PM10 NAAQS levels

In the case of a fire a cocktail of gases and particulates could be emitted and could

be over the recommended levels This situation will however be dealt with as an

emergency and normalised as quickly as is possible

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS

The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of

its heritage potential and there are no proposed protected geosites in Zone 6

Should any artefacts be discovered during construction procedures stipulated in the

draft EMP will apply

53 BIODIVERSITY AND CONSERVATION

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

In terms of terrestrial fauna the CDCrsquos open space management plan provides for

the preservation of certain corridors The destruction of certain habitats as a result of

the development will therefore not automatically result in the loss of certain species

54 WATER QUALITY

There is a natural attenuation pond on the southern most part of the site which will be

avoided

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through

spills or leaks

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-3

This risk can however be minimized if not avoided altogether The floor of the factory

will be designed as a bunded area to contain any spills and the entire process will be

contained Potential spills or leaks will therefore be contained and will not impact on

water resources Storm water is therefore considered clean water under normal

operational conditions An oil trap will be placed at the exit of the site to ensure that

no grease from the laydown area enters the stormwater system

Spills and leaks can occur during the handling or the transport of hazardous

substances Best practice guidelines will be followed to ensure that this risk is

adequately managed

Wastewater discharged to sewer will be treated to comply with municipal discharge

standards and is not expected to have an impact on the chemical characteristics of

the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be

discharged from the plant is small in relation to the total volume received at the

Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works

(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently

operated at 61 of its capacity which is approximately 80 Mℓday Thus the

0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore

not have any significant impact on the WWTW

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES

The plant will generate a relatively small amount of solid waste in the form of scrap

metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)

The scrap metal may be sold to other steel processing facilities such as Agni Steel

which will be located next to the plant or collected and disposed of with the rest of

the solid waste by a licensed service provider

As mentioned previously there will be a wastewater treatment plant on site which will

neutralise process water (012 Mlweek) in order to ensure it is of a standard

acceptable for discharge to sewer Waste in the form of sludge from the

neutralization or spent acid must be disposed of as a hazardous waste Solid waste

from the filters used for air quality control is also in this category These wastes can

usually be tested and then delisted which means that it can be placed in a general

purpose landfill

Hazardous effluent from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-

site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored

and removed on a monthly basis is limited to 10 m3

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-4

A number of substances classified as hazardous are used in the galvanizing process

(Table 2) and the transport and handling of these is subject to certain rules and

guidelines In particular the material safety data sheets (cf Appendix H) should be

referred to for inter alia hazards identification accidental release measures

handling and storage precautions exposure controlpersonal protection ecological

information and transport information The Hazardous Chemical Substances

Regulations 1995 should also be adhered to in respect of the transport and storage

of hazardous chemical substances

Table 2 Hazardous materials to be used on site

Major Input Materials

Substance

listed in the

SABS 0228

Group II

hazardous

substances

Volumes to be

stored on site at

any one time

Diesel radic 2000 litres

Liquid petroleum radic 20 000 liters

Sodium hydroxide (NaOH)

(used for degreasing) 8 radic 1000m

3

Hydrochloric acid (HCI)

(used for pickling) 8 radic 800m

3

Zinc (used for galvanising) - TBD

Trivalent chromium (CR+3

)

(used for chromating) 8 radic 10m

3

Sulphuric acid (H2SO4) (used for

treatment of waste water on site) 8 radic TBD

Ammonium Hydroxide (NH4OH) 8 radic TBD

TBD ndash To be determined

Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one

time) and is classified as a flammable substance Specification for flammable storage

facilities in accordance with the requirements of the Nelson Mandela Bay

Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for

quantities between 5000 and 20 000 liters the substance must be kept in a

flammable liquid store which complies with the requirements of a specification

obtainable from the Department Some of the requirements are

Flammable liquid and solid storage facilities are only permitted on the ground

floor

Decanting of flammable liquids and solids are not permitted within any building

Due to the fact that there are flammable materials on site a certificate may be

required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and

Emergency Services Department to confirm that facilities for flammable storage

are in accordance with their requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-5

Because of the permanent installation and high quantity of liquid petroleum on site

the Major Hazard Installation Regulations 2001 promulgated under the Occupational

Health and Safety Act No 85 of 1993 applies A written application for approval of

the installation is required to be submitted to the chief inspector Department of

Labour provincial director Department of Labour and NMBM prior to construction

In addition a risk assessment should be formulated covering all hazardous materials

together with an emergency preparedness and response plan

56 HEALTH AND SAFETY

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling instructions as well as occupational exposure limits

are indicated in the material safety data sheets of the various substances used

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as

provide site supervision including executing tests (individual test cold run and hot

run) during 3 months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the

EMP

In addition the emergency preparedness and response plan will cover the health and

safety aspects related to emergency situations

57 TRAFFIC

The volumes of traffic at the IDZ are currently relatively low and variable depending

on the different zones in the IDZ however these volumes will increase as more

developments are implemented

The construction phase of the Casa Steel development will take about 12 months

and will essentially consist of erecting a building to house the galvanizing line and

other equipment and preparing a concrete laydown area adjacent to the building

The traffic that would be generated during the construction phase can be expected to

be less than the traffic that would be generated by the Casa Steel development when

it is fully operational

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-6

In the operation phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and

from the Port of Ngqura

The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the

Casa Steel development would be off Ring Road 1 The other roads of significance

for the Casa Steel development are the N2 Neptune Road MR435 and MR450

Access to the port is given by Neptune Road Road Link NEP-03 has not yet been

built

Figure 8 Coega IDZ road network identification

(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-7

Figure 9 Coega IDZ road network

Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No

01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-8

The distribution of freight trips is fixed as the majority of trips will be made between

the Port of Ngqura and the Casa Steel site With regard to personnel trips there are

various points of origins (the surrounding residential areas) that could be used by

staff going to the Casa Steel site The distribution of personnel trips is based on

existing traffic count information and is shown in Figure 10

Figure 10 Trip distribution for freight and personnel trips

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The resultant expected Casa Steel traffic assignment is shown in Figure 11

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-9

Figure 11 Morning peak hour Casa Steel development traffic

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The traffic that is expected to be generated by the Casa Steel development is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low

and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)

Consultation has taken place with Transnet Port Authority (TPA) to establish the

impact of the galvanizing plant operations on traffic inside the port The additional

ships entering and exiting the port of Ngqura as a result of the proposed development

will have a negligible impact on port traffic and TPA indicated that it would be well

within the portrsquos capacity

58 NOISE

Noise is not foreseen to be a significant issue insofar as the noise levels inside the

plant and at the boundary of the site will not exceed the limits prescribed by the CDC

Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels

during the day and 60 decibels at night

Mitigation of noise impacts will be addressed in the design of the noise-emitting

components of the plant and their enclosures

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-10

59 SOCIO-ECONOMIC ASPECTS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of

NMBM There are no residents within the IDZ

The direct socio-economic impacts of the proposed project are thus limited to the

employment generated by the project during construction and operation Job creation

remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)

and the IDZ and Port of Ngqura are expected to become a significant catalyst to the

economic growth of the Municipality and the region with current investments at

Coega creating more jobs and stimulating the economy

In this context the proposed galvanizing plant will make a positive contribution

towards the achievement of these goals

There will be 50 to 60 employees during operation phase distributed as follows

Figure 12 Casa Steel organisation chart

Even though a large part of the inputs will be imported and the bulk of the production

output will be exported there will be some positive impacts for the economy of the

region and of South Africa in general Notably the requirements of the plant for

water electricity waste collection and disposal waste water treatment and transport

for example will create business for the various service providers and have an

indirect impact on employment and fiscal revenues as a result

From a visual impact point of view it can be anticipated that the landscape in the IDZ

will be significantly affected over time by developments related to the establishment

of the port and various industries

HEAD ( WORKS )

MGR ( COMM) MGR ( ADMNHR ) Manager marketing

MANAGER OPERATION MANAGER MANAGER MANAGER Q C

AC FIN PUR ampSTORE

PPC SH-GALV SH-tech

SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF

1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO

JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF

2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO

WORKERS WORKERS 7NOS

15 7

RAW MAT amp

DESP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 6-1

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY

A description of the nature of the impact any specific legal requirements and the

stage (constructiondecommissioning or operation) will be given Impacts are

considered to be the same during construction and decommissioning The

significance of the potential impacts will be considered before and after identified

mitigation is implemented

The following criteria will be used to evaluate significance

Nature The nature of the impact will be classified as positive or negative and

direct or indirect

Extent and location Magnitude of the impact and is classified as

Local the impacted area is only at the site ndash the actual extent of the activity

Regional the impacted area extends to the surrounding immediate and

neighbouring properties

National the impact can be considered to be of national importance

Duration This measures the lifetime of the impact and is classified as

o Short term the impact will be for 0 ndash 3 years or only last for the period of

construction

o Medium term three to ten years

o Long term longer than 10 years or the impact will continue for the entire

operational lifetime of the project

o Permanent this applies to the impact that will remain after the operational

lifetime of the project

Intensity This is the degree to which the project affects or changes the

environment and is classified as

o Low the change is slight and often not noticeable and the natural functioning

of the environment is not affected

o Medium The environment is remarkably altered but still functions in a

modified way

o High Functioning of the affected environment is disturbed and can cease

Probability This is the likelihood or the chances that the impact will occur and

is classified as

o Low during the normal operation of the project no impacts are expected

o Medium the impact is likely to occur if extra care is not taken to mitigate

them

o High the environment will be affected irrespectively in some cases such

impact can be reduced

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 6-2

Confidence This is the level knowledgeinformation the environmental impact

practitioner or a specialist had in hisher judgement and is rated as

o Low the judgement is based on intuition and not on knowledge or

information

o Medium common sense and general knowledge informs the decision

o High Scientific and or proven information has been used to give such a

judgment

Significance Based on the above criteria the significance of issues will be

determined This is the importance of the impact in terms of physical extent and

time scale and is rated as

o Low the impacts are less important

o Medium the impacts are important and require attention mitigation is

required to reduce the negative impacts

o High the impacts are of great importance Mitigation is therefore crucial

Cumulative Impacts The possible cumulative impacts will also be considered

Mitigation Mitigation for significant issues is incorporated into the EMP for

construction

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 7-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS

71 IMPACTS DURING CONSTRUCTION

711 Air quality

Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris

handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine

particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural

operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks

and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)

Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Fugitive particulate emissions (dust)

related to construction activities Regional

Short

term Medium High High Medium Regional

Short

term Low High High Low

Construction vehicle gas emissions Regional Short

term Medium High High Medium Regional

Short

term Low High High Low

712 Heritage and archaeological resources

Naturedescription of impact excavation activities may impact on unidentified heritage resources

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-2

Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based

on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments

Heritage and archaeological

resources Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on unidentified heritage

resources Local

Short

term

Medium -

high Low High Low

713 Biodiversity and conservation

Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation

importance and cause soil contamination

Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species

Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan

and has compiled a list of protected species to be rescued (see draft EMP)

Biodiversity and conservation Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Loss of fauna and flora Local Perma

nent

Medium -

high High High High Local

Permanen

t Medium High High Medium

Soil contamination Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-3

714 Water related impacts

Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater

runoff spills and leaks Soil erosion

Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of

spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste

disposal Stormwater quality monitoring (see draft EMP)

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Soil erosion Local Short

term Medium Medium High Medium Local

Short

term Medium Low High Low

715 Waste management

Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed

Commentmitigation see draft EMP and waste management plan

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-4

Waste management Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Local

Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

716 Health and safety

Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Short

term

Medium -

high

Medium -

high High High Local

Short

term

Medium -

high Low High Low

717 Traffic

Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and

construction workers from surrounding areas and transport of equipment from the port

Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low

Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and

accurate estimates of quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-5

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Increased traffic on N2 and within the

IDZ Regional

Short

term Low High High Low

718 Noise

Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Short

term

Medium-

high High High Medium Local

Short

term Medium High High Medium

719 Socio-economic

Naturedescription of impact temporary employment will be created during the construction phase

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-6

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Temporary employment Regional Short

term Medium High High Medium

72 IMPACTS DURING OPERATION

721 Air quality

NatureDescription of impact gas and particulate emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning

Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local

sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and

veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute

to background fine particulate concentrations (von Gruenewaldt 2011b)

Assumptions and limitations Potential release of CR6+

As no emission factors are available for trivalent chromium processing the

potential impacts due to these activities could not be quantified

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Dust emitted from traffic on paved roads Regional Long Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-7

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

term

Hydrogen chloride emissions from

pickling process Local

Long

term Low High High Low

Particulate emissions (smoke) from

galvanizing process (due to the

volatilization of flux)

Local Long

term Low High High Low

Particulate oxides of nitrogen carbon

monoxide and sulphur dioxide emissions

from LNG burner

Local Long

term Low High High Low

Nuisance related to odour Local Long

term Low Low High Low

Abnormally high hydrogen chloride and

particulate emissions due to scrubber

malfunction

Local Short

term Medium Low High Medium

Gases (eg SOx NOx CO etc) and

smoke emitted in case of a fire Local

Short

term High Low High Medium

722 Water quality

NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks

Commentmitigation see draft EMP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-8

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Stormwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

723 Waste management and hazardous substances

NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous

waste both can affect environmental quality and human health

Commentmitigation see draft EMP and waste management plan

Waste management and hazardous

substances Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Regional

Long

term High

Medium -

high High High Regional Long term High Low High Low

Soilwaterair pollution due to improper

transport storage and handling of

hazardous substances

Regional Long

term High

Medium -

high High High Regional Long term High Low High Low

Health hazard Local Long

term High

Medium -

high High High Local Long term High Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-9

724 Health and safety

Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Long

term

Medium-

high

Medium-

high High High Local Long term

Medium-

high Low High Low

725 Traffic

Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on

the road network

Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak

hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road

network within Zone 6 of the IDZ (Iliso 2011)

Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)

Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of

quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-10

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on traffic and capacity of the N2 Regional Long

term Low High High Low

Impact on traffic and capacity of ring

road 1 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR435 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR450 Local

Long

term Low High High Low

Impact on traffic and capacity of

Neptune road Local

Long

term Low High High Low

726 Noise

Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Long

term Medium High High Medium Local Long term Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-11

727 Socio-economic

Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate

revenue for the municipality and the region as a whole

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Employment and economic growth Regional Short

term Medium High High Medium

73 COMPARATIVE ASSESSMENT OF IMPACTS

During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as

low during operation after mitigation

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 8-1

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

As a tenant operating in the IDZ Casa Steel will be required to comply with all

current and future CDC requirements as well as with the relevant conditions of

permits licences issued to CDC (eg Integrated Stormwater Masterplan for the

eastern side of the Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)

In particular the CDC has its own requirements regarding the monitoring of certain

aspects of the project such as the quality of the effluent and the noise levels These

have been incorporated into the EMP

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 9-1

9 ENVIRONMENTAL IMPACT STATEMENT

All predicted negative impacts can be mitigated to a low significance The only

exceptions are biodiversity as the construction of the plant will result in the

destruction of habitat and loss of fauna and flora and noise impacts inherent to

construction activities Mitigation measures have been included in the EMP for these

impacts and they have a medium significance post-mitigation

Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium to

long term similar impacts are likely to occur due to ongoing developments in the IDZ

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 10-1

10 CONCLUSION AND RECOMMENDATIONS

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as

other infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified

and assessed No fatal flaws have been identified

It is recommended that the project be approved subject to the conditions listed in

chapter 9 and adherence to the EMP requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 11-1

11 REFERENCES

Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ

Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants

Bennie JS (2010) The historical component (built environment) of the Heritage

Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port

Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report

compiled for Eastern Cape Heritage Consultants

Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater

Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay

Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage

Consultants

BKS (2006) Coega Industrial Development Zone Transport Study Volume 3

Demand Modelling Report Final Draft

Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I

Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6

Report compiled for SRK Consulting

Coastal amp Environmental Services (2010) Environmental Impact Assessment for the

Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone

Volume 3 Environmental Impact Assessment Report CES Grahamstown

Coega Development Corporation (2008) Industry Waste Management Plan -

Strategic Master Plan Report

Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants

Report No CDCSHE 03 8122

Department of Water Affairs and Forestry (1998) Waste Management Series

ldquoMinimum Requirements For The Handling Classification And Disposal Of

Hazardous Wasterdquo Second Edition

Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising

Plant in the Coega Industrial Development Zone

Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the

Coega Industrial Development Zone (IDZ) Specialist Water Study

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 11-2

Jacobs E (2008) Final Environmental Impact Report and Draft Environmental

Management Plan Proposed Steel Recycling and Processing Facility within the

Coega IDZ Report compiled for SRK Consulting

Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY

Galvanising Plant in the Coega Industrial Development Zone Waste Management

and Hazardous Substances Report compiled for ILISO Consulting

RSA National air quality standard for thoracic particulates (PM10) SA standards

(Government Gazette No 32816)

von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed

Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape

Report compiled for ILISO Consulting

von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel

Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report

compiled for ILISO Consulting

Additional sources

Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed

Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared

for Coastal Environmental Services

Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed

Kalagadi Manganese smelter in the Coega Industrial Development Zone Port

Elizabeth Eastern Cape Province Report prepared for Coastal Environmental

Services

Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia

steel recycling facility at the Coega Industrial Development Area Port Elizabeth

Prepared for SRK Consulting Port Elizabeth

APPENDIX A

LIST OF INTERESTED AND

AFFECTED PARTIES

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

DEDEARegional Manager

and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza

DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza

DEA Ocean and

CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza

DEA Ocean and

Coast

Oceanographer land-

based sources of

marine pollution

Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza

DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza

CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza

CDCEnvironmental

Project

Manager

Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza

TNPAPort of Ngqura

Environmental

Manager

Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet

NMBMEnvironmental

ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza

NMBMEnvironmental

ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza

DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza

DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza

WESSASenior Conservation

Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza

Zwartkops

ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700

hughlauegmailcom

zwartkopstrustiafricacom

SANParksNational Marine

CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza

Department Of

LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza

NMBM Air Quality

Division

Assistant

DirectorAir

Pollution and Noise

Templeton Titima 079 490 0574 Ttitimamandelametrogovza

NMBM Air Quality

DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza

NUMSARegional

RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

Department of

HealthNadiema

van der

Bergh083 378 2103

nadiemavanderberghimpiloecprovgov

za

DWA Chief Services

Officer

Joseph Jacobs 041 586 4884 jjacobsdwafgovza

EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza

NUMSecretary of union

officesZandile Xhentsa 043 743 6597 zxhentsanumorgza

DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza

Dynamic

CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom

EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza

Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza

UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom

lprincezago2uticom

Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza

Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza

Absa Mr Johann Steyn 082 3775820 johannstabsacoza

Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza

PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza

Universal

EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza

Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza

GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom

Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza

NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom

DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza

DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza

TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet

DWA Mr Landile Jack JackLdwagovza

DWA Ms Lizna Fourie FourieL4dwagovza

APPENDIX B

NOTICE OF ATMOSPHERIC

EMISSIONS LICENCE APPLICATION

AND ADVERTISEMENT

APPENDIX C

NOTICE OF COMMENT PERIOD FOR

DRAFT SCOPING REPORT

APPENDIX D

SUMMARY OF ISSUES RAISED AND

RESPONSES THERETO

April 2012

1

PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL

DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))

IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt

AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt

This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses

provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process

conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the

Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

2

IssueCommentQuestion Date

received Origin Response

1 Please provide more information with respect to the potential

dangers including the toxicity of the proposed project

07032011

By email

Wayne Poulton

(Bosun Brick

tenant at the

IDZ)

An Environmental Impact Assessment (EIA) was undertaken

which assessed the potential toxicity of the emissions and

effluent Mitigation measures were also recommended in the draft

Environmental Management Programme (EMP) to avoid

minimise or compensate any significant impacts The Draft

Environmental Impact Report and draft EMP were made available

to stakeholders for comment in March 2012

2 Do you have a Background Information Document (BID) or

similar that provides more information on the project

27032011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The BID was sent to all registered IampAPs on 4 May 2011

3 The RoD issued to the CDC on 632007 for the change in

land use for the remaining area of the Coega IDZ includes a

number of requirements with respect to

atmospheric emissions that should be considered in the

Atmospheric Emissions Licence (AEL) application such as

prohibiting and monitoring where possible visible emission

plumes to the atmosphere In particular the

recommendations on pp87-91 of the final revised Scoping

Report dated Nov 2006 must be implemented (clause 421)

04042011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

We have obtained copies of the documents referred to and ensure

that these requirements were taken into account in the

environmental assessment and AEL application

4 If the Port of Ngqura is used for import and export the scope

of the traffic impact assessment (TIA) should also include the

port

10052011

By email

Elliot

Motsoahole

(TNPA Port of

Ngqura)

The scope of the TIA was extended to include port related traffic

The TNPA at the Port of Ngqura was consulted and does not

have any objection to the project TNPA has indicated that the

development would require a minimum number of vessels per

year which would have minimal impact on the Port operations

However due notice would have to be given to the Port of Ngqura

before a vessel is scheduled to arrive so that the vessel can be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

3

IssueCommentQuestion Date

received Origin Response

accommodated at an available berth

5 Concerns with respect to potential stormwater pollution

draining into the Coega catchment and the port of Ngqura

The port needs to be dredged and heavy metals present a

risk in that regard

16052011

By

telephone

Andrew Lucas

(Department of

Water Affairs)

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination by effluent waste or

hazardousdangerous substances is very low

Thus no metals oils or other contaminants are expected to be

present in the stormwater

However stormwater pollution can occur in exceptional

circumstances such as accidents and emergencies The

emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

6 All steel sheets bathing unit must be under roof

7 The sludge out of the decreasing bath will be high in Na and

pH Therefore handling and disposal must be clarified up front

in this project

8 Per se the wastewater from decreasing bath will have high

ph and the component from the pickling unit will have low ph

Then it may be assumed that both streams will neutralize

each other Please then clarify proposed sewer discharge

with Nelson Mandela Bay Municipality up-front for acceptance

of influent as per the documented proposal

9 Pickling may result in dissolved metals How does your team

expect to deal with this As it is planned for discharge into

24052011

By email

Landile Jack

(Department of

Water Affairs)

All bathing units will be under roof

Effluent from the degreasing and pickling baths will be discharged

to the wastewater treatment plant The respectively alkaline and

acidic effluents will mix and neutralise each other in the

wastewater treatment plant Calcium or gypsum will be added if

required to complete the neutralisation process Effluent from the

treatment plant will be discharged to sewer Contact has been

made with the relevant officials and the Municipalityrsquos

requirements have been obtained The effluent discharged to

sewer will notably comply with the applicable discharge standards

Traces of metals (eg iron) may be present but will not exceed

prescribed thresholds The necessary authorisation will be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

4

IssueCommentQuestion Date

received Origin Response

sewer Clarity and acceptance needs to be agreed with

Nelson Mandela Bay Municipality Who owns the sewer

10 Quenching unit will results to Zinc particles How will this

affect sewer discharge This again must be dealt with within

the negotiations with the Municipality

11 Once all has been agreed with the Municipality and at the

same time due negotiations must be done with hazardous

waste courier and disposal facility to accept the hazardous

waste identified in all production lines

12 Of note is the low volume of the proposed WWTW facility ie

250 cubmweek And the no discharge of the quenching

water ie over-flow and cooling only Hence Zinc particles

generation

obtained from the municipality

The sludge from the treatment plant will be collected by a licensed

service provider and disposed of at a permitted site

The quenching bath will be periodically emptied (every 6 months)

and the water discharged will go to the water treatment plant Zinc

particles will settle in the sludge which will be disposed of at a

permitted site

Contact has been made with EnviroServ who manages the

Aloes II HH waste site regarding collection and disposal of

hazardous waste (See waste management report)

13 Investigate the potential effects of toxicity andor influence of

emissions waste and hazardous substances both in

terrestrial and marine fauna

14 With regards to water usage where is the plant going to

extract its waters used in galvanization andor waste

management process ie rainfall rivers or even from the

sea) and which avenues would be more environmental

friendly and effective

31052011

By email

A Bewana

(SANPARKS)

Emissions waste and hazardous substances are not expected to

affect terrestrial or marine ecosystems The air quality study

concluded that atmospheric emissions would not be harmful to

human health and by extension terrestrial fauna There are no

standards for air quality for defining faunal impacts therefore by

ensuring that standards for humans are complied with the impact

on fauna is deemed to be acceptable In this case the impact of

emissions on terrestrial and marine fauna are thus not significant

Solid and liquid wastes both general and hazardous as well as

hazardous substances will be stored handled and disposed of

appropriately to as not to cause harm to terrestrial or marine

fauna

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

5

IssueCommentQuestion Date

received Origin Response

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination and hence land-based

marine pollution by effluent waste or hazardousdangerous

substances is very low

The risk of emissions waste and hazardous substances to

terrestrial and marine fauna is thus very low

However pollution of terrestrial and marine ecosystems can occur

in exceptional circumstances such as accidents and emergencies

The emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

The CDC has an agreement with the NMBM to supply potable

water to the Coega IDZ Currently the infrastructure to supply

return effluent (RE) to the IDZ is not in place therefore Casa Steel

will be supplied with potable water up until such time as the

following 2 options of RE are available

1) Upgrading of the existing Fishwater Flats waste water

treatment works (between IDZ amp PE) including RE plant

and infrastructure to pipe RE to the IDZ (EIA for the

upgrade is underway)

2) Construction of a new waste water treatment works

including RE plant in Zone 9 of the Coega IDZ

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option should be investigated further between Agni and Casa The

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

6

IssueCommentQuestion Date

received Origin Response

CDC can facilitate discussions between the 2 investors

Compliance with CDC Permits amp Requirements

15 It should be made clear that tenants will be required to

comply with CDC requirements and the relevant conditions of

permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water

Licence for its Storm Water Systems on the

East Side of the Coega River that tenants will

need to take cognizance of The contents of the

ldquoIntegrated Stormwater Masterplan for the

eastern side of the Coega IDZ Oct 2010rdquo

especially the Table of best practice p53

onwards may need to be taken cognizance of

o CDC is developing an Operations

Environmental Management Plan that will place

certain obligations on tenants

16 Environmental audits and data collected during monitoring

(eg stack emissions stormwater) will need to be shared with

CDC

Air Emissions

17 Presumably permanent in stack monitoring will be required in

terms of AEL permit requirements

18 Abnormal operating conditions resulting in air emissions ndash I

could find nothing in the EIR to indicate under what

circumstances these could occur (eg start-up) potential

frequency and duration and the impact on ambient air quality

ndash these events usually result in the most problems wrt air

emissions

09042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

15 Compliance with the CDCrsquos Permits amp Requirements has

been included explicitly as a requirement in the EIR (p8-1) and

EMP (pp18 and 25) in the following terms

ldquoAs a tenant operating in the IDZ Casa Steel will be required to

comply with all current and future CDC requirements as well as

with the relevant conditions of permits licences issued to CDC

(eg Integrated Stormwater Masterplan for the eastern side of the

Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)rdquo

16 The need to communicate with the CDC on monitoring and

auditing activities was emphasised in Chapter 8 of the EMP The

following paragraphs were added

ldquoDuring construction the environmental officer will be responsible

for monitoring compliance with the EMP and authorisation

conditions and keeping records as required in the EMP andor

authorisation conditions

The ECO will conduct site inspections every two weeks audit the

records kept by the environmental officer and submit an

environmental compliance report every two months to the

authorities and the CDC (via the Environmental Monitoring

Committeersquos ECO)

During operation the health and safety officer will monitor

compliance with the EMP and the conditions of the Environmental

Authorisation Data collected during monitoring activities and any

environmental audits conducted will be shared with authorities

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

7

IssueCommentQuestion Date

received Origin Response

Water

19 Large volumes of (2000 m3mth) of water are required of

which only 400m3 needs to be potable The NMBM return

effluent system will provide non-potable water once it is

constructed What other water recycling initiatives can be

utilized to reduce potable water requirements (the ISWMP for

the eastern side of the Coega IDZ has some best practice

guidelines collecting rainwater from the roof etc)

General

20 There is no mention of how the CDC Architectural Guidelines

will be incorporated into the development (eg to prevent a

stark uniform warehouse type development)

21 Does NMBM have adequate fire services to cover this

development Apart from the large petroleum store are there

any other large fire hazards

22 Reports from the tenantrsquos ECO during construction and from

the SHE Officer during operations should be channeled to the

Coega Environmental Monitoring Committee This can be

directly or preferably via the EMCrsquos ECO (this will be while

the EMC and ECO are in place) A precedent has been set

for this in the Environmental Authorisations for Agni-Steel and

Kalagadi Manganese Smelter

23 All mitigation actions emanating from the EIR should be

summarized (preferably in a table) If compliance with them is

to be part of the Environmental Authorization from DEDEAT

then they (or the ones that DEDEAT deems to be applicable)

and the CDC (via the Environmental Monitoring Committeersquos

ECO)

The ECO (during construction) and the health and safety officer

(during operation) will report to the Coega Environmental

Monitoring Committee (EMC) via the EMCrsquos ECO (this will be

while the EMC and ECO are in place)rdquo

17 The draft EMP recommends regular monitoring of emissions

from the scrubbers and from the chromating process Additional

emissions monitoring requirements will be confirmed once the

AEL is issued Mention has been made in the EMP (pp11 and 19)

that all AEL conditions including monitoring and reporting

requirements should be adhered to

18 Abnormal emissions can occur in exceptional circumstances

Start-up will not cause abnormal emissions as the scrubbers

will be commissioned first and will be functioning once the plant

starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions

would be emitted as a building fugitive

The hourly hydrogen chloride ground level concentrations

(directly offsite) were predicted to be 239 microgmsup3 (based on the

emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits

as stipulated for listed activities for galvanising processes) using a

screen model which assumes worst case meteorological

conditions The health effect screening level for hourly HCl

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

8

IssueCommentQuestion Date

received Origin Response

should be attached to the EA as an Appendix (otherwise no

one knows about them or takes cognizance of them)

concentrations is 2100 microgmsup3 Assuming abnormal emissions

emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset

conditions will still be well within the health effect screening

levels

Similarly the hourly particulate emissions from the building

fugitives during upset conditions would amount to 293 microgmsup3

(based on the emission limits as stipulated for listed activities for

galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1

January 2015) directly off-site

Therefore if emissions are 5 times higher normal they will still be

within health effect screening levels and the daily PM10 NAAQS

levels

In the case of a fire a cocktail of gases and particulates could be

emitted and could be over the recommended levels This

situation will however be dealt with as an emergency and

normalised as quickly as is possible

The above has been added to the impact identificationdescription

and assessment sections of the EIR

19 The CDC has an agreement with the NMBM to supply

potable water to the Coega IDZ Currently the infrastructure to

supply return effluent to the IDZ is not in place therefore Casa

Steel will be supplied with potable water up until such time as the

infrastructure is in place

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

9

IssueCommentQuestion Date

received Origin Response

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option will be investigated further between Agni and Casa The

CDC has come forward to facilitate discussions between the two

investors

Other water recycling initiatives such as rainwater harvesting

have been considered but are not practical

20 The CDCrsquos Architectural and Landscape Design guidelines

contain requirements pertaining to such aspects as the height

orientation and mass and form of buildings as well as guidelines

for landscaping and signage in order to ensure an attractive

development and achieve an architectural integrity within the

Coega IDZ The plans for the proposed galvanizing plant will be

submitted to the Design Review Committee for approval as

required by the CDC

21 Casa Steel will be required to install fire hydrants according

to the NMBMrsquos standardsrequirements The CDC will provide

potable water (up until such time as return effluent is available)

and a connection to the boundary of the site which will be

connected to the fire hydrants The installation of the fire hydrants

will require approval by the Metrorsquos Fire Chief as was done for

Agni-Steel one of the investors in Zone 6

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

10

IssueCommentQuestion Date

received Origin Response

The Coega IDZ falls within the NMBM and therefore the rates and

taxes paid by the CDC covers the fire services for which the Metro

is responsible Currently the Metro has sufficient capacity to

provide fire services to the tenants within the IDZ This was

confirmed in discussion with the CDCrsquos Infrastructure

Development Unit It is however unknown at which point the

Metrorsquos Disaster Management Plan would not be able to

accommodate servicing tenants in the IDZ

The LNG burner is the only major fire hazard on the plant

22 See response to item 16 above

23 Key mitigation and management measures emanating from

the EIR were recapitulated in Chapter 9 of the EIR to form part of

the conditions attached to the Environmental Authorization from

DEDEAT All mitigation measures recommended as a result of the

impact assessment are presented in a table in the draft EMP

which is appended to the EIR (Appendix J)

24 Hydrogen chloride is one of the main emissions There are no

ambient air quality guidelines for HCl and the EIR says

concentrations will be well within health parameters

However the main problem with HCl is its corrosive effect -

there is absolutely no mention of this in the draft EIR nor air

specialist report

There needs to be some sort of comment assessment as to

whether HCl emissions are likely to impact on for example

the adjacent Agni-Steel Plant wrt corrosion - their factory

structure will be made of steel

11042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The atmospheric corrosion of metals is a complex process with

both the extent of deterioration and the mechanisms varying

considerably depending on the metal Depending on the way

pollutants are transported from the atmosphere to the corroding

surface two types of deposition processes are recognized in

atmospheric corrosion ndash dry deposition and wet deposition Wet

deposition refers to precipitation whereas dry deposition refers to

the remaining processes including gas phase deposition and

particle deposition The most important pollutants acting as

corrosive agents are sulphur and nitrogen compounds including

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

11

IssueCommentQuestion Date

received Origin Response

The EIR specialist rpt suggests monitoring HCl at ground

level on the property boundary and this is supported in case

there are complaints from neighbours

secondary pollutants and particulates Pollutants can contribute to

corrosivity individually however there may be a synergistic effect

when more than one of these pollutants is present in the

environment being affected In the field of atmospheric corrosion

sulphur dioxide is the single most investigated gaseous pollutant

and the quantification of the direct contribution of sulphur dioxide

to the corrosion process of metallic materials is comparatively well

understood (Tidblad amp Kucera 1998)

Very little work has reported on the effect of HCl on the

degradation of materials in the environment with no local dose-

response thresholds developed for corrosion occurring due to HCl

exposures This is probably because HCl which is present

outdoors in markedly reduced concentrations when compared

with SO2 has not been considered to contribute to significant

degradation of materials (Syed 2006) For this reason the

incremental corrosion due to HCl from the Coega Galvanising

Plant cannot be quantified

25 It is unacceptable for ILISO to be using CDC maps (see

figure 9 ndash pg5-6) without these maps being referenced

accordingly particularly when it appears that a CDC map has

been used and then overlaid with features by an unknown

author (ie CASA steel site Port (where the boundaries

depicted are incorrect) and a North legend which is out of

keeping with the overall cartographic intent of the original

work

26 Figure 10 is not referenced appropriately and I believe that I

commented previously in respect to references to roads not

12042012

By email

Graham Taylor

(Spatial

Development

Manager -

Infrastructure

Development

CDC)

This has been rectified in the final version of the report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

12

IssueCommentQuestion Date

received Origin Response

yet built As a result Figure 10 is confusing and clarity needs

to be provided in terms of referencing In addition the Port

shape is irregular and similar to the comment above

27 I acknowledge the emergency preparedness and response

plan but please confirm that this includes pro-active routine

monitoring of storm water leaving your premises to verify that

your assumptions of clean storm water are correct

13042012

By post

Andrew Lucas

(Director

WRampU

Department of

Water Affairs)

Pro-active routine monitoring of stormwater leaving the premises

will be undertaken This has been explicitly emphasised in

chapter 8 of the draft EMP

28 Will portablechemical toilets be used during construction

29 What provisions have been made for storm water drainage

during construction

18042012

By

telephone

Department of

Water Affairs

Port Elizabeth

Chemical toilets will be used during construction

The Casa Steel site will be located at the corner of two roads

drainage of stormwater from the site will take place through the

roadsrsquo drainage system

From Lea September [mailtoleailisocom]

Sent 11 March 2011 0935 AM

To Wayne Poulton

Cc Terry Baker

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Wayne

An Environmental Impact Assessment (EIA) will be undertaken for this project during the

next 10 to 12 months

We foresee that some of the key environmental impacts of the project will be in terms of air

quality water quality waste and hazardous substances

At this stage I am not able to give you any details regarding the potential toxicity of the

emissions andor effluent However specialist studies will be conducted as part of the EIA

that will determine the key impacts of the project Mitigation measures will also be identified

to avoid minimise or compensate any significant impacts

You are registered on the stakeholder database and you will be kept informed of progress in

the EIA process you will notably get the opportunity to access the reports produced and

provide any feedback on them

Please feel free to contact me should you need any further information

Best regards

Lea September

From Wayne Poulton [mailtowaynepbosuncoza]

Sent 07 March 2011 1257 PM

To Lea September

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

Please can you provide me with some more information as to the potential dangers including

the toxicity of this

Kind regards

Wayne

From Lea September [mailtoleailisocom]

Sent 04 March 2011 1123

To Lea September

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 March 2011 0745 AM

To Paul Martin

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 05 April 2011 0847 AM

To Paul Martin

Cc Terry Baker Renee von Gruenewaldt

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Thank you Paul for this information

I have downloaded a copy of the RoD and Scoping report you referred to and will make sure

these requirements are taken into account in the environmental assessment

Best regards

Lea September

From Paul Martin [mailtopmartinaxxesscoza]

Sent 04 April 2011 0955 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Further to my comments on 27311

Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in

the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega

IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised

scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions

including prohibiting and monitoring where possible visible emission plumes to the atmosphere

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Paul Martin

Sent Monday March 28 2011 745 AM

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 10 May 2011 0327 PM

To ElliotMotsoaholetransnetnet

Cc Terry Baker

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Mr Motsoahole

Thank you for your input on this issue

The Port of Ngqura will indeed be used for import and export At the moment the scope of

the traffic impact assessment only covers road traffic I have however relayed the matter to

our traffic specialist and we will consider this issue in the finalization of the Scoping Report I

will keep you informed of any developments in that regard

I trust this is acceptable to you

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]

Sent 10 May 2011 0855 AM

To Lea September

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

It has been noted that Casa Steel will source steel coils from various markets internationally and

in South Africa and the bulk of the plantrsquos production output will be exported to African countries

However there is no mention of logistic requirements

Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will

be used the scope of traffic impact assessment should also include the port

Regards

From Lea September [mailtoleailisocom]

Sent 04 May 2011 0747 AM

To Lea September

Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

Please find attached a letter announcing the EIA process underway for the proposed 80 000

tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as

a Background Information Document (BID) outlining the details of the project

Please contact me should you require any further information on this project

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

Elliot Motsoahole

Manager - Environment

Transnet National Ports Authority

Port of Nqqura

Port Control Building Klub Road Port Elizabeth 6212

PO Box 612054 Bluewater Bay 6212

+27 41 507 8450

+27 86 674 7729

Cell +27 83 542 5619

E-mail Elliotmotsoaholetransnetnet

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

DISCLAIMER The information contained in this communication is subject to copyright and

intended only for the use of leailisocom Unauthorised use disclosure or copying is

strictly prohibited Should a virus infection occur as a result of this communication the sender

will not be liable If you have received this communication in error please notify

elliotmotsoaholetransnetnet

From Lea September [mailtoleailisocom]

Sent 25 May 2011 1147 AM

To Jack Landile (ELS)

Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi

Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Landile

Thank you for your input

Contact has been made with the relevant Municipal Directorate and we will follow up with

them to obtain clarifications on all these issues

I have added both Lizna and yourself on the database and will keep you updated on

progress on this project

Best regards

Lea September

From Jack Landile (ELS) [mailtoJackLdwagovza]

Sent 24 May 2011 0524 PM

To Fourie Lizna (ELS)

Cc Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Hi Lizna

I missed you on this sorry

I linked Pieter twice Instead

Regards

Landile

From Jack Landile (ELS)

Sent 24 May 2011 0445 PM

To leailisocom

Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Lea

The e-mail you sent to Mr Kooverji dated 19 May 2011 refer

Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are

All steel sheets bathing unit must be under roof

The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project

Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal

Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer

Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality

Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines

Of note is the low volume of the proposed WWTW facility ie 250 cubmweek

And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles

generation

Regards

Landile

From Lea September [mailtoleailisocom]

Sent 19 May 2011 0947 AM

To Lea September

Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Stakeholder

Please find attached the remaining appendices to the draft Scoping report for the proposed

80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 June 2011 0411 PM

To Aphiwe Bewana

Subject RE Proposed 80 000 TPY Galvanizing plant in Coega

Dear Mr Bewana

Thank you for your input and apologies for the late reply

We have taken note of your comments and are will be taking them forward in the EIA phase

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Aphiwe Bewana [mailtoaphiwebewanagmailcom]

Sent 31 May 2011 1205 PM

To Lea September

Subject Re Proposed 80 000 TPY Galvanizing plant in Coega

Comment

Re Proposed 80 000 TPY Galvanizing plant in Coega

As SANParks we would like the EIA phase to investigate the potential effects of toxicity

andor influence of emissions waste and hazardous substances both in terrestrial and

marine fauna In the draft scoping report reference has been made with regards to the

terrestrial fauna but there is no attention to potential effects to marine fauna

Equally with regards to water usage where is the plant going to extract its waters used in

galvanization andor waste management process ie rainfall rivers or even from the sea)

and which avenues would be more environmental friendly and effective

Regards

Aphiwe Bewana

Marine Planner

South African National Parks

POBox 76693

NMMU

Port Elizabeth

6031

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 06 July 2011 1031 AM

To Lea September

Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Hi Lea

Irsquove reviewed the Final Scoping Report Herewith a few comments

1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the

Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a

revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the

NMBLP Please include only those in the IDZ as part of your IAP list

Regards

Andrea

From Lea September [mailtoleailisocom]

Sent Wednesday July 06 2011 859 AM

To Lea Septemberrsquo

Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Dear Stakeholder

The final scoping report for the above-mentioned project (attached) is available for comment

until 27 July 2011

The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic

commentaryrdquo tab

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 09 April 2012 1159 AM

To Lea September

Subject Comments on Galvanising Plant EIR Coega IDZ

Lea

Attached are my comments on the Draft EIR for the Coega IDZ galvanising

plant

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

Email attachment

COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ

Dr Paul Martin PO Box 61029

Bluewater Bay 6212 Tel 041 4665698

Email pmartinaxxesscoza

Compliance with CDC Permits amp Requirements

It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of

o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants

Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC

Air Emissions

Presumably permanent in stack monitoring will be required in terms of AEL permit requirements

Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions

Water

Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)

General

There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)

Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards

Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter

All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 11 April 2012 1245 PM

To Lea September

Subject Fw Comments on Galvanising Plant EIR Coega IDZ

Lea

One other comment on that I have on the Galvanising Plant Draft EIR

Hydrogen chloride is one of the main emissions There are no ambient air

quality guidelines for HCl and the EIR says concentrations will be well

within health parameters

However the main problem with HCl is its corrosive effect - there is

absolutely no mention of this in the draft EIR nor air specialist report

There needs to be some sort of comment assessment as to whether HCl

emissions are likely to impact on for example the adjacent Agni-Steel

Plant wrt corrosion - their factory structure will be made of steel

The EIR specialist rpt suggests monitoring HCl at ground level on the

property boundary and this is supported in case there are complaints from

neighbours

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Paul Martin ltpmartinaxxesscozagt

To Lea September ltleailisocomgt

Sent Monday April 09 2012 1158 AM

Subject Comments on Galvanising Plant EIR Coega IDZ

gt Lea

gt

gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising

gt plant

gt

gt

gt Dr Paul Martin

gt PO Box 61029

gt Bluewater Bay 6212

gt Tel 041 4665698

gt Cell 0732524111

gt email pmartinaxxesscoza

gt

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 12 April 2012 1139 AM

To Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Hi Lea

Hope yoursquore keeping well

I have requested comments from my colleagues and the CDC Casa team on the Draft EIR

Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report

Regards

Andrea

From Graham Taylor

Sent Thursday April 12 2012 838 AM

To Andrea Von Holdt Firhana Sam

Cc Johan Fourie Maria van Zyl Melikhaya Sihawu

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Andrea Firhana

Firhana if you could please ensure that the co-ordinates provided in the EIR correspond

with our records (pages 4-1 amp 4-2)

My comments are as follows

It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work

Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above

Regards

Graham Taylor

Spatial Development Manager - Infrastructure Development

Mobile 0832283055

Office 0414030454

Facsimile 0865185033

Email GrahamTaylorcoegacoza

Website wwwcoegacom

right PLACE | right TIME | right CHOICE

This email and all contents are subject to the following disclaimer

httpwwwcoegacomemaildisclaimerhtml

From Lea September [mailtoleailisocom]

Sent 04 May 2012 0411 PM

To Andrea Von Holdt

Cc Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Dear Andrea

We have taken note of the comments from the GIS Unit These issues have been rectified in

the final version of the EIR

Please can you forward to the relevant persons at the GIS Unit

Thank you

Best regards

Lea September

APPENDIX E

BACKGROUND INFORMATION

DOCUMENT

APPENDIX F

AIR QUALITY IMPACT ASSESSMENT

APPENDIX G

TRAFFIC IMPACT ASSESSMENT

APPENDIX H

WASTE MANAGEMENT AND HAZARDOUS

SUBSTANCES SPECIALIST STUDY

APPENDIX I

WATER QUALITY SPECIALIST STUDY

APPENDIX J

ENVIRONMENTAL MANAGEMENT

PROGRAMME

Page 2: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA

PROPOSED 80 000 TPY GALVANIZING PLANT IN THE

COEGA INDUSTRIAL DEVELOPMENT ZONE (IDZ)

DEDEA Reference ECm1LN2M11-24

Report Title Draft Environmental Impact Assessment Report

Authors Lea September Martin van Veelen Terry Baker

ILISO project reference no 1000196

Status of report Final v10

First issue April 2012

Final issue

Prepared by Submitted to

ILISO Consulting (Pty) Ltd Eastern Cape Department of Economic

P O Box 68735 Development and Environmental Affairs

Highveld Contact Mr Jeff Govender

0169 Private Bag X 5001

Greenacres 6057

Contact Lea September On behalf of

Tel 012 685 0900 Casa Steel Trading (Pty) Ltd

Fax 012 665 1886 Contact Mrs Leoncie Mukundente Director

Cell 082 455 1157 Tel 041 379 4623

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 i

PROPOSED 80 000 TPY GALVANIZING PLANT IN THE

COEGA INDUSTRIAL DEVELOPMENT ZONE

FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT

TABLE OF CONTENTS

ACRONYMS IV

EXECUTIVE SUMMARY V

1 INTRODUCTION 1-1

11 BACKGROUND 1-1

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS 1-1 13 PURPOSE OF THIS REPORT 1-2

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) 1-2

15 PROJECT TEAM 1-3

16 STRUCTURE OF THIS REPORT 1-4

2 DESCRIPTION OF THE PROPOSED PROJECT 2-1

21 TECHNICAL ASPECTS 2-1

211 The galvanizing process 2-1

212 Main inputs and outputs in operational phase 2-3

213 Installations on site 2-3

22 LOCATION OF THE PROPOSED GALVANIZING PLANT 2-4

23 NEED AND DESIRABILITY 2-6

24 ALTERNATIVES IDENTIFIED 2-6

25 CONSTRUCTION ASPECTS 2-6

26 OPERATION ASPECTS 2-7

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT 3-1

31 OBJECTIVES 3-1

32 AUTHORITY CONSULTATION 3-1

33 PUBLIC PARTICIPATION PROCESS CONDUCTED 3-1

34 LEGISLATION AND GUIDELINES CONSIDERED 3-2

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT 4-1

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION 4-1

42 SOCIO-ECONOMIC CHARACTERISTICS 4-3

43 BIOPHYSICAL CHARACTERISTICS 4-3

431 Surface and ground water 4-3

432 Climate and atmospheric conditions 4-3

433 Geology and soils 4-4

434 Terrestrial ecology 4-4

435 Land use and topography 4-7

436 Heritage and archaeological survey 4-7

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED 5-1

51 AIR QUALITY 5-1

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 ii

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS 5-2

53 BIODIVERSITY AND CONSERVATION 5-2

54 WATER QUALITY 5-2 55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES 5-3

56 HEALTH AND SAFETY 5-5

57 TRAFFIC 5-5

58 NOISE 5-9

59 SOCIO-ECONOMIC ASPECTS 5-10

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY 6-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS 7-1

71 IMPACTS DURING CONSTRUCTION 7-1

711 Air quality 7-1

712 Heritage and archaeological resources 7-1

713 Biodiversity and conservation 7-2

714 Water related impacts 7-3

715 Waste management 7-3

716 Health and safety 7-4

717 Traffic 7-4

718 Noise 7-5

719 Socio-economic 7-5

72 IMPACTS DURING OPERATION 7-6

721 Air quality 7-6

722 Water quality 7-7

723 Waste management and hazardous substances 7-8

724 Health and safety 7-9

725 Traffic 7-9

726 Noise 7-10

727 Socio-economic 7-11

73 COMPARATIVE ASSESSMENT OF IMPACTS 7-11

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME 8-1

9 ENVIRONMENTAL IMPACT STATEMENT 9-1

10 CONCLUSION AND RECOMMENDATIONS 10-1

11 REFERENCES 11-1

LIST OF FIGURES

Figure 1 Process flow diagram for proposed galvanizing plant 2-2

Figure 2 Continuous Galvanizing Line 2-3

Figure 3 Location of the proposed galvanizing plant 2-5

Figure 4 Zone layout in the Coega IDZ 4-1

Figure 5 Site location 4-2

Figure 6 Coega IDZ Open Space Management Plan (OSMP) 4-5

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble gravels

exposed by tracks in Zone 6 (Source Binneman 2010) 4-8

Figure 8 Coega IDZ road network layout (Adapted from BKS 2006) 5-6

Figure 9 Coega IDZ road network 5-7

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 iii

Figure 10 Trip distribution for freight and personnel trips 5-8

Figure 11 Morning peak hour Casa Steel development traffic 5-9

Figure 12 Casa Steel organisation chart 5-10

LIST OF TABLES

Table 1 Coordinates of site corners for the proposed galvanizing plant 4-1

Table 2 Hazardous materials to be used on site 5-4

APPENDICES

APPENDIX A List of registered stakeholders

APPENDIX B Notice of AEL application and advertisements

APPENDIX C Notice of comment period for draft scoping report

APPENDIX D Summary of issues raised and responses thereto

APPENDIX E Background Information Document

APPENDIX F Air Quality Impact Assessment

APPENDIX G Traffic Impact Assessment

APPENDIX H Waste Management and Hazardous Substances specialist study

APPENDIX I Water Quality Specialist Study

APPENDIX J Environmental Management Programme (EMP)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 iv

ACRONYMS

AEL Atmospheric Emissions Licence

BID Background Information Document

CCA Custom Controlled Area

CDC Coega Development Corporation

DEA Department of Environmental Affairs

DEDEAT Department of Economic Development Environmental Affairs and Tourism

DWA Department of Water Affairs

EAP Environmental Assessment Practitioner

EIA Environmental Impact Assessment

ELC Environmental Liaison Committee

EMP Environmental Management Programme

GN Government Notice

IampAPs Interested and Affected Parties

IDZ Industrial Development Zone

LNG Liquid natural gas

masl Meters above sea level

MSDS Material Safety Data sheet

NEMA National Environmental Management Act

NEMBA National Environment Management Biodiversity Act (No10 of 2004)

NMBM Nelson Mandela Bay Municipality

OSMP Open Space Management Plan

PoS Plan of Study

SAHRA South African Heritage Resources Agency

TNPA Transnet National Ports Authority

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 v

EXECUTIVE SUMMARY

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone

(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province

Galvanizing consists of coating steel with zinc in order to protect it from corrosion An

Environmental Impact Assessment (EIA) is required as the proposed project involves several

activities listed in terms of Section 24 of the National Environmental Management Act

(NEMA) 107 of 1998 as amended and requires an environmental authorisation The

project also involves activities listed in terms of the National Environmental Management Air

Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008

which respectively require an Atmospheric Emissions Licence and a Waste Management

Licence

The Scoping and Environmental Impact Assessment process underway covers all aspects of

the project and informs all three applications

Scoping was the first phase of investigations and aimed to inter alia identify potential key

environmental issues and impacts to be addressed in the EIA phase

The following environmental issues and potential impacts identified in the Scoping Phase

were investigated in the EIA

Air quality

The galvanizing process generates atmospheric emissions which are regulated in terms

of the National Environmental Management Air Quality Act and appropriate measures

are required in order to adhere to the applicable standards Other sources of impact on

air quality include emissions from the LNG burner emissions and dust from the transport

of steel and other materials in trucks as well as dust and gas emissions related to

construction activities Mitigation measures recommended in the EMP will ensure that air

quality impacts are kept to a minimum and compliance with emissions standards is

maintained

Biodiversity and conservation

Certain types of vegetation in the IDZ are of high conservation importance Protected

species will be rescued as per the CDCrsquos requirements

Water quality

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through spills

or leaks This risk can however be minimized if not avoided altogether through design

choices (bunded areas) and the adherence to best practice guidelines for the handling or

the transport of hazardous substances and waste

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vi

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

Waste management and hazardous substances

The plant will generate a relatively small amount of solid waste which will be re-used

recycled or disposed of in accordance with the EMP recommendations

There will be a wastewater treatment plant on site which will neutralise process water

(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer

Hazardous waste from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site

at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and

removed on a monthly basis is limited to 10 m3

A number of substances classified as hazardous are used in the galvanizing process and

the transport and handling of these is subject to certain rules and guidelines

In addition the permanent storage of a high quantity of liquid petroleum on site (20 000

litres at any one time) is subject to certain specifications and requires approval from the

municipality

Health and safety

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling of the various substances used will be done in

accordance with applicable instructions (cf material safety data sheets)

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as provide

site supervision including executing tests (individual test cold run and hot run) during 3

months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the EMP

Traffic

In the operational phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and from

the Port of Ngqura

The traffic expected to be generated during construction as well as operation is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low and

the total traffic generated by Casa Steel is also relatively low

The impact on port traffic is also negligible and well within the portrsquos capacity

Socio-economic aspects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vii

The proposed galvanizing plant will make a positive contribution by creating jobs during

construction and operation and generating business for the various service providers

Fatal flaws

No fatal flaws have been identified

The significance of these potential key environmental impacts were assessed in the EIA

phase and the findings of this phase of investigations are presented in this report

The main findings of the EIA are as follows

During construction impacts post-mitigation are low with the exception of noise and

biodiversity as the construction of the plant will result in the destruction of habitat

and loss of fauna and flora and noise impacts inherent to construction activities

Mitigation measures have been included in the EMP for these impacts and they have

a medium significance post-mitigation

All impacts were assessed as low during operation after mitigation

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium

to long term similar impacts are likely to occur due to ongoing developments in the

IDZ

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

The CDC has its own requirements regarding the monitoring of certain aspects of the

project such as the quality of the effluent and the noise levels These have been

incorporated into the EMP Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as other

infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified and

assessed No fatal flaws have been identified

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 viii

It is recommended that the project be approved subject to the conditions listed above

and adherence to the EMP recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-1

1 INTRODUCTION

11 BACKGROUND

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)

Nelson Mandela Bay Municipality Eastern Cape Province

The demand for galvanised steel products is high in South Africa and Africa and is

expected to increase in the foreseeable future From an economic point of view the

proposed project has therefore been found to be viable

Casa Steel will source the steel coils from various markets internationally and in

South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is

destined to be exported mainly to African countries

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

An Environmental Impact Assessment (EIA) is required as the proposed project

involves several activities listed in terms of Section 24 of the National Environmental

Management Act (NEMA) No 107 of 1998 as amended and requires an

environmental authorisation

The following listed activities requiring environmental authorisation have been

identified

Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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 metres

Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped

land to industrial use greater than 1 ha but less than 20 ha in size outside an

urban area

Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any

process or activity requiring a license in terms of national or provincial legislation

governing the generation or release of emissions

Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5

hectares or more of vegetation where 75 or more of the vegetative cover

constitutes indigenous vegetation except where such removal of vegetation is

required for

(i) purposes of agriculture or afforestation inside areas identified in

spatial instruments adopted by the competent authority for

agriculture or afforestation purposes

(ii) the undertaking of a process or activity included in the list of waste

management activities published in terms of section 19 of the

National Environmental Management Waste Act 2008 (Act No 59

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-2

of 2008) in which case the activity is regarded to be excluded from

this list

(iii) the undertaking of a linear activity falling below the thresholds in

Notice 544 of 2010

Hot dip galvanizing is a listed activity in terms of section 21 of the National

Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires

an Atmospheric Emissions Licence (AEL)

In addition the treatment of wastewater with an annual throughput capacity of more

than 2000 m3 is a listed activity in terms of the National Environmental Management

Waste Act 59 of 2008 and requires a waste management licence

ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental

Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact

Assessment process in terms of section 24 of NEMA for the construction and

operation of the proposed galvanizing plant The EIA process covers all aspects of

the project and informs all three applications (for environmental authorisation waste

management licence and AEL)

13 PURPOSE OF THIS REPORT

This report builds on the scoping report submitted to the Eastern Cape Department of

Economic Development and Environmental Affairs (DEDEA) and the Nelson

Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It

describes the proposed project and presents the findings of the second phase of

investigations (EIA phase)

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT

PRACTITIONER (EAP)

The EIA was managed by Ms Terry Baker a certified Environmental Assessment

Practitioner with 20 years of working experience She has a MA in Environmental

Management and specialises in Environmental Impact Assessments and Project

Management She has been involved in a variety of different types of EIAs including

for water supply projects dams transmission lines roads and airports in South

Africa Botswana Uganda Lesotho and Mozambique She has been involved in

water resource management and public participation programmes on a number of

projects Terry has also been involved in the use of Geographic Information Systems

environmental status quo reports water quality assessments socio-economic and

institutional development projects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-3

15 PROJECT TEAM

In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen

(water quality specialist) and Lea September (EAP) with specialist input from Renee

von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous

substances) and Seniel Pillay (Traffic Impact Assessor)

The Business Unit Head of the ILISO Environmental Management Discipline Group

Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is

a Fellow of the South African Institution of Civil Engineers a member of the South

African Society of Aquatic Scientists of the Environmental Scientific Association of

the International Water Association of the Water Institute of South Africa and of the

Vaal River Catchment Association He is a certified Environmental Assessment

Practitioner with 30 years experience who specialises in project management

environmental impact assessments and water resource planning He specifically has

extensive experience in water quality especially water quality management water

quality monitoring and water quality assessment Martin has experience in managing

projects that involve multi-disciplinary teams and public consultation and

participation in South Africa and abroad

Lea September is an Environmental Assessment Practitioner with a Masters degree

in Environmental Management She has experience in impact assessment and

environmental management and has been responsible for drafting impact

assessment reports and Environmental Management Programmes and conducting

public participation processes as well as high level environmental screenings for a

variety of projects in the energy water transport and industrial sectors

Renee von Gruenewaldt has nine-years experience in the field of air pollution

impact assessment and air quality management Prior to becoming involved in air

quality consultation she was part of the Highveld Boundary Layer Wind Research

Group based at the University of Pretoria Since joining Environmental Management

Services (the company now Airshed Planning Professionals) she has undertaken

numerous air pollution impact studies and has provided extensive guidance to both

industry and government on air quality management practices

Pieter Smuts graduated as a Civil Engineer and became involved in the field of

municipal engineering and infrastructure construction He has specialized during the

last twelve years in solid waste management He has completed waste management

plans feasibility studies and final designs of waste management facilities in South

Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and

the review of the Mavoco hazardous waste landfill design in Maputo Mozambique

and completed a study on hazardous waste (textile factory sludge) management in

Maseru Lesotho

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-4

Seniel Pillay is a transportation engineer with over 16 years experience in

transportation planning and traffic engineering He has been involved in a wide

range of projects ranging from developing the Transport Operations Plan for the

FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System

for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller

traffic impact assessments for inter alia road improvement schemes Of particular

relevance to this project his experience includes Heavy Goods Vehicle Study for

eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact

Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash

Preliminary Transportation Assessment

16 STRUCTURE OF THIS REPORT

The proposed project and the alternatives considered are described in Chapter 2

Chapter 3 details the approach adopted for the EIA phase

The biophysical and socio-economic environment affected by the activity is described

in Chapter 4

The environmental impacts identified are discussed in Chapter 5

The EIA methodology is described in Chapter 6 and Chapter 7 presents the results

of the impact assessment

The environmental impact statement is presented in Chapter 8

Finally Chapter 9 spell out the conclusions and recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-1

2 DESCRIPTION OF THE PROPOSED PROJECT

21 TECHNICAL ASPECTS

211 The galvanizing process

Galvanizing consists of coating steel with zinc in order to protect it from corrosion

Before steel strips can be galvanized they undergo a pre-treatment in order to

ensure that the steel sheets are free from any surface oxides as they enter the

molten zinc coating Bath This is done by removing the oil from the steel sheets (in

the degreasing unit) and then removing the rust from the surface of the sheet (in the

pickling unit)

The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The

melting zinc on the strip surface will be cooled and solidified through air cooling in the

cooling tower

Finally the galvanised steel sheets are dipped into a water quenching tank in order to

further cool the sheets from about 150degC to 40degC

It is possible to make galvanised steel more durable by chromating it Approximately

50 of the galvanised steel production output will receive chromate passivation

treatment after quenching the galvanised steel sheets will be sprayed with a chrome

solution (3 kgcm2)

After galvanizing and chromating the steel sheets are cut to achieve the desired coil

size and weight and transported to the storage yard

The process flow diagram below (Figure 1) illustrates the main stages of the

galvanizing process and indicates the major inputs and outputs as well as the

resulting effluent and atmospheric emissions

Draft Environmenal Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-2

Figure 1 Process flow diagram for proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-3

212 Main inputs and outputs in operational phase

In view of the above the main inputs will be as follows

Steel coils 85 000 tonsyear

Zinc 870 tonsyear

Electricity 2500 kVA

Water 2000 m3month (of which 400 m3 will be potable water)

Liquid Natural Gas (LNG) 270 NM3hour

Sodium hydroxide (NaOH) 1000 m3year

Hydrochloric acid (HCl) 800 m3year

Chrome (Cr+3) 10 m3year

The main outputs will be

Galvanized steel 80 000 tonsyear

Scrap metal 20 tonsyear

General waste 65 tonsyear

Hazardous waste 2 m3month

Wastewater 012 Mlweek

Atmospheric emissions lt 5 ppm

213 Installations on site

The bulk of the operations involved in the galvanizing process occur along a

continuous galvanizing line (See Figure 2 below) which is the main piece of

machinery required for the proposed galvanising plant

Figure 2 Continuous Galvanizing Line

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-4

Water is one of the major inputs and is used throughout the galvanizing process notably

for rinsing and cooling purposes and as a mixing agent for the various chemical

solutions The plant will have a water treatment plant on site to treat the water used in

the various processes (approx 250 m3

of wastewater per week) The wastewater

treatment facility will be operated by a professional water treatment company as Casa

Steel does not have the required expertise in house to treat its process water Sulphuric

acid (H2SO4) is used as part of the treatment process to reduce caustic soda The

neutralised water is discharged to the sewer while any sludge is disposed of as

hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)

will be disposed of

Some critical areas of the galvanizing process such as the zinc pot require uninterrupted

power It is therefore proposed to install an LNG burner to maintain the zinc bath at a

temperature of between 450 and 460degC

22 LOCATION OF THE PROPOSED GALVANIZING PLANT

The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast

of Port Elizabeth in the Eastern Cape (Figure 3)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-5

Figure 3 Location of the proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-6

23 NEED AND DESIRABILITY

The profitability of the proposed project has been established by Casa Steel and a

pre-feasibility study has confirmed that the proposed project was feasible from a

technical and financial point of view The Coega IDZ is specifically designed to host

facilities such as a galvanizing plant and can provide the necessary infrastructure

and services to its investors It therefore constitutes a very suitable location for the

project

24 ALTERNATIVES IDENTIFIED

Zone 6 has been specifically earmarked for heavy ferrous metal industries and is

therefore a suitable location for the proposed galvanizing plant as such no site

alternatives have been provided for and assessed in this EIA However prior to the

commencement of the EIA process Casa Steel was presented with a number of

different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the

selection of the site were

(a) The dimensions of the land the site should be at least 200 m long and

50 m wide in order to accommodate the galvanizing line and adjacent lay

down area and additional land should be available next to the site for future

expansion

(b) The fiscal arrangements applying to the site the site should be located

within the future Custom Controlled Area (CCA) as the bulk of the

production output of the plant will be exported

The no-go alternative is assessed in this report

25 CONSTRUCTION ASPECTS

The construction phase of the project will take about 12 months and will essentially

consist of erecting a building to house the galvanizing line and other equipment and

preparing a concrete laydown area adjacent to the building

The CDC will provide an access point from the existing tarred road that will lead to

the site

Approximately 100 workers from the surrounding areas will be contracted for the

construction work

The requirements in terms of services during construction are listed below

Water 1000 m3month

Electricity 2500 kVA

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-7

The CDC will provide temporary services for the construction phase including a

conservancy tank for flush toilets Sewage infrastructure will only be provided for the

operational phase

26 OPERATION ASPECTS

Before the plant can become fully operational the equipment and machinery will be

tested for approximately 3 months The supplier will supervise these tests as part of

the transfer of know-how and training of staff on the plant

Casa Steel will start operating the plant at a reduced capacity (about 50 000

tonsyear) for a period of time (mostly determined by market aspects) before bringing

production to full capacity (80 000 tonsyear) This is done by operating the line for

longer hours

Approximately 50 to 60 people will be working on the plant Approximately 6-10 of

these will be unskilled 40-45 skilled and about 5 people in managerial positions

The requirements in terms of services during operation are as follows

Water 2000 m3month

Electricity 2500 kVA

Effluent discharge 24 m3day

The CDC has entered into agreements with the municipality to secure the provision

of services such as water and electricity to its tenants Tenants in the IDZ have their

own agreements with the NMBM for electricity while the agreements for water and

sewage are with the Facilities Unit of the CDC

Regarding discharge of wastewater to the sewer the municipality indicated that the

only requirement is that the water discharged complies with applicable municipal

discharge standards

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 3-1

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT

31 OBJECTIVES

The main objectives of the EIA phase are to

Assess the significance of the environmental issues and impacts identified in the

scoping phase focusing on key impacts

Recommend appropriate measures to mitigate negative impacts and enhance the

benefits and include them in the draft EMP

Undertake a public participation process that provides opportunities for all

interested and affected parties (IampAPs) to be involved

32 AUTHORITY CONSULTATION

The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental

Liaison Committeersquo (ELC) which comprises representatives of various authorities

including DEDEAT the Department of Environmental Affairs (DEA) and Department

of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the

Coega Development Corporation (CDC) and Transnet National Ports Authority

(TNPA) The ELC has been specifically formed to facilitate EIA applications in the

IDZ

Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to

the clearance of vegetation should be included in the application A formal request

was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the

application and all registered stakeholders were informed of the request in writing on

19 October 2011

33 PUBLIC PARTICIPATION PROCESS CONDUCTED

On-site notices were replaced by a notification displayed on the CDCrsquos digital notice

board at the business centre in Zone 1 of the IDZ The eNotice was placed on

13 April 2011 and will remain for the full duration of the EIA process

Registered stakeholders will be notified in writing of the availability of the draft EIA

report and EMP which will also be advertised in a local newspaper Stakeholders

including state departments and the public will have forty (40) days to comment on

the draft EIA report and EMP The draft EIA report and EMP will be sent by email

where possible and made available for download on the ILISO website

(wwwilisocom)

A summary of all issues and comments received during the stakeholder consultation

process as well as of correspondence in that regard will be captured in an Issues

and Responses Report that will form an Appendix to the EIA Report

The list of registered IampAPs is included in Appendix A

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 3-2

34 LEGISLATION AND GUIDELINES CONSIDERED

The following legislation and guidelines were considered in the preparation of this

report

National Environmental Management Act Act No 107 of 1998

NEMA EIA Regulations 2010

National Environmental Management Air Quality Act Act No 39 of 2004

National Environmental Management Waste Act Act No 59 of 2008

Hazardous Substances Act Act 15 of 1993

Occupational Health and Safety Act Act 85 of 1993

Hazardous Chemical Substances Regulations 1995 (GNR 1179)

Major Hazard Installation Regulations 2001 (GNR 692)

National Water Act Act 36 of 1998

National Heritage Resources Act Act 25 of 1999

DEAT Integrated Environmental Management Information Series 1-5 and 12-15

NEMA draft Implementation Guideline

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Public Participation (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Alternatives (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Draft Guideline for Determining the Scope of Specialist

Involvement in EIA Processes (2005)

IAIA guidelines

National air quality standard for thoracic particulates Government Gazette

No 32816

Listed activities and associated minimum standards identified in terms of section

21 of the National Environmental Management Air Quality Act Act No 39 of

2004 Government Notice 248 of 2009

Minimum Requirements for the Handling Classification and Disposal of

Hazardous Waste DWAF Waste Management Series (1998)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-1

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION

The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega

IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay

to the north of the N2 highway between Port Elizabeth and Grahamstown east of the

Coega River

The co-ordinates of the corners of the site are shown in Table 1

Table 1 Coordinates of site corners for the proposed galvanizing plant

Point Longitude Latitude

A 25deg411126E 33deg45587S

B 25deg411156E 33deg45499S

C 25deg411938E 33deg45131S

D 25deg412174E 33deg45481S

E 25deg412508E 33deg45979S

F 25deg412634E 33deg451160S

G 25deg411782E 33deg451560S

H 25deg411692E 33deg451428S

J 25deg411314E 33deg45868S

Figure 4 Zone layout in the Coega IDZ

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-2

Figure 5 Site location

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-3

42 SOCIO-ECONOMIC CHARACTERISTICS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the

NMBM There are no residents within the IDZ

As far as the broader NMBM and Eastern Cape Province are concerned the

following can be noted The NMBM is located within the Eastern Cape Province the

2nd largest Province in South Africa (3rd in terms of population) characterised by a

predominantly black population with low incomes and high levels of unemployment

(CES 2010)

The NMBM has a population of just above 11 million and covers an area of

1 950 km2 It is the main urban and industrial centre of the province and Port

Elizabeth in particular which forms part of the NMBM is the commercial capital of

the Eastern Cape 52 of the NMBM population is female and 37 is below the

age of 20 these two groups are particularly affected by unemployment

43 BIOPHYSICAL CHARACTERISTICS

431 Surface and ground water

No rivers occur in Zone 6 There is however a natural attenuation pond on the

southern most part of the site which will have to be avoided

The IDZ is underlain by calcrete sand and gravel deposits that overlie low

permeability clays These clays limit the vertical infiltration of rainwater and induce a

horizontal groundwater flow towards the Coega River channel which is the most

significant surface water feature in the Coega IDZ Consequently rapid run-off takes

place following precipitation (Jacobs 2008)

Groundwater levels at Coega are generally about 3 to 5 m below surface ie just

above the contact between the permeable sands and the underlying impermeable

clays The groundwater flow direction is to the southeast following the surface water

drainage direction (Jacobs 2008)

432 Climate and atmospheric conditions

Port Elizabeth has a warm temperate climate and the temperature ranges are not

extreme Exceptionally high temperatures may be experienced during berg wind

conditions which occur frequently during autumn and winter Extreme temperatures

also occur during summer with little accompanying wind

The wind regime for the area largely reflects the synoptic scale circulation with

dominant westerly and northwesterly flow fields representing the pre-frontal

conditions and south-westerly flow fields representing the frontal conditions The

south-easterly and south-westerly wind flow (land breeze) increases during daytime

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-4

conditions with westerly and north-westerly wind flow increasing during the night (sea

breeze)

The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of

Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15

km southwest) and Port Elizabeth (~23 km southwest)

An ambient air monitoring network has been established in the Coega IDZ which

consists of three monitors Saltworks Motherwell and Amsterdamplein Although

NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative

impacts due to the proposed Galvanising Plant is PM10 A maximum daily average

PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed

SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3

was exceeded on 17 days in 2007 and 26 days in 2008

Existing sources of emissions in the vicinity of the proposed galvanizing plant include

industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other

fugitive dust sources (von Gruenewaldt 2011b)

433 Geology and soils

Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel

and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly

limestone and conglomerate

434 Terrestrial ecology

This section draws from the EIA report compiled for the Agni Steel (formerly Afro-

Asia) steel processing facility which is adjacent to the proposed site for the

galvanizing plant (Jacobs 2008)

The area consists largely of grasses succulents and scrubby bush with alien

species making up the greater part of the more dense vegetation

Zone 6 falls within the inland vegetation and is characterised by a vegetation type

referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the

Coega IDZ and has been found to have three times the level of endemism of other

vegetation communities in the Coega IDZ Bontveld therefore has a high

conservation status Two Bontveld conservation areas have been identified within the

IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)

Bontveld that will be destroyed as a result of development in the IDZ will be given

conservation status in these two areas

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-5

Figure 6 Coega IDZ Open Space Management Plan (OSMP)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-6

Certain areas in the IDZ are invaded by alien plant species The most common

invader species is rooikrans (Acacia cyclops) which presently forms large

monospecific stands in areas throughout the Coega IDZ There are several other

aliens present that pose a threat to the flora of this area including the prickly pear

(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)

Loss of vegetation and alien plant invasion due to human activity has resulted in a

reduction in the diversity of terrestrial fauna

The majority of mammals present in the Coega IDZ are small or medium-sized Of

the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed

gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of

Algoa Bay however it is not considered threatened The gerbil is common in

foredune and dune thicket habitat in the Coega region and is therefore unlikely to

occur on the proposed site

A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird

species are resident or common to the area Most diversity occurs in the thicket

although the coastal area also supports specialised avifauna Two species of tern

the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well

as the Cape gannet (Morus capensis) and the African penguin (Spheniscus

demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne

caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant

(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser

flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns

are two of the most endangered coastal species in South Africa Other bird species

of conservation concern include the Whitefronted plover (Charadrius marginatus)

African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus

bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus

ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides

paradisea) Breeding pairs of Damara terns and African black oyster catchers have

been observed in the coastal dunes of the IDZ but should not be affected by

developments that fall outside the dune areas

The Eastern Cape supports nearly a third (approximately 133 species) of the reptile

species recorded in South Africa More than half of the Eastern Capersquos endemic

reptile species occur in the Algoa Bay area giving the region a high conservation

value A total of 63 reptile species are believed to occur within the Coega IDZ The

majority of these are found in Succulent Thicket and riverine habitats Only a few

reptile species occur in the coastal dunes and estuarine habitats More than a third of

the species are described as relatively tolerant of disturbed environments provided

that migration corridors of suitable habitat are maintained to link pristine habitats

Twenty two reptiles are of special concern including five endemic species (two of

which may also be endangered) four endangered sea turtles eight species listed

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-7

with CITES one rare species and four species at the periphery of their range

Fourteen of these species of special concern are confirmed as occurring on or within

2 km of the Coega IDZ

A total of 32 amphibian species and sub-species occur in the Eastern Cape

representing almost a third of the species recorded in South Africa However none of

the species are endemic or Red Data Book species Based on previous studies in the

area it is estimated that approximately 17 amphibian species occur within the Coega

IDZ Four species are listed as peripheral but none are threatened internationally

These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog

(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and

the bubbling kassina (Kassina senegalensis)

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated

vegetation has not been extensively studied One grasshopper species Acrotylos

hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue

(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis

pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in

four localities in the Eastern Cape one of which is within the Coega IDZ The Coega

copper Aloeides clarki is endemic to this particular region of the Eastern Cape and

is currently known to occur in three localities two of which are in the Coega IDZ The

localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the

Coega IDZ and their distributions were taken into account when defining Coegarsquos

open space system and Development Framework Plan

435 Land use and topography

The land is currently undeveloped and earmarked for industrial development The

site is relatively flat ranging from an elevation of 66 masl on the northern-most

corner to 59 masl at the southern-most corner

436 Heritage and archaeological survey

Extensive studies have been undertaken in Zone 6 with respect to heritage aspects

Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a

2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond

2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is

currently being finalised

Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing

Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha

in extent and was located next to the R102 road to Motherwell Kaplan conducted

HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi

Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will

now be located in Zone 5)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-8

The various archaeological investigations reached similar observations and

conclusions Stone tools of various densities and types were found throughout the

zone The majority of the stone tools were mainly of Earlier and Middle Stone Age

and occasional Later Stone Age origins (Figure 4)

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble

gravels exposed by tracks in Zone 6 (Source Binneman 2010)

The stone tools which comprised of quartzite flakes chunks flaked pebblecobble

and cores were randomly distributed across the landscape and are in secondary

context There were no lsquoconcentrationsrsquo of tools observed which suggested any

spatial patterning or activity areas although these may be present or covered by soil

and vegetation

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 5-1

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED

The following environmental issues and potential impacts were identified in the

Scoping phase

51 AIR QUALITY

The galvanizing process generates atmospheric emissions with particulates and

hydrogen chloride representing the main pollutants of concern The plant is fitted with

air extraction as well as scrubber systems which are designed to retain the bulk of

pollutants and particles for each of the processes in such a way that less than 5 ppm

of gases and particles will be released into the atmosphere after the fume scrubber

Other sources of impact on air quality include emissions from the LNG burner as well

as emissions and dust from the transport of steel and other materials in trucks

Construction activities will also create dust and gas emissions due to the clearing of

groundcover tipping of material to storage pile levelling of area wind erosion from

storage piles vehicle and construction equipment activity and tailpipe emissions

from vehicles and construction equipment such as graders scrapers and dozers

Overall the air quality impact assessment (Gruenewaldt 2011b) found that

The predicted particulate oxides of nitrogen carbon monoxide and sulphur

dioxide concentrations are all below the National Ambient Air Quality Standards

for all averaging periods

The predicted off-site concentrations of hydrogen chloride are well below the

most stringent effect screening levels

No odour threshold exceedances for hydrogen chloride were predicted to occur

due to routine operations at the Steel Galvanising Plant The South Wales

Environmental Protection Authority stipulates that an odour unit of 20 is

acceptable for urban areas The odour unit would be lt10 directly off-site for

hydrogen chloride

Abnormal emissions can occur in exceptional circumstances Start-up will not

cause abnormal emissions as the scrubbers will be commissioned first and will be

functioning once the plant starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions would be emitted as a

building fugitive

The hourly hydrogen chloride ground level concentrations (directly offsite) were

predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based

on the emission limits as stipulated for listed activities for galvanising processes)

using a screen model which assumes worst case meteorological conditions The

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-2

health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming

abnormal emissions emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset conditions will still

be well within the health effect screening levels

Similarly the hourly particulate emissions from the building fugitives during upset

conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for

listed activities for galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly

off-site

Therefore if emissions are 5 times higher normal they will still be within health effect

screening levels and the daily PM10 NAAQS levels

In the case of a fire a cocktail of gases and particulates could be emitted and could

be over the recommended levels This situation will however be dealt with as an

emergency and normalised as quickly as is possible

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS

The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of

its heritage potential and there are no proposed protected geosites in Zone 6

Should any artefacts be discovered during construction procedures stipulated in the

draft EMP will apply

53 BIODIVERSITY AND CONSERVATION

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

In terms of terrestrial fauna the CDCrsquos open space management plan provides for

the preservation of certain corridors The destruction of certain habitats as a result of

the development will therefore not automatically result in the loss of certain species

54 WATER QUALITY

There is a natural attenuation pond on the southern most part of the site which will be

avoided

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through

spills or leaks

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-3

This risk can however be minimized if not avoided altogether The floor of the factory

will be designed as a bunded area to contain any spills and the entire process will be

contained Potential spills or leaks will therefore be contained and will not impact on

water resources Storm water is therefore considered clean water under normal

operational conditions An oil trap will be placed at the exit of the site to ensure that

no grease from the laydown area enters the stormwater system

Spills and leaks can occur during the handling or the transport of hazardous

substances Best practice guidelines will be followed to ensure that this risk is

adequately managed

Wastewater discharged to sewer will be treated to comply with municipal discharge

standards and is not expected to have an impact on the chemical characteristics of

the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be

discharged from the plant is small in relation to the total volume received at the

Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works

(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently

operated at 61 of its capacity which is approximately 80 Mℓday Thus the

0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore

not have any significant impact on the WWTW

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES

The plant will generate a relatively small amount of solid waste in the form of scrap

metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)

The scrap metal may be sold to other steel processing facilities such as Agni Steel

which will be located next to the plant or collected and disposed of with the rest of

the solid waste by a licensed service provider

As mentioned previously there will be a wastewater treatment plant on site which will

neutralise process water (012 Mlweek) in order to ensure it is of a standard

acceptable for discharge to sewer Waste in the form of sludge from the

neutralization or spent acid must be disposed of as a hazardous waste Solid waste

from the filters used for air quality control is also in this category These wastes can

usually be tested and then delisted which means that it can be placed in a general

purpose landfill

Hazardous effluent from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-

site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored

and removed on a monthly basis is limited to 10 m3

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-4

A number of substances classified as hazardous are used in the galvanizing process

(Table 2) and the transport and handling of these is subject to certain rules and

guidelines In particular the material safety data sheets (cf Appendix H) should be

referred to for inter alia hazards identification accidental release measures

handling and storage precautions exposure controlpersonal protection ecological

information and transport information The Hazardous Chemical Substances

Regulations 1995 should also be adhered to in respect of the transport and storage

of hazardous chemical substances

Table 2 Hazardous materials to be used on site

Major Input Materials

Substance

listed in the

SABS 0228

Group II

hazardous

substances

Volumes to be

stored on site at

any one time

Diesel radic 2000 litres

Liquid petroleum radic 20 000 liters

Sodium hydroxide (NaOH)

(used for degreasing) 8 radic 1000m

3

Hydrochloric acid (HCI)

(used for pickling) 8 radic 800m

3

Zinc (used for galvanising) - TBD

Trivalent chromium (CR+3

)

(used for chromating) 8 radic 10m

3

Sulphuric acid (H2SO4) (used for

treatment of waste water on site) 8 radic TBD

Ammonium Hydroxide (NH4OH) 8 radic TBD

TBD ndash To be determined

Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one

time) and is classified as a flammable substance Specification for flammable storage

facilities in accordance with the requirements of the Nelson Mandela Bay

Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for

quantities between 5000 and 20 000 liters the substance must be kept in a

flammable liquid store which complies with the requirements of a specification

obtainable from the Department Some of the requirements are

Flammable liquid and solid storage facilities are only permitted on the ground

floor

Decanting of flammable liquids and solids are not permitted within any building

Due to the fact that there are flammable materials on site a certificate may be

required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and

Emergency Services Department to confirm that facilities for flammable storage

are in accordance with their requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-5

Because of the permanent installation and high quantity of liquid petroleum on site

the Major Hazard Installation Regulations 2001 promulgated under the Occupational

Health and Safety Act No 85 of 1993 applies A written application for approval of

the installation is required to be submitted to the chief inspector Department of

Labour provincial director Department of Labour and NMBM prior to construction

In addition a risk assessment should be formulated covering all hazardous materials

together with an emergency preparedness and response plan

56 HEALTH AND SAFETY

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling instructions as well as occupational exposure limits

are indicated in the material safety data sheets of the various substances used

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as

provide site supervision including executing tests (individual test cold run and hot

run) during 3 months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the

EMP

In addition the emergency preparedness and response plan will cover the health and

safety aspects related to emergency situations

57 TRAFFIC

The volumes of traffic at the IDZ are currently relatively low and variable depending

on the different zones in the IDZ however these volumes will increase as more

developments are implemented

The construction phase of the Casa Steel development will take about 12 months

and will essentially consist of erecting a building to house the galvanizing line and

other equipment and preparing a concrete laydown area adjacent to the building

The traffic that would be generated during the construction phase can be expected to

be less than the traffic that would be generated by the Casa Steel development when

it is fully operational

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-6

In the operation phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and

from the Port of Ngqura

The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the

Casa Steel development would be off Ring Road 1 The other roads of significance

for the Casa Steel development are the N2 Neptune Road MR435 and MR450

Access to the port is given by Neptune Road Road Link NEP-03 has not yet been

built

Figure 8 Coega IDZ road network identification

(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-7

Figure 9 Coega IDZ road network

Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No

01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-8

The distribution of freight trips is fixed as the majority of trips will be made between

the Port of Ngqura and the Casa Steel site With regard to personnel trips there are

various points of origins (the surrounding residential areas) that could be used by

staff going to the Casa Steel site The distribution of personnel trips is based on

existing traffic count information and is shown in Figure 10

Figure 10 Trip distribution for freight and personnel trips

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The resultant expected Casa Steel traffic assignment is shown in Figure 11

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-9

Figure 11 Morning peak hour Casa Steel development traffic

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The traffic that is expected to be generated by the Casa Steel development is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low

and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)

Consultation has taken place with Transnet Port Authority (TPA) to establish the

impact of the galvanizing plant operations on traffic inside the port The additional

ships entering and exiting the port of Ngqura as a result of the proposed development

will have a negligible impact on port traffic and TPA indicated that it would be well

within the portrsquos capacity

58 NOISE

Noise is not foreseen to be a significant issue insofar as the noise levels inside the

plant and at the boundary of the site will not exceed the limits prescribed by the CDC

Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels

during the day and 60 decibels at night

Mitigation of noise impacts will be addressed in the design of the noise-emitting

components of the plant and their enclosures

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-10

59 SOCIO-ECONOMIC ASPECTS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of

NMBM There are no residents within the IDZ

The direct socio-economic impacts of the proposed project are thus limited to the

employment generated by the project during construction and operation Job creation

remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)

and the IDZ and Port of Ngqura are expected to become a significant catalyst to the

economic growth of the Municipality and the region with current investments at

Coega creating more jobs and stimulating the economy

In this context the proposed galvanizing plant will make a positive contribution

towards the achievement of these goals

There will be 50 to 60 employees during operation phase distributed as follows

Figure 12 Casa Steel organisation chart

Even though a large part of the inputs will be imported and the bulk of the production

output will be exported there will be some positive impacts for the economy of the

region and of South Africa in general Notably the requirements of the plant for

water electricity waste collection and disposal waste water treatment and transport

for example will create business for the various service providers and have an

indirect impact on employment and fiscal revenues as a result

From a visual impact point of view it can be anticipated that the landscape in the IDZ

will be significantly affected over time by developments related to the establishment

of the port and various industries

HEAD ( WORKS )

MGR ( COMM) MGR ( ADMNHR ) Manager marketing

MANAGER OPERATION MANAGER MANAGER MANAGER Q C

AC FIN PUR ampSTORE

PPC SH-GALV SH-tech

SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF

1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO

JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF

2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO

WORKERS WORKERS 7NOS

15 7

RAW MAT amp

DESP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 6-1

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY

A description of the nature of the impact any specific legal requirements and the

stage (constructiondecommissioning or operation) will be given Impacts are

considered to be the same during construction and decommissioning The

significance of the potential impacts will be considered before and after identified

mitigation is implemented

The following criteria will be used to evaluate significance

Nature The nature of the impact will be classified as positive or negative and

direct or indirect

Extent and location Magnitude of the impact and is classified as

Local the impacted area is only at the site ndash the actual extent of the activity

Regional the impacted area extends to the surrounding immediate and

neighbouring properties

National the impact can be considered to be of national importance

Duration This measures the lifetime of the impact and is classified as

o Short term the impact will be for 0 ndash 3 years or only last for the period of

construction

o Medium term three to ten years

o Long term longer than 10 years or the impact will continue for the entire

operational lifetime of the project

o Permanent this applies to the impact that will remain after the operational

lifetime of the project

Intensity This is the degree to which the project affects or changes the

environment and is classified as

o Low the change is slight and often not noticeable and the natural functioning

of the environment is not affected

o Medium The environment is remarkably altered but still functions in a

modified way

o High Functioning of the affected environment is disturbed and can cease

Probability This is the likelihood or the chances that the impact will occur and

is classified as

o Low during the normal operation of the project no impacts are expected

o Medium the impact is likely to occur if extra care is not taken to mitigate

them

o High the environment will be affected irrespectively in some cases such

impact can be reduced

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 6-2

Confidence This is the level knowledgeinformation the environmental impact

practitioner or a specialist had in hisher judgement and is rated as

o Low the judgement is based on intuition and not on knowledge or

information

o Medium common sense and general knowledge informs the decision

o High Scientific and or proven information has been used to give such a

judgment

Significance Based on the above criteria the significance of issues will be

determined This is the importance of the impact in terms of physical extent and

time scale and is rated as

o Low the impacts are less important

o Medium the impacts are important and require attention mitigation is

required to reduce the negative impacts

o High the impacts are of great importance Mitigation is therefore crucial

Cumulative Impacts The possible cumulative impacts will also be considered

Mitigation Mitigation for significant issues is incorporated into the EMP for

construction

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 7-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS

71 IMPACTS DURING CONSTRUCTION

711 Air quality

Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris

handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine

particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural

operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks

and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)

Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Fugitive particulate emissions (dust)

related to construction activities Regional

Short

term Medium High High Medium Regional

Short

term Low High High Low

Construction vehicle gas emissions Regional Short

term Medium High High Medium Regional

Short

term Low High High Low

712 Heritage and archaeological resources

Naturedescription of impact excavation activities may impact on unidentified heritage resources

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-2

Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based

on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments

Heritage and archaeological

resources Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on unidentified heritage

resources Local

Short

term

Medium -

high Low High Low

713 Biodiversity and conservation

Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation

importance and cause soil contamination

Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species

Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan

and has compiled a list of protected species to be rescued (see draft EMP)

Biodiversity and conservation Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Loss of fauna and flora Local Perma

nent

Medium -

high High High High Local

Permanen

t Medium High High Medium

Soil contamination Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-3

714 Water related impacts

Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater

runoff spills and leaks Soil erosion

Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of

spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste

disposal Stormwater quality monitoring (see draft EMP)

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Soil erosion Local Short

term Medium Medium High Medium Local

Short

term Medium Low High Low

715 Waste management

Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed

Commentmitigation see draft EMP and waste management plan

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-4

Waste management Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Local

Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

716 Health and safety

Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Short

term

Medium -

high

Medium -

high High High Local

Short

term

Medium -

high Low High Low

717 Traffic

Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and

construction workers from surrounding areas and transport of equipment from the port

Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low

Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and

accurate estimates of quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-5

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Increased traffic on N2 and within the

IDZ Regional

Short

term Low High High Low

718 Noise

Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Short

term

Medium-

high High High Medium Local

Short

term Medium High High Medium

719 Socio-economic

Naturedescription of impact temporary employment will be created during the construction phase

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-6

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Temporary employment Regional Short

term Medium High High Medium

72 IMPACTS DURING OPERATION

721 Air quality

NatureDescription of impact gas and particulate emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning

Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local

sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and

veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute

to background fine particulate concentrations (von Gruenewaldt 2011b)

Assumptions and limitations Potential release of CR6+

As no emission factors are available for trivalent chromium processing the

potential impacts due to these activities could not be quantified

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Dust emitted from traffic on paved roads Regional Long Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-7

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

term

Hydrogen chloride emissions from

pickling process Local

Long

term Low High High Low

Particulate emissions (smoke) from

galvanizing process (due to the

volatilization of flux)

Local Long

term Low High High Low

Particulate oxides of nitrogen carbon

monoxide and sulphur dioxide emissions

from LNG burner

Local Long

term Low High High Low

Nuisance related to odour Local Long

term Low Low High Low

Abnormally high hydrogen chloride and

particulate emissions due to scrubber

malfunction

Local Short

term Medium Low High Medium

Gases (eg SOx NOx CO etc) and

smoke emitted in case of a fire Local

Short

term High Low High Medium

722 Water quality

NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks

Commentmitigation see draft EMP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-8

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Stormwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

723 Waste management and hazardous substances

NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous

waste both can affect environmental quality and human health

Commentmitigation see draft EMP and waste management plan

Waste management and hazardous

substances Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Regional

Long

term High

Medium -

high High High Regional Long term High Low High Low

Soilwaterair pollution due to improper

transport storage and handling of

hazardous substances

Regional Long

term High

Medium -

high High High Regional Long term High Low High Low

Health hazard Local Long

term High

Medium -

high High High Local Long term High Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-9

724 Health and safety

Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Long

term

Medium-

high

Medium-

high High High Local Long term

Medium-

high Low High Low

725 Traffic

Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on

the road network

Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak

hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road

network within Zone 6 of the IDZ (Iliso 2011)

Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)

Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of

quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-10

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on traffic and capacity of the N2 Regional Long

term Low High High Low

Impact on traffic and capacity of ring

road 1 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR435 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR450 Local

Long

term Low High High Low

Impact on traffic and capacity of

Neptune road Local

Long

term Low High High Low

726 Noise

Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Long

term Medium High High Medium Local Long term Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-11

727 Socio-economic

Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate

revenue for the municipality and the region as a whole

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Employment and economic growth Regional Short

term Medium High High Medium

73 COMPARATIVE ASSESSMENT OF IMPACTS

During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as

low during operation after mitigation

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 8-1

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

As a tenant operating in the IDZ Casa Steel will be required to comply with all

current and future CDC requirements as well as with the relevant conditions of

permits licences issued to CDC (eg Integrated Stormwater Masterplan for the

eastern side of the Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)

In particular the CDC has its own requirements regarding the monitoring of certain

aspects of the project such as the quality of the effluent and the noise levels These

have been incorporated into the EMP

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 9-1

9 ENVIRONMENTAL IMPACT STATEMENT

All predicted negative impacts can be mitigated to a low significance The only

exceptions are biodiversity as the construction of the plant will result in the

destruction of habitat and loss of fauna and flora and noise impacts inherent to

construction activities Mitigation measures have been included in the EMP for these

impacts and they have a medium significance post-mitigation

Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium to

long term similar impacts are likely to occur due to ongoing developments in the IDZ

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 10-1

10 CONCLUSION AND RECOMMENDATIONS

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as

other infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified

and assessed No fatal flaws have been identified

It is recommended that the project be approved subject to the conditions listed in

chapter 9 and adherence to the EMP requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 11-1

11 REFERENCES

Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ

Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants

Bennie JS (2010) The historical component (built environment) of the Heritage

Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port

Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report

compiled for Eastern Cape Heritage Consultants

Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater

Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay

Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage

Consultants

BKS (2006) Coega Industrial Development Zone Transport Study Volume 3

Demand Modelling Report Final Draft

Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I

Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6

Report compiled for SRK Consulting

Coastal amp Environmental Services (2010) Environmental Impact Assessment for the

Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone

Volume 3 Environmental Impact Assessment Report CES Grahamstown

Coega Development Corporation (2008) Industry Waste Management Plan -

Strategic Master Plan Report

Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants

Report No CDCSHE 03 8122

Department of Water Affairs and Forestry (1998) Waste Management Series

ldquoMinimum Requirements For The Handling Classification And Disposal Of

Hazardous Wasterdquo Second Edition

Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising

Plant in the Coega Industrial Development Zone

Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the

Coega Industrial Development Zone (IDZ) Specialist Water Study

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 11-2

Jacobs E (2008) Final Environmental Impact Report and Draft Environmental

Management Plan Proposed Steel Recycling and Processing Facility within the

Coega IDZ Report compiled for SRK Consulting

Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY

Galvanising Plant in the Coega Industrial Development Zone Waste Management

and Hazardous Substances Report compiled for ILISO Consulting

RSA National air quality standard for thoracic particulates (PM10) SA standards

(Government Gazette No 32816)

von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed

Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape

Report compiled for ILISO Consulting

von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel

Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report

compiled for ILISO Consulting

Additional sources

Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed

Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared

for Coastal Environmental Services

Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed

Kalagadi Manganese smelter in the Coega Industrial Development Zone Port

Elizabeth Eastern Cape Province Report prepared for Coastal Environmental

Services

Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia

steel recycling facility at the Coega Industrial Development Area Port Elizabeth

Prepared for SRK Consulting Port Elizabeth

APPENDIX A

LIST OF INTERESTED AND

AFFECTED PARTIES

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

DEDEARegional Manager

and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza

DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza

DEA Ocean and

CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza

DEA Ocean and

Coast

Oceanographer land-

based sources of

marine pollution

Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza

DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza

CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza

CDCEnvironmental

Project

Manager

Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza

TNPAPort of Ngqura

Environmental

Manager

Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet

NMBMEnvironmental

ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza

NMBMEnvironmental

ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza

DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza

DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza

WESSASenior Conservation

Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza

Zwartkops

ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700

hughlauegmailcom

zwartkopstrustiafricacom

SANParksNational Marine

CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza

Department Of

LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza

NMBM Air Quality

Division

Assistant

DirectorAir

Pollution and Noise

Templeton Titima 079 490 0574 Ttitimamandelametrogovza

NMBM Air Quality

DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza

NUMSARegional

RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

Department of

HealthNadiema

van der

Bergh083 378 2103

nadiemavanderberghimpiloecprovgov

za

DWA Chief Services

Officer

Joseph Jacobs 041 586 4884 jjacobsdwafgovza

EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza

NUMSecretary of union

officesZandile Xhentsa 043 743 6597 zxhentsanumorgza

DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza

Dynamic

CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom

EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza

Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza

UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom

lprincezago2uticom

Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza

Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza

Absa Mr Johann Steyn 082 3775820 johannstabsacoza

Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza

PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza

Universal

EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza

Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza

GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom

Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza

NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom

DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza

DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza

TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet

DWA Mr Landile Jack JackLdwagovza

DWA Ms Lizna Fourie FourieL4dwagovza

APPENDIX B

NOTICE OF ATMOSPHERIC

EMISSIONS LICENCE APPLICATION

AND ADVERTISEMENT

APPENDIX C

NOTICE OF COMMENT PERIOD FOR

DRAFT SCOPING REPORT

APPENDIX D

SUMMARY OF ISSUES RAISED AND

RESPONSES THERETO

April 2012

1

PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL

DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))

IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt

AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt

This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses

provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process

conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the

Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

2

IssueCommentQuestion Date

received Origin Response

1 Please provide more information with respect to the potential

dangers including the toxicity of the proposed project

07032011

By email

Wayne Poulton

(Bosun Brick

tenant at the

IDZ)

An Environmental Impact Assessment (EIA) was undertaken

which assessed the potential toxicity of the emissions and

effluent Mitigation measures were also recommended in the draft

Environmental Management Programme (EMP) to avoid

minimise or compensate any significant impacts The Draft

Environmental Impact Report and draft EMP were made available

to stakeholders for comment in March 2012

2 Do you have a Background Information Document (BID) or

similar that provides more information on the project

27032011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The BID was sent to all registered IampAPs on 4 May 2011

3 The RoD issued to the CDC on 632007 for the change in

land use for the remaining area of the Coega IDZ includes a

number of requirements with respect to

atmospheric emissions that should be considered in the

Atmospheric Emissions Licence (AEL) application such as

prohibiting and monitoring where possible visible emission

plumes to the atmosphere In particular the

recommendations on pp87-91 of the final revised Scoping

Report dated Nov 2006 must be implemented (clause 421)

04042011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

We have obtained copies of the documents referred to and ensure

that these requirements were taken into account in the

environmental assessment and AEL application

4 If the Port of Ngqura is used for import and export the scope

of the traffic impact assessment (TIA) should also include the

port

10052011

By email

Elliot

Motsoahole

(TNPA Port of

Ngqura)

The scope of the TIA was extended to include port related traffic

The TNPA at the Port of Ngqura was consulted and does not

have any objection to the project TNPA has indicated that the

development would require a minimum number of vessels per

year which would have minimal impact on the Port operations

However due notice would have to be given to the Port of Ngqura

before a vessel is scheduled to arrive so that the vessel can be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

3

IssueCommentQuestion Date

received Origin Response

accommodated at an available berth

5 Concerns with respect to potential stormwater pollution

draining into the Coega catchment and the port of Ngqura

The port needs to be dredged and heavy metals present a

risk in that regard

16052011

By

telephone

Andrew Lucas

(Department of

Water Affairs)

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination by effluent waste or

hazardousdangerous substances is very low

Thus no metals oils or other contaminants are expected to be

present in the stormwater

However stormwater pollution can occur in exceptional

circumstances such as accidents and emergencies The

emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

6 All steel sheets bathing unit must be under roof

7 The sludge out of the decreasing bath will be high in Na and

pH Therefore handling and disposal must be clarified up front

in this project

8 Per se the wastewater from decreasing bath will have high

ph and the component from the pickling unit will have low ph

Then it may be assumed that both streams will neutralize

each other Please then clarify proposed sewer discharge

with Nelson Mandela Bay Municipality up-front for acceptance

of influent as per the documented proposal

9 Pickling may result in dissolved metals How does your team

expect to deal with this As it is planned for discharge into

24052011

By email

Landile Jack

(Department of

Water Affairs)

All bathing units will be under roof

Effluent from the degreasing and pickling baths will be discharged

to the wastewater treatment plant The respectively alkaline and

acidic effluents will mix and neutralise each other in the

wastewater treatment plant Calcium or gypsum will be added if

required to complete the neutralisation process Effluent from the

treatment plant will be discharged to sewer Contact has been

made with the relevant officials and the Municipalityrsquos

requirements have been obtained The effluent discharged to

sewer will notably comply with the applicable discharge standards

Traces of metals (eg iron) may be present but will not exceed

prescribed thresholds The necessary authorisation will be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

4

IssueCommentQuestion Date

received Origin Response

sewer Clarity and acceptance needs to be agreed with

Nelson Mandela Bay Municipality Who owns the sewer

10 Quenching unit will results to Zinc particles How will this

affect sewer discharge This again must be dealt with within

the negotiations with the Municipality

11 Once all has been agreed with the Municipality and at the

same time due negotiations must be done with hazardous

waste courier and disposal facility to accept the hazardous

waste identified in all production lines

12 Of note is the low volume of the proposed WWTW facility ie

250 cubmweek And the no discharge of the quenching

water ie over-flow and cooling only Hence Zinc particles

generation

obtained from the municipality

The sludge from the treatment plant will be collected by a licensed

service provider and disposed of at a permitted site

The quenching bath will be periodically emptied (every 6 months)

and the water discharged will go to the water treatment plant Zinc

particles will settle in the sludge which will be disposed of at a

permitted site

Contact has been made with EnviroServ who manages the

Aloes II HH waste site regarding collection and disposal of

hazardous waste (See waste management report)

13 Investigate the potential effects of toxicity andor influence of

emissions waste and hazardous substances both in

terrestrial and marine fauna

14 With regards to water usage where is the plant going to

extract its waters used in galvanization andor waste

management process ie rainfall rivers or even from the

sea) and which avenues would be more environmental

friendly and effective

31052011

By email

A Bewana

(SANPARKS)

Emissions waste and hazardous substances are not expected to

affect terrestrial or marine ecosystems The air quality study

concluded that atmospheric emissions would not be harmful to

human health and by extension terrestrial fauna There are no

standards for air quality for defining faunal impacts therefore by

ensuring that standards for humans are complied with the impact

on fauna is deemed to be acceptable In this case the impact of

emissions on terrestrial and marine fauna are thus not significant

Solid and liquid wastes both general and hazardous as well as

hazardous substances will be stored handled and disposed of

appropriately to as not to cause harm to terrestrial or marine

fauna

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

5

IssueCommentQuestion Date

received Origin Response

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination and hence land-based

marine pollution by effluent waste or hazardousdangerous

substances is very low

The risk of emissions waste and hazardous substances to

terrestrial and marine fauna is thus very low

However pollution of terrestrial and marine ecosystems can occur

in exceptional circumstances such as accidents and emergencies

The emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

The CDC has an agreement with the NMBM to supply potable

water to the Coega IDZ Currently the infrastructure to supply

return effluent (RE) to the IDZ is not in place therefore Casa Steel

will be supplied with potable water up until such time as the

following 2 options of RE are available

1) Upgrading of the existing Fishwater Flats waste water

treatment works (between IDZ amp PE) including RE plant

and infrastructure to pipe RE to the IDZ (EIA for the

upgrade is underway)

2) Construction of a new waste water treatment works

including RE plant in Zone 9 of the Coega IDZ

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option should be investigated further between Agni and Casa The

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

6

IssueCommentQuestion Date

received Origin Response

CDC can facilitate discussions between the 2 investors

Compliance with CDC Permits amp Requirements

15 It should be made clear that tenants will be required to

comply with CDC requirements and the relevant conditions of

permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water

Licence for its Storm Water Systems on the

East Side of the Coega River that tenants will

need to take cognizance of The contents of the

ldquoIntegrated Stormwater Masterplan for the

eastern side of the Coega IDZ Oct 2010rdquo

especially the Table of best practice p53

onwards may need to be taken cognizance of

o CDC is developing an Operations

Environmental Management Plan that will place

certain obligations on tenants

16 Environmental audits and data collected during monitoring

(eg stack emissions stormwater) will need to be shared with

CDC

Air Emissions

17 Presumably permanent in stack monitoring will be required in

terms of AEL permit requirements

18 Abnormal operating conditions resulting in air emissions ndash I

could find nothing in the EIR to indicate under what

circumstances these could occur (eg start-up) potential

frequency and duration and the impact on ambient air quality

ndash these events usually result in the most problems wrt air

emissions

09042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

15 Compliance with the CDCrsquos Permits amp Requirements has

been included explicitly as a requirement in the EIR (p8-1) and

EMP (pp18 and 25) in the following terms

ldquoAs a tenant operating in the IDZ Casa Steel will be required to

comply with all current and future CDC requirements as well as

with the relevant conditions of permits licences issued to CDC

(eg Integrated Stormwater Masterplan for the eastern side of the

Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)rdquo

16 The need to communicate with the CDC on monitoring and

auditing activities was emphasised in Chapter 8 of the EMP The

following paragraphs were added

ldquoDuring construction the environmental officer will be responsible

for monitoring compliance with the EMP and authorisation

conditions and keeping records as required in the EMP andor

authorisation conditions

The ECO will conduct site inspections every two weeks audit the

records kept by the environmental officer and submit an

environmental compliance report every two months to the

authorities and the CDC (via the Environmental Monitoring

Committeersquos ECO)

During operation the health and safety officer will monitor

compliance with the EMP and the conditions of the Environmental

Authorisation Data collected during monitoring activities and any

environmental audits conducted will be shared with authorities

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

7

IssueCommentQuestion Date

received Origin Response

Water

19 Large volumes of (2000 m3mth) of water are required of

which only 400m3 needs to be potable The NMBM return

effluent system will provide non-potable water once it is

constructed What other water recycling initiatives can be

utilized to reduce potable water requirements (the ISWMP for

the eastern side of the Coega IDZ has some best practice

guidelines collecting rainwater from the roof etc)

General

20 There is no mention of how the CDC Architectural Guidelines

will be incorporated into the development (eg to prevent a

stark uniform warehouse type development)

21 Does NMBM have adequate fire services to cover this

development Apart from the large petroleum store are there

any other large fire hazards

22 Reports from the tenantrsquos ECO during construction and from

the SHE Officer during operations should be channeled to the

Coega Environmental Monitoring Committee This can be

directly or preferably via the EMCrsquos ECO (this will be while

the EMC and ECO are in place) A precedent has been set

for this in the Environmental Authorisations for Agni-Steel and

Kalagadi Manganese Smelter

23 All mitigation actions emanating from the EIR should be

summarized (preferably in a table) If compliance with them is

to be part of the Environmental Authorization from DEDEAT

then they (or the ones that DEDEAT deems to be applicable)

and the CDC (via the Environmental Monitoring Committeersquos

ECO)

The ECO (during construction) and the health and safety officer

(during operation) will report to the Coega Environmental

Monitoring Committee (EMC) via the EMCrsquos ECO (this will be

while the EMC and ECO are in place)rdquo

17 The draft EMP recommends regular monitoring of emissions

from the scrubbers and from the chromating process Additional

emissions monitoring requirements will be confirmed once the

AEL is issued Mention has been made in the EMP (pp11 and 19)

that all AEL conditions including monitoring and reporting

requirements should be adhered to

18 Abnormal emissions can occur in exceptional circumstances

Start-up will not cause abnormal emissions as the scrubbers

will be commissioned first and will be functioning once the plant

starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions

would be emitted as a building fugitive

The hourly hydrogen chloride ground level concentrations

(directly offsite) were predicted to be 239 microgmsup3 (based on the

emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits

as stipulated for listed activities for galvanising processes) using a

screen model which assumes worst case meteorological

conditions The health effect screening level for hourly HCl

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

8

IssueCommentQuestion Date

received Origin Response

should be attached to the EA as an Appendix (otherwise no

one knows about them or takes cognizance of them)

concentrations is 2100 microgmsup3 Assuming abnormal emissions

emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset

conditions will still be well within the health effect screening

levels

Similarly the hourly particulate emissions from the building

fugitives during upset conditions would amount to 293 microgmsup3

(based on the emission limits as stipulated for listed activities for

galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1

January 2015) directly off-site

Therefore if emissions are 5 times higher normal they will still be

within health effect screening levels and the daily PM10 NAAQS

levels

In the case of a fire a cocktail of gases and particulates could be

emitted and could be over the recommended levels This

situation will however be dealt with as an emergency and

normalised as quickly as is possible

The above has been added to the impact identificationdescription

and assessment sections of the EIR

19 The CDC has an agreement with the NMBM to supply

potable water to the Coega IDZ Currently the infrastructure to

supply return effluent to the IDZ is not in place therefore Casa

Steel will be supplied with potable water up until such time as the

infrastructure is in place

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

9

IssueCommentQuestion Date

received Origin Response

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option will be investigated further between Agni and Casa The

CDC has come forward to facilitate discussions between the two

investors

Other water recycling initiatives such as rainwater harvesting

have been considered but are not practical

20 The CDCrsquos Architectural and Landscape Design guidelines

contain requirements pertaining to such aspects as the height

orientation and mass and form of buildings as well as guidelines

for landscaping and signage in order to ensure an attractive

development and achieve an architectural integrity within the

Coega IDZ The plans for the proposed galvanizing plant will be

submitted to the Design Review Committee for approval as

required by the CDC

21 Casa Steel will be required to install fire hydrants according

to the NMBMrsquos standardsrequirements The CDC will provide

potable water (up until such time as return effluent is available)

and a connection to the boundary of the site which will be

connected to the fire hydrants The installation of the fire hydrants

will require approval by the Metrorsquos Fire Chief as was done for

Agni-Steel one of the investors in Zone 6

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

10

IssueCommentQuestion Date

received Origin Response

The Coega IDZ falls within the NMBM and therefore the rates and

taxes paid by the CDC covers the fire services for which the Metro

is responsible Currently the Metro has sufficient capacity to

provide fire services to the tenants within the IDZ This was

confirmed in discussion with the CDCrsquos Infrastructure

Development Unit It is however unknown at which point the

Metrorsquos Disaster Management Plan would not be able to

accommodate servicing tenants in the IDZ

The LNG burner is the only major fire hazard on the plant

22 See response to item 16 above

23 Key mitigation and management measures emanating from

the EIR were recapitulated in Chapter 9 of the EIR to form part of

the conditions attached to the Environmental Authorization from

DEDEAT All mitigation measures recommended as a result of the

impact assessment are presented in a table in the draft EMP

which is appended to the EIR (Appendix J)

24 Hydrogen chloride is one of the main emissions There are no

ambient air quality guidelines for HCl and the EIR says

concentrations will be well within health parameters

However the main problem with HCl is its corrosive effect -

there is absolutely no mention of this in the draft EIR nor air

specialist report

There needs to be some sort of comment assessment as to

whether HCl emissions are likely to impact on for example

the adjacent Agni-Steel Plant wrt corrosion - their factory

structure will be made of steel

11042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The atmospheric corrosion of metals is a complex process with

both the extent of deterioration and the mechanisms varying

considerably depending on the metal Depending on the way

pollutants are transported from the atmosphere to the corroding

surface two types of deposition processes are recognized in

atmospheric corrosion ndash dry deposition and wet deposition Wet

deposition refers to precipitation whereas dry deposition refers to

the remaining processes including gas phase deposition and

particle deposition The most important pollutants acting as

corrosive agents are sulphur and nitrogen compounds including

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

11

IssueCommentQuestion Date

received Origin Response

The EIR specialist rpt suggests monitoring HCl at ground

level on the property boundary and this is supported in case

there are complaints from neighbours

secondary pollutants and particulates Pollutants can contribute to

corrosivity individually however there may be a synergistic effect

when more than one of these pollutants is present in the

environment being affected In the field of atmospheric corrosion

sulphur dioxide is the single most investigated gaseous pollutant

and the quantification of the direct contribution of sulphur dioxide

to the corrosion process of metallic materials is comparatively well

understood (Tidblad amp Kucera 1998)

Very little work has reported on the effect of HCl on the

degradation of materials in the environment with no local dose-

response thresholds developed for corrosion occurring due to HCl

exposures This is probably because HCl which is present

outdoors in markedly reduced concentrations when compared

with SO2 has not been considered to contribute to significant

degradation of materials (Syed 2006) For this reason the

incremental corrosion due to HCl from the Coega Galvanising

Plant cannot be quantified

25 It is unacceptable for ILISO to be using CDC maps (see

figure 9 ndash pg5-6) without these maps being referenced

accordingly particularly when it appears that a CDC map has

been used and then overlaid with features by an unknown

author (ie CASA steel site Port (where the boundaries

depicted are incorrect) and a North legend which is out of

keeping with the overall cartographic intent of the original

work

26 Figure 10 is not referenced appropriately and I believe that I

commented previously in respect to references to roads not

12042012

By email

Graham Taylor

(Spatial

Development

Manager -

Infrastructure

Development

CDC)

This has been rectified in the final version of the report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

12

IssueCommentQuestion Date

received Origin Response

yet built As a result Figure 10 is confusing and clarity needs

to be provided in terms of referencing In addition the Port

shape is irregular and similar to the comment above

27 I acknowledge the emergency preparedness and response

plan but please confirm that this includes pro-active routine

monitoring of storm water leaving your premises to verify that

your assumptions of clean storm water are correct

13042012

By post

Andrew Lucas

(Director

WRampU

Department of

Water Affairs)

Pro-active routine monitoring of stormwater leaving the premises

will be undertaken This has been explicitly emphasised in

chapter 8 of the draft EMP

28 Will portablechemical toilets be used during construction

29 What provisions have been made for storm water drainage

during construction

18042012

By

telephone

Department of

Water Affairs

Port Elizabeth

Chemical toilets will be used during construction

The Casa Steel site will be located at the corner of two roads

drainage of stormwater from the site will take place through the

roadsrsquo drainage system

From Lea September [mailtoleailisocom]

Sent 11 March 2011 0935 AM

To Wayne Poulton

Cc Terry Baker

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Wayne

An Environmental Impact Assessment (EIA) will be undertaken for this project during the

next 10 to 12 months

We foresee that some of the key environmental impacts of the project will be in terms of air

quality water quality waste and hazardous substances

At this stage I am not able to give you any details regarding the potential toxicity of the

emissions andor effluent However specialist studies will be conducted as part of the EIA

that will determine the key impacts of the project Mitigation measures will also be identified

to avoid minimise or compensate any significant impacts

You are registered on the stakeholder database and you will be kept informed of progress in

the EIA process you will notably get the opportunity to access the reports produced and

provide any feedback on them

Please feel free to contact me should you need any further information

Best regards

Lea September

From Wayne Poulton [mailtowaynepbosuncoza]

Sent 07 March 2011 1257 PM

To Lea September

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

Please can you provide me with some more information as to the potential dangers including

the toxicity of this

Kind regards

Wayne

From Lea September [mailtoleailisocom]

Sent 04 March 2011 1123

To Lea September

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 March 2011 0745 AM

To Paul Martin

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 05 April 2011 0847 AM

To Paul Martin

Cc Terry Baker Renee von Gruenewaldt

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Thank you Paul for this information

I have downloaded a copy of the RoD and Scoping report you referred to and will make sure

these requirements are taken into account in the environmental assessment

Best regards

Lea September

From Paul Martin [mailtopmartinaxxesscoza]

Sent 04 April 2011 0955 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Further to my comments on 27311

Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in

the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega

IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised

scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions

including prohibiting and monitoring where possible visible emission plumes to the atmosphere

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Paul Martin

Sent Monday March 28 2011 745 AM

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 10 May 2011 0327 PM

To ElliotMotsoaholetransnetnet

Cc Terry Baker

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Mr Motsoahole

Thank you for your input on this issue

The Port of Ngqura will indeed be used for import and export At the moment the scope of

the traffic impact assessment only covers road traffic I have however relayed the matter to

our traffic specialist and we will consider this issue in the finalization of the Scoping Report I

will keep you informed of any developments in that regard

I trust this is acceptable to you

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]

Sent 10 May 2011 0855 AM

To Lea September

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

It has been noted that Casa Steel will source steel coils from various markets internationally and

in South Africa and the bulk of the plantrsquos production output will be exported to African countries

However there is no mention of logistic requirements

Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will

be used the scope of traffic impact assessment should also include the port

Regards

From Lea September [mailtoleailisocom]

Sent 04 May 2011 0747 AM

To Lea September

Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

Please find attached a letter announcing the EIA process underway for the proposed 80 000

tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as

a Background Information Document (BID) outlining the details of the project

Please contact me should you require any further information on this project

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

Elliot Motsoahole

Manager - Environment

Transnet National Ports Authority

Port of Nqqura

Port Control Building Klub Road Port Elizabeth 6212

PO Box 612054 Bluewater Bay 6212

+27 41 507 8450

+27 86 674 7729

Cell +27 83 542 5619

E-mail Elliotmotsoaholetransnetnet

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

DISCLAIMER The information contained in this communication is subject to copyright and

intended only for the use of leailisocom Unauthorised use disclosure or copying is

strictly prohibited Should a virus infection occur as a result of this communication the sender

will not be liable If you have received this communication in error please notify

elliotmotsoaholetransnetnet

From Lea September [mailtoleailisocom]

Sent 25 May 2011 1147 AM

To Jack Landile (ELS)

Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi

Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Landile

Thank you for your input

Contact has been made with the relevant Municipal Directorate and we will follow up with

them to obtain clarifications on all these issues

I have added both Lizna and yourself on the database and will keep you updated on

progress on this project

Best regards

Lea September

From Jack Landile (ELS) [mailtoJackLdwagovza]

Sent 24 May 2011 0524 PM

To Fourie Lizna (ELS)

Cc Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Hi Lizna

I missed you on this sorry

I linked Pieter twice Instead

Regards

Landile

From Jack Landile (ELS)

Sent 24 May 2011 0445 PM

To leailisocom

Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Lea

The e-mail you sent to Mr Kooverji dated 19 May 2011 refer

Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are

All steel sheets bathing unit must be under roof

The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project

Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal

Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer

Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality

Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines

Of note is the low volume of the proposed WWTW facility ie 250 cubmweek

And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles

generation

Regards

Landile

From Lea September [mailtoleailisocom]

Sent 19 May 2011 0947 AM

To Lea September

Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Stakeholder

Please find attached the remaining appendices to the draft Scoping report for the proposed

80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 June 2011 0411 PM

To Aphiwe Bewana

Subject RE Proposed 80 000 TPY Galvanizing plant in Coega

Dear Mr Bewana

Thank you for your input and apologies for the late reply

We have taken note of your comments and are will be taking them forward in the EIA phase

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Aphiwe Bewana [mailtoaphiwebewanagmailcom]

Sent 31 May 2011 1205 PM

To Lea September

Subject Re Proposed 80 000 TPY Galvanizing plant in Coega

Comment

Re Proposed 80 000 TPY Galvanizing plant in Coega

As SANParks we would like the EIA phase to investigate the potential effects of toxicity

andor influence of emissions waste and hazardous substances both in terrestrial and

marine fauna In the draft scoping report reference has been made with regards to the

terrestrial fauna but there is no attention to potential effects to marine fauna

Equally with regards to water usage where is the plant going to extract its waters used in

galvanization andor waste management process ie rainfall rivers or even from the sea)

and which avenues would be more environmental friendly and effective

Regards

Aphiwe Bewana

Marine Planner

South African National Parks

POBox 76693

NMMU

Port Elizabeth

6031

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 06 July 2011 1031 AM

To Lea September

Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Hi Lea

Irsquove reviewed the Final Scoping Report Herewith a few comments

1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the

Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a

revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the

NMBLP Please include only those in the IDZ as part of your IAP list

Regards

Andrea

From Lea September [mailtoleailisocom]

Sent Wednesday July 06 2011 859 AM

To Lea Septemberrsquo

Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Dear Stakeholder

The final scoping report for the above-mentioned project (attached) is available for comment

until 27 July 2011

The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic

commentaryrdquo tab

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 09 April 2012 1159 AM

To Lea September

Subject Comments on Galvanising Plant EIR Coega IDZ

Lea

Attached are my comments on the Draft EIR for the Coega IDZ galvanising

plant

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

Email attachment

COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ

Dr Paul Martin PO Box 61029

Bluewater Bay 6212 Tel 041 4665698

Email pmartinaxxesscoza

Compliance with CDC Permits amp Requirements

It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of

o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants

Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC

Air Emissions

Presumably permanent in stack monitoring will be required in terms of AEL permit requirements

Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions

Water

Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)

General

There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)

Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards

Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter

All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 11 April 2012 1245 PM

To Lea September

Subject Fw Comments on Galvanising Plant EIR Coega IDZ

Lea

One other comment on that I have on the Galvanising Plant Draft EIR

Hydrogen chloride is one of the main emissions There are no ambient air

quality guidelines for HCl and the EIR says concentrations will be well

within health parameters

However the main problem with HCl is its corrosive effect - there is

absolutely no mention of this in the draft EIR nor air specialist report

There needs to be some sort of comment assessment as to whether HCl

emissions are likely to impact on for example the adjacent Agni-Steel

Plant wrt corrosion - their factory structure will be made of steel

The EIR specialist rpt suggests monitoring HCl at ground level on the

property boundary and this is supported in case there are complaints from

neighbours

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Paul Martin ltpmartinaxxesscozagt

To Lea September ltleailisocomgt

Sent Monday April 09 2012 1158 AM

Subject Comments on Galvanising Plant EIR Coega IDZ

gt Lea

gt

gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising

gt plant

gt

gt

gt Dr Paul Martin

gt PO Box 61029

gt Bluewater Bay 6212

gt Tel 041 4665698

gt Cell 0732524111

gt email pmartinaxxesscoza

gt

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 12 April 2012 1139 AM

To Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Hi Lea

Hope yoursquore keeping well

I have requested comments from my colleagues and the CDC Casa team on the Draft EIR

Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report

Regards

Andrea

From Graham Taylor

Sent Thursday April 12 2012 838 AM

To Andrea Von Holdt Firhana Sam

Cc Johan Fourie Maria van Zyl Melikhaya Sihawu

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Andrea Firhana

Firhana if you could please ensure that the co-ordinates provided in the EIR correspond

with our records (pages 4-1 amp 4-2)

My comments are as follows

It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work

Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above

Regards

Graham Taylor

Spatial Development Manager - Infrastructure Development

Mobile 0832283055

Office 0414030454

Facsimile 0865185033

Email GrahamTaylorcoegacoza

Website wwwcoegacom

right PLACE | right TIME | right CHOICE

This email and all contents are subject to the following disclaimer

httpwwwcoegacomemaildisclaimerhtml

From Lea September [mailtoleailisocom]

Sent 04 May 2012 0411 PM

To Andrea Von Holdt

Cc Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Dear Andrea

We have taken note of the comments from the GIS Unit These issues have been rectified in

the final version of the EIR

Please can you forward to the relevant persons at the GIS Unit

Thank you

Best regards

Lea September

APPENDIX E

BACKGROUND INFORMATION

DOCUMENT

APPENDIX F

AIR QUALITY IMPACT ASSESSMENT

APPENDIX G

TRAFFIC IMPACT ASSESSMENT

APPENDIX H

WASTE MANAGEMENT AND HAZARDOUS

SUBSTANCES SPECIALIST STUDY

APPENDIX I

WATER QUALITY SPECIALIST STUDY

APPENDIX J

ENVIRONMENTAL MANAGEMENT

PROGRAMME

Page 3: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 i

PROPOSED 80 000 TPY GALVANIZING PLANT IN THE

COEGA INDUSTRIAL DEVELOPMENT ZONE

FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT

TABLE OF CONTENTS

ACRONYMS IV

EXECUTIVE SUMMARY V

1 INTRODUCTION 1-1

11 BACKGROUND 1-1

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS 1-1 13 PURPOSE OF THIS REPORT 1-2

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) 1-2

15 PROJECT TEAM 1-3

16 STRUCTURE OF THIS REPORT 1-4

2 DESCRIPTION OF THE PROPOSED PROJECT 2-1

21 TECHNICAL ASPECTS 2-1

211 The galvanizing process 2-1

212 Main inputs and outputs in operational phase 2-3

213 Installations on site 2-3

22 LOCATION OF THE PROPOSED GALVANIZING PLANT 2-4

23 NEED AND DESIRABILITY 2-6

24 ALTERNATIVES IDENTIFIED 2-6

25 CONSTRUCTION ASPECTS 2-6

26 OPERATION ASPECTS 2-7

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT 3-1

31 OBJECTIVES 3-1

32 AUTHORITY CONSULTATION 3-1

33 PUBLIC PARTICIPATION PROCESS CONDUCTED 3-1

34 LEGISLATION AND GUIDELINES CONSIDERED 3-2

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT 4-1

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION 4-1

42 SOCIO-ECONOMIC CHARACTERISTICS 4-3

43 BIOPHYSICAL CHARACTERISTICS 4-3

431 Surface and ground water 4-3

432 Climate and atmospheric conditions 4-3

433 Geology and soils 4-4

434 Terrestrial ecology 4-4

435 Land use and topography 4-7

436 Heritage and archaeological survey 4-7

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED 5-1

51 AIR QUALITY 5-1

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 ii

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS 5-2

53 BIODIVERSITY AND CONSERVATION 5-2

54 WATER QUALITY 5-2 55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES 5-3

56 HEALTH AND SAFETY 5-5

57 TRAFFIC 5-5

58 NOISE 5-9

59 SOCIO-ECONOMIC ASPECTS 5-10

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY 6-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS 7-1

71 IMPACTS DURING CONSTRUCTION 7-1

711 Air quality 7-1

712 Heritage and archaeological resources 7-1

713 Biodiversity and conservation 7-2

714 Water related impacts 7-3

715 Waste management 7-3

716 Health and safety 7-4

717 Traffic 7-4

718 Noise 7-5

719 Socio-economic 7-5

72 IMPACTS DURING OPERATION 7-6

721 Air quality 7-6

722 Water quality 7-7

723 Waste management and hazardous substances 7-8

724 Health and safety 7-9

725 Traffic 7-9

726 Noise 7-10

727 Socio-economic 7-11

73 COMPARATIVE ASSESSMENT OF IMPACTS 7-11

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME 8-1

9 ENVIRONMENTAL IMPACT STATEMENT 9-1

10 CONCLUSION AND RECOMMENDATIONS 10-1

11 REFERENCES 11-1

LIST OF FIGURES

Figure 1 Process flow diagram for proposed galvanizing plant 2-2

Figure 2 Continuous Galvanizing Line 2-3

Figure 3 Location of the proposed galvanizing plant 2-5

Figure 4 Zone layout in the Coega IDZ 4-1

Figure 5 Site location 4-2

Figure 6 Coega IDZ Open Space Management Plan (OSMP) 4-5

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble gravels

exposed by tracks in Zone 6 (Source Binneman 2010) 4-8

Figure 8 Coega IDZ road network layout (Adapted from BKS 2006) 5-6

Figure 9 Coega IDZ road network 5-7

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 iii

Figure 10 Trip distribution for freight and personnel trips 5-8

Figure 11 Morning peak hour Casa Steel development traffic 5-9

Figure 12 Casa Steel organisation chart 5-10

LIST OF TABLES

Table 1 Coordinates of site corners for the proposed galvanizing plant 4-1

Table 2 Hazardous materials to be used on site 5-4

APPENDICES

APPENDIX A List of registered stakeholders

APPENDIX B Notice of AEL application and advertisements

APPENDIX C Notice of comment period for draft scoping report

APPENDIX D Summary of issues raised and responses thereto

APPENDIX E Background Information Document

APPENDIX F Air Quality Impact Assessment

APPENDIX G Traffic Impact Assessment

APPENDIX H Waste Management and Hazardous Substances specialist study

APPENDIX I Water Quality Specialist Study

APPENDIX J Environmental Management Programme (EMP)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 iv

ACRONYMS

AEL Atmospheric Emissions Licence

BID Background Information Document

CCA Custom Controlled Area

CDC Coega Development Corporation

DEA Department of Environmental Affairs

DEDEAT Department of Economic Development Environmental Affairs and Tourism

DWA Department of Water Affairs

EAP Environmental Assessment Practitioner

EIA Environmental Impact Assessment

ELC Environmental Liaison Committee

EMP Environmental Management Programme

GN Government Notice

IampAPs Interested and Affected Parties

IDZ Industrial Development Zone

LNG Liquid natural gas

masl Meters above sea level

MSDS Material Safety Data sheet

NEMA National Environmental Management Act

NEMBA National Environment Management Biodiversity Act (No10 of 2004)

NMBM Nelson Mandela Bay Municipality

OSMP Open Space Management Plan

PoS Plan of Study

SAHRA South African Heritage Resources Agency

TNPA Transnet National Ports Authority

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 v

EXECUTIVE SUMMARY

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone

(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province

Galvanizing consists of coating steel with zinc in order to protect it from corrosion An

Environmental Impact Assessment (EIA) is required as the proposed project involves several

activities listed in terms of Section 24 of the National Environmental Management Act

(NEMA) 107 of 1998 as amended and requires an environmental authorisation The

project also involves activities listed in terms of the National Environmental Management Air

Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008

which respectively require an Atmospheric Emissions Licence and a Waste Management

Licence

The Scoping and Environmental Impact Assessment process underway covers all aspects of

the project and informs all three applications

Scoping was the first phase of investigations and aimed to inter alia identify potential key

environmental issues and impacts to be addressed in the EIA phase

The following environmental issues and potential impacts identified in the Scoping Phase

were investigated in the EIA

Air quality

The galvanizing process generates atmospheric emissions which are regulated in terms

of the National Environmental Management Air Quality Act and appropriate measures

are required in order to adhere to the applicable standards Other sources of impact on

air quality include emissions from the LNG burner emissions and dust from the transport

of steel and other materials in trucks as well as dust and gas emissions related to

construction activities Mitigation measures recommended in the EMP will ensure that air

quality impacts are kept to a minimum and compliance with emissions standards is

maintained

Biodiversity and conservation

Certain types of vegetation in the IDZ are of high conservation importance Protected

species will be rescued as per the CDCrsquos requirements

Water quality

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through spills

or leaks This risk can however be minimized if not avoided altogether through design

choices (bunded areas) and the adherence to best practice guidelines for the handling or

the transport of hazardous substances and waste

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vi

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

Waste management and hazardous substances

The plant will generate a relatively small amount of solid waste which will be re-used

recycled or disposed of in accordance with the EMP recommendations

There will be a wastewater treatment plant on site which will neutralise process water

(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer

Hazardous waste from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site

at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and

removed on a monthly basis is limited to 10 m3

A number of substances classified as hazardous are used in the galvanizing process and

the transport and handling of these is subject to certain rules and guidelines

In addition the permanent storage of a high quantity of liquid petroleum on site (20 000

litres at any one time) is subject to certain specifications and requires approval from the

municipality

Health and safety

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling of the various substances used will be done in

accordance with applicable instructions (cf material safety data sheets)

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as provide

site supervision including executing tests (individual test cold run and hot run) during 3

months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the EMP

Traffic

In the operational phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and from

the Port of Ngqura

The traffic expected to be generated during construction as well as operation is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low and

the total traffic generated by Casa Steel is also relatively low

The impact on port traffic is also negligible and well within the portrsquos capacity

Socio-economic aspects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vii

The proposed galvanizing plant will make a positive contribution by creating jobs during

construction and operation and generating business for the various service providers

Fatal flaws

No fatal flaws have been identified

The significance of these potential key environmental impacts were assessed in the EIA

phase and the findings of this phase of investigations are presented in this report

The main findings of the EIA are as follows

During construction impacts post-mitigation are low with the exception of noise and

biodiversity as the construction of the plant will result in the destruction of habitat

and loss of fauna and flora and noise impacts inherent to construction activities

Mitigation measures have been included in the EMP for these impacts and they have

a medium significance post-mitigation

All impacts were assessed as low during operation after mitigation

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium

to long term similar impacts are likely to occur due to ongoing developments in the

IDZ

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

The CDC has its own requirements regarding the monitoring of certain aspects of the

project such as the quality of the effluent and the noise levels These have been

incorporated into the EMP Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as other

infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified and

assessed No fatal flaws have been identified

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 viii

It is recommended that the project be approved subject to the conditions listed above

and adherence to the EMP recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-1

1 INTRODUCTION

11 BACKGROUND

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)

Nelson Mandela Bay Municipality Eastern Cape Province

The demand for galvanised steel products is high in South Africa and Africa and is

expected to increase in the foreseeable future From an economic point of view the

proposed project has therefore been found to be viable

Casa Steel will source the steel coils from various markets internationally and in

South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is

destined to be exported mainly to African countries

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

An Environmental Impact Assessment (EIA) is required as the proposed project

involves several activities listed in terms of Section 24 of the National Environmental

Management Act (NEMA) No 107 of 1998 as amended and requires an

environmental authorisation

The following listed activities requiring environmental authorisation have been

identified

Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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 metres

Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped

land to industrial use greater than 1 ha but less than 20 ha in size outside an

urban area

Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any

process or activity requiring a license in terms of national or provincial legislation

governing the generation or release of emissions

Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5

hectares or more of vegetation where 75 or more of the vegetative cover

constitutes indigenous vegetation except where such removal of vegetation is

required for

(i) purposes of agriculture or afforestation inside areas identified in

spatial instruments adopted by the competent authority for

agriculture or afforestation purposes

(ii) the undertaking of a process or activity included in the list of waste

management activities published in terms of section 19 of the

National Environmental Management Waste Act 2008 (Act No 59

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-2

of 2008) in which case the activity is regarded to be excluded from

this list

(iii) the undertaking of a linear activity falling below the thresholds in

Notice 544 of 2010

Hot dip galvanizing is a listed activity in terms of section 21 of the National

Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires

an Atmospheric Emissions Licence (AEL)

In addition the treatment of wastewater with an annual throughput capacity of more

than 2000 m3 is a listed activity in terms of the National Environmental Management

Waste Act 59 of 2008 and requires a waste management licence

ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental

Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact

Assessment process in terms of section 24 of NEMA for the construction and

operation of the proposed galvanizing plant The EIA process covers all aspects of

the project and informs all three applications (for environmental authorisation waste

management licence and AEL)

13 PURPOSE OF THIS REPORT

This report builds on the scoping report submitted to the Eastern Cape Department of

Economic Development and Environmental Affairs (DEDEA) and the Nelson

Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It

describes the proposed project and presents the findings of the second phase of

investigations (EIA phase)

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT

PRACTITIONER (EAP)

The EIA was managed by Ms Terry Baker a certified Environmental Assessment

Practitioner with 20 years of working experience She has a MA in Environmental

Management and specialises in Environmental Impact Assessments and Project

Management She has been involved in a variety of different types of EIAs including

for water supply projects dams transmission lines roads and airports in South

Africa Botswana Uganda Lesotho and Mozambique She has been involved in

water resource management and public participation programmes on a number of

projects Terry has also been involved in the use of Geographic Information Systems

environmental status quo reports water quality assessments socio-economic and

institutional development projects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-3

15 PROJECT TEAM

In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen

(water quality specialist) and Lea September (EAP) with specialist input from Renee

von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous

substances) and Seniel Pillay (Traffic Impact Assessor)

The Business Unit Head of the ILISO Environmental Management Discipline Group

Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is

a Fellow of the South African Institution of Civil Engineers a member of the South

African Society of Aquatic Scientists of the Environmental Scientific Association of

the International Water Association of the Water Institute of South Africa and of the

Vaal River Catchment Association He is a certified Environmental Assessment

Practitioner with 30 years experience who specialises in project management

environmental impact assessments and water resource planning He specifically has

extensive experience in water quality especially water quality management water

quality monitoring and water quality assessment Martin has experience in managing

projects that involve multi-disciplinary teams and public consultation and

participation in South Africa and abroad

Lea September is an Environmental Assessment Practitioner with a Masters degree

in Environmental Management She has experience in impact assessment and

environmental management and has been responsible for drafting impact

assessment reports and Environmental Management Programmes and conducting

public participation processes as well as high level environmental screenings for a

variety of projects in the energy water transport and industrial sectors

Renee von Gruenewaldt has nine-years experience in the field of air pollution

impact assessment and air quality management Prior to becoming involved in air

quality consultation she was part of the Highveld Boundary Layer Wind Research

Group based at the University of Pretoria Since joining Environmental Management

Services (the company now Airshed Planning Professionals) she has undertaken

numerous air pollution impact studies and has provided extensive guidance to both

industry and government on air quality management practices

Pieter Smuts graduated as a Civil Engineer and became involved in the field of

municipal engineering and infrastructure construction He has specialized during the

last twelve years in solid waste management He has completed waste management

plans feasibility studies and final designs of waste management facilities in South

Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and

the review of the Mavoco hazardous waste landfill design in Maputo Mozambique

and completed a study on hazardous waste (textile factory sludge) management in

Maseru Lesotho

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-4

Seniel Pillay is a transportation engineer with over 16 years experience in

transportation planning and traffic engineering He has been involved in a wide

range of projects ranging from developing the Transport Operations Plan for the

FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System

for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller

traffic impact assessments for inter alia road improvement schemes Of particular

relevance to this project his experience includes Heavy Goods Vehicle Study for

eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact

Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash

Preliminary Transportation Assessment

16 STRUCTURE OF THIS REPORT

The proposed project and the alternatives considered are described in Chapter 2

Chapter 3 details the approach adopted for the EIA phase

The biophysical and socio-economic environment affected by the activity is described

in Chapter 4

The environmental impacts identified are discussed in Chapter 5

The EIA methodology is described in Chapter 6 and Chapter 7 presents the results

of the impact assessment

The environmental impact statement is presented in Chapter 8

Finally Chapter 9 spell out the conclusions and recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-1

2 DESCRIPTION OF THE PROPOSED PROJECT

21 TECHNICAL ASPECTS

211 The galvanizing process

Galvanizing consists of coating steel with zinc in order to protect it from corrosion

Before steel strips can be galvanized they undergo a pre-treatment in order to

ensure that the steel sheets are free from any surface oxides as they enter the

molten zinc coating Bath This is done by removing the oil from the steel sheets (in

the degreasing unit) and then removing the rust from the surface of the sheet (in the

pickling unit)

The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The

melting zinc on the strip surface will be cooled and solidified through air cooling in the

cooling tower

Finally the galvanised steel sheets are dipped into a water quenching tank in order to

further cool the sheets from about 150degC to 40degC

It is possible to make galvanised steel more durable by chromating it Approximately

50 of the galvanised steel production output will receive chromate passivation

treatment after quenching the galvanised steel sheets will be sprayed with a chrome

solution (3 kgcm2)

After galvanizing and chromating the steel sheets are cut to achieve the desired coil

size and weight and transported to the storage yard

The process flow diagram below (Figure 1) illustrates the main stages of the

galvanizing process and indicates the major inputs and outputs as well as the

resulting effluent and atmospheric emissions

Draft Environmenal Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-2

Figure 1 Process flow diagram for proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-3

212 Main inputs and outputs in operational phase

In view of the above the main inputs will be as follows

Steel coils 85 000 tonsyear

Zinc 870 tonsyear

Electricity 2500 kVA

Water 2000 m3month (of which 400 m3 will be potable water)

Liquid Natural Gas (LNG) 270 NM3hour

Sodium hydroxide (NaOH) 1000 m3year

Hydrochloric acid (HCl) 800 m3year

Chrome (Cr+3) 10 m3year

The main outputs will be

Galvanized steel 80 000 tonsyear

Scrap metal 20 tonsyear

General waste 65 tonsyear

Hazardous waste 2 m3month

Wastewater 012 Mlweek

Atmospheric emissions lt 5 ppm

213 Installations on site

The bulk of the operations involved in the galvanizing process occur along a

continuous galvanizing line (See Figure 2 below) which is the main piece of

machinery required for the proposed galvanising plant

Figure 2 Continuous Galvanizing Line

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-4

Water is one of the major inputs and is used throughout the galvanizing process notably

for rinsing and cooling purposes and as a mixing agent for the various chemical

solutions The plant will have a water treatment plant on site to treat the water used in

the various processes (approx 250 m3

of wastewater per week) The wastewater

treatment facility will be operated by a professional water treatment company as Casa

Steel does not have the required expertise in house to treat its process water Sulphuric

acid (H2SO4) is used as part of the treatment process to reduce caustic soda The

neutralised water is discharged to the sewer while any sludge is disposed of as

hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)

will be disposed of

Some critical areas of the galvanizing process such as the zinc pot require uninterrupted

power It is therefore proposed to install an LNG burner to maintain the zinc bath at a

temperature of between 450 and 460degC

22 LOCATION OF THE PROPOSED GALVANIZING PLANT

The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast

of Port Elizabeth in the Eastern Cape (Figure 3)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-5

Figure 3 Location of the proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-6

23 NEED AND DESIRABILITY

The profitability of the proposed project has been established by Casa Steel and a

pre-feasibility study has confirmed that the proposed project was feasible from a

technical and financial point of view The Coega IDZ is specifically designed to host

facilities such as a galvanizing plant and can provide the necessary infrastructure

and services to its investors It therefore constitutes a very suitable location for the

project

24 ALTERNATIVES IDENTIFIED

Zone 6 has been specifically earmarked for heavy ferrous metal industries and is

therefore a suitable location for the proposed galvanizing plant as such no site

alternatives have been provided for and assessed in this EIA However prior to the

commencement of the EIA process Casa Steel was presented with a number of

different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the

selection of the site were

(a) The dimensions of the land the site should be at least 200 m long and

50 m wide in order to accommodate the galvanizing line and adjacent lay

down area and additional land should be available next to the site for future

expansion

(b) The fiscal arrangements applying to the site the site should be located

within the future Custom Controlled Area (CCA) as the bulk of the

production output of the plant will be exported

The no-go alternative is assessed in this report

25 CONSTRUCTION ASPECTS

The construction phase of the project will take about 12 months and will essentially

consist of erecting a building to house the galvanizing line and other equipment and

preparing a concrete laydown area adjacent to the building

The CDC will provide an access point from the existing tarred road that will lead to

the site

Approximately 100 workers from the surrounding areas will be contracted for the

construction work

The requirements in terms of services during construction are listed below

Water 1000 m3month

Electricity 2500 kVA

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-7

The CDC will provide temporary services for the construction phase including a

conservancy tank for flush toilets Sewage infrastructure will only be provided for the

operational phase

26 OPERATION ASPECTS

Before the plant can become fully operational the equipment and machinery will be

tested for approximately 3 months The supplier will supervise these tests as part of

the transfer of know-how and training of staff on the plant

Casa Steel will start operating the plant at a reduced capacity (about 50 000

tonsyear) for a period of time (mostly determined by market aspects) before bringing

production to full capacity (80 000 tonsyear) This is done by operating the line for

longer hours

Approximately 50 to 60 people will be working on the plant Approximately 6-10 of

these will be unskilled 40-45 skilled and about 5 people in managerial positions

The requirements in terms of services during operation are as follows

Water 2000 m3month

Electricity 2500 kVA

Effluent discharge 24 m3day

The CDC has entered into agreements with the municipality to secure the provision

of services such as water and electricity to its tenants Tenants in the IDZ have their

own agreements with the NMBM for electricity while the agreements for water and

sewage are with the Facilities Unit of the CDC

Regarding discharge of wastewater to the sewer the municipality indicated that the

only requirement is that the water discharged complies with applicable municipal

discharge standards

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 3-1

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT

31 OBJECTIVES

The main objectives of the EIA phase are to

Assess the significance of the environmental issues and impacts identified in the

scoping phase focusing on key impacts

Recommend appropriate measures to mitigate negative impacts and enhance the

benefits and include them in the draft EMP

Undertake a public participation process that provides opportunities for all

interested and affected parties (IampAPs) to be involved

32 AUTHORITY CONSULTATION

The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental

Liaison Committeersquo (ELC) which comprises representatives of various authorities

including DEDEAT the Department of Environmental Affairs (DEA) and Department

of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the

Coega Development Corporation (CDC) and Transnet National Ports Authority

(TNPA) The ELC has been specifically formed to facilitate EIA applications in the

IDZ

Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to

the clearance of vegetation should be included in the application A formal request

was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the

application and all registered stakeholders were informed of the request in writing on

19 October 2011

33 PUBLIC PARTICIPATION PROCESS CONDUCTED

On-site notices were replaced by a notification displayed on the CDCrsquos digital notice

board at the business centre in Zone 1 of the IDZ The eNotice was placed on

13 April 2011 and will remain for the full duration of the EIA process

Registered stakeholders will be notified in writing of the availability of the draft EIA

report and EMP which will also be advertised in a local newspaper Stakeholders

including state departments and the public will have forty (40) days to comment on

the draft EIA report and EMP The draft EIA report and EMP will be sent by email

where possible and made available for download on the ILISO website

(wwwilisocom)

A summary of all issues and comments received during the stakeholder consultation

process as well as of correspondence in that regard will be captured in an Issues

and Responses Report that will form an Appendix to the EIA Report

The list of registered IampAPs is included in Appendix A

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 3-2

34 LEGISLATION AND GUIDELINES CONSIDERED

The following legislation and guidelines were considered in the preparation of this

report

National Environmental Management Act Act No 107 of 1998

NEMA EIA Regulations 2010

National Environmental Management Air Quality Act Act No 39 of 2004

National Environmental Management Waste Act Act No 59 of 2008

Hazardous Substances Act Act 15 of 1993

Occupational Health and Safety Act Act 85 of 1993

Hazardous Chemical Substances Regulations 1995 (GNR 1179)

Major Hazard Installation Regulations 2001 (GNR 692)

National Water Act Act 36 of 1998

National Heritage Resources Act Act 25 of 1999

DEAT Integrated Environmental Management Information Series 1-5 and 12-15

NEMA draft Implementation Guideline

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Public Participation (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Alternatives (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Draft Guideline for Determining the Scope of Specialist

Involvement in EIA Processes (2005)

IAIA guidelines

National air quality standard for thoracic particulates Government Gazette

No 32816

Listed activities and associated minimum standards identified in terms of section

21 of the National Environmental Management Air Quality Act Act No 39 of

2004 Government Notice 248 of 2009

Minimum Requirements for the Handling Classification and Disposal of

Hazardous Waste DWAF Waste Management Series (1998)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-1

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION

The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega

IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay

to the north of the N2 highway between Port Elizabeth and Grahamstown east of the

Coega River

The co-ordinates of the corners of the site are shown in Table 1

Table 1 Coordinates of site corners for the proposed galvanizing plant

Point Longitude Latitude

A 25deg411126E 33deg45587S

B 25deg411156E 33deg45499S

C 25deg411938E 33deg45131S

D 25deg412174E 33deg45481S

E 25deg412508E 33deg45979S

F 25deg412634E 33deg451160S

G 25deg411782E 33deg451560S

H 25deg411692E 33deg451428S

J 25deg411314E 33deg45868S

Figure 4 Zone layout in the Coega IDZ

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-2

Figure 5 Site location

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-3

42 SOCIO-ECONOMIC CHARACTERISTICS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the

NMBM There are no residents within the IDZ

As far as the broader NMBM and Eastern Cape Province are concerned the

following can be noted The NMBM is located within the Eastern Cape Province the

2nd largest Province in South Africa (3rd in terms of population) characterised by a

predominantly black population with low incomes and high levels of unemployment

(CES 2010)

The NMBM has a population of just above 11 million and covers an area of

1 950 km2 It is the main urban and industrial centre of the province and Port

Elizabeth in particular which forms part of the NMBM is the commercial capital of

the Eastern Cape 52 of the NMBM population is female and 37 is below the

age of 20 these two groups are particularly affected by unemployment

43 BIOPHYSICAL CHARACTERISTICS

431 Surface and ground water

No rivers occur in Zone 6 There is however a natural attenuation pond on the

southern most part of the site which will have to be avoided

The IDZ is underlain by calcrete sand and gravel deposits that overlie low

permeability clays These clays limit the vertical infiltration of rainwater and induce a

horizontal groundwater flow towards the Coega River channel which is the most

significant surface water feature in the Coega IDZ Consequently rapid run-off takes

place following precipitation (Jacobs 2008)

Groundwater levels at Coega are generally about 3 to 5 m below surface ie just

above the contact between the permeable sands and the underlying impermeable

clays The groundwater flow direction is to the southeast following the surface water

drainage direction (Jacobs 2008)

432 Climate and atmospheric conditions

Port Elizabeth has a warm temperate climate and the temperature ranges are not

extreme Exceptionally high temperatures may be experienced during berg wind

conditions which occur frequently during autumn and winter Extreme temperatures

also occur during summer with little accompanying wind

The wind regime for the area largely reflects the synoptic scale circulation with

dominant westerly and northwesterly flow fields representing the pre-frontal

conditions and south-westerly flow fields representing the frontal conditions The

south-easterly and south-westerly wind flow (land breeze) increases during daytime

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-4

conditions with westerly and north-westerly wind flow increasing during the night (sea

breeze)

The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of

Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15

km southwest) and Port Elizabeth (~23 km southwest)

An ambient air monitoring network has been established in the Coega IDZ which

consists of three monitors Saltworks Motherwell and Amsterdamplein Although

NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative

impacts due to the proposed Galvanising Plant is PM10 A maximum daily average

PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed

SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3

was exceeded on 17 days in 2007 and 26 days in 2008

Existing sources of emissions in the vicinity of the proposed galvanizing plant include

industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other

fugitive dust sources (von Gruenewaldt 2011b)

433 Geology and soils

Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel

and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly

limestone and conglomerate

434 Terrestrial ecology

This section draws from the EIA report compiled for the Agni Steel (formerly Afro-

Asia) steel processing facility which is adjacent to the proposed site for the

galvanizing plant (Jacobs 2008)

The area consists largely of grasses succulents and scrubby bush with alien

species making up the greater part of the more dense vegetation

Zone 6 falls within the inland vegetation and is characterised by a vegetation type

referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the

Coega IDZ and has been found to have three times the level of endemism of other

vegetation communities in the Coega IDZ Bontveld therefore has a high

conservation status Two Bontveld conservation areas have been identified within the

IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)

Bontveld that will be destroyed as a result of development in the IDZ will be given

conservation status in these two areas

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-5

Figure 6 Coega IDZ Open Space Management Plan (OSMP)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-6

Certain areas in the IDZ are invaded by alien plant species The most common

invader species is rooikrans (Acacia cyclops) which presently forms large

monospecific stands in areas throughout the Coega IDZ There are several other

aliens present that pose a threat to the flora of this area including the prickly pear

(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)

Loss of vegetation and alien plant invasion due to human activity has resulted in a

reduction in the diversity of terrestrial fauna

The majority of mammals present in the Coega IDZ are small or medium-sized Of

the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed

gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of

Algoa Bay however it is not considered threatened The gerbil is common in

foredune and dune thicket habitat in the Coega region and is therefore unlikely to

occur on the proposed site

A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird

species are resident or common to the area Most diversity occurs in the thicket

although the coastal area also supports specialised avifauna Two species of tern

the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well

as the Cape gannet (Morus capensis) and the African penguin (Spheniscus

demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne

caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant

(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser

flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns

are two of the most endangered coastal species in South Africa Other bird species

of conservation concern include the Whitefronted plover (Charadrius marginatus)

African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus

bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus

ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides

paradisea) Breeding pairs of Damara terns and African black oyster catchers have

been observed in the coastal dunes of the IDZ but should not be affected by

developments that fall outside the dune areas

The Eastern Cape supports nearly a third (approximately 133 species) of the reptile

species recorded in South Africa More than half of the Eastern Capersquos endemic

reptile species occur in the Algoa Bay area giving the region a high conservation

value A total of 63 reptile species are believed to occur within the Coega IDZ The

majority of these are found in Succulent Thicket and riverine habitats Only a few

reptile species occur in the coastal dunes and estuarine habitats More than a third of

the species are described as relatively tolerant of disturbed environments provided

that migration corridors of suitable habitat are maintained to link pristine habitats

Twenty two reptiles are of special concern including five endemic species (two of

which may also be endangered) four endangered sea turtles eight species listed

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-7

with CITES one rare species and four species at the periphery of their range

Fourteen of these species of special concern are confirmed as occurring on or within

2 km of the Coega IDZ

A total of 32 amphibian species and sub-species occur in the Eastern Cape

representing almost a third of the species recorded in South Africa However none of

the species are endemic or Red Data Book species Based on previous studies in the

area it is estimated that approximately 17 amphibian species occur within the Coega

IDZ Four species are listed as peripheral but none are threatened internationally

These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog

(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and

the bubbling kassina (Kassina senegalensis)

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated

vegetation has not been extensively studied One grasshopper species Acrotylos

hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue

(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis

pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in

four localities in the Eastern Cape one of which is within the Coega IDZ The Coega

copper Aloeides clarki is endemic to this particular region of the Eastern Cape and

is currently known to occur in three localities two of which are in the Coega IDZ The

localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the

Coega IDZ and their distributions were taken into account when defining Coegarsquos

open space system and Development Framework Plan

435 Land use and topography

The land is currently undeveloped and earmarked for industrial development The

site is relatively flat ranging from an elevation of 66 masl on the northern-most

corner to 59 masl at the southern-most corner

436 Heritage and archaeological survey

Extensive studies have been undertaken in Zone 6 with respect to heritage aspects

Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a

2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond

2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is

currently being finalised

Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing

Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha

in extent and was located next to the R102 road to Motherwell Kaplan conducted

HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi

Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will

now be located in Zone 5)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-8

The various archaeological investigations reached similar observations and

conclusions Stone tools of various densities and types were found throughout the

zone The majority of the stone tools were mainly of Earlier and Middle Stone Age

and occasional Later Stone Age origins (Figure 4)

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble

gravels exposed by tracks in Zone 6 (Source Binneman 2010)

The stone tools which comprised of quartzite flakes chunks flaked pebblecobble

and cores were randomly distributed across the landscape and are in secondary

context There were no lsquoconcentrationsrsquo of tools observed which suggested any

spatial patterning or activity areas although these may be present or covered by soil

and vegetation

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 5-1

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED

The following environmental issues and potential impacts were identified in the

Scoping phase

51 AIR QUALITY

The galvanizing process generates atmospheric emissions with particulates and

hydrogen chloride representing the main pollutants of concern The plant is fitted with

air extraction as well as scrubber systems which are designed to retain the bulk of

pollutants and particles for each of the processes in such a way that less than 5 ppm

of gases and particles will be released into the atmosphere after the fume scrubber

Other sources of impact on air quality include emissions from the LNG burner as well

as emissions and dust from the transport of steel and other materials in trucks

Construction activities will also create dust and gas emissions due to the clearing of

groundcover tipping of material to storage pile levelling of area wind erosion from

storage piles vehicle and construction equipment activity and tailpipe emissions

from vehicles and construction equipment such as graders scrapers and dozers

Overall the air quality impact assessment (Gruenewaldt 2011b) found that

The predicted particulate oxides of nitrogen carbon monoxide and sulphur

dioxide concentrations are all below the National Ambient Air Quality Standards

for all averaging periods

The predicted off-site concentrations of hydrogen chloride are well below the

most stringent effect screening levels

No odour threshold exceedances for hydrogen chloride were predicted to occur

due to routine operations at the Steel Galvanising Plant The South Wales

Environmental Protection Authority stipulates that an odour unit of 20 is

acceptable for urban areas The odour unit would be lt10 directly off-site for

hydrogen chloride

Abnormal emissions can occur in exceptional circumstances Start-up will not

cause abnormal emissions as the scrubbers will be commissioned first and will be

functioning once the plant starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions would be emitted as a

building fugitive

The hourly hydrogen chloride ground level concentrations (directly offsite) were

predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based

on the emission limits as stipulated for listed activities for galvanising processes)

using a screen model which assumes worst case meteorological conditions The

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-2

health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming

abnormal emissions emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset conditions will still

be well within the health effect screening levels

Similarly the hourly particulate emissions from the building fugitives during upset

conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for

listed activities for galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly

off-site

Therefore if emissions are 5 times higher normal they will still be within health effect

screening levels and the daily PM10 NAAQS levels

In the case of a fire a cocktail of gases and particulates could be emitted and could

be over the recommended levels This situation will however be dealt with as an

emergency and normalised as quickly as is possible

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS

The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of

its heritage potential and there are no proposed protected geosites in Zone 6

Should any artefacts be discovered during construction procedures stipulated in the

draft EMP will apply

53 BIODIVERSITY AND CONSERVATION

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

In terms of terrestrial fauna the CDCrsquos open space management plan provides for

the preservation of certain corridors The destruction of certain habitats as a result of

the development will therefore not automatically result in the loss of certain species

54 WATER QUALITY

There is a natural attenuation pond on the southern most part of the site which will be

avoided

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through

spills or leaks

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-3

This risk can however be minimized if not avoided altogether The floor of the factory

will be designed as a bunded area to contain any spills and the entire process will be

contained Potential spills or leaks will therefore be contained and will not impact on

water resources Storm water is therefore considered clean water under normal

operational conditions An oil trap will be placed at the exit of the site to ensure that

no grease from the laydown area enters the stormwater system

Spills and leaks can occur during the handling or the transport of hazardous

substances Best practice guidelines will be followed to ensure that this risk is

adequately managed

Wastewater discharged to sewer will be treated to comply with municipal discharge

standards and is not expected to have an impact on the chemical characteristics of

the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be

discharged from the plant is small in relation to the total volume received at the

Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works

(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently

operated at 61 of its capacity which is approximately 80 Mℓday Thus the

0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore

not have any significant impact on the WWTW

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES

The plant will generate a relatively small amount of solid waste in the form of scrap

metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)

The scrap metal may be sold to other steel processing facilities such as Agni Steel

which will be located next to the plant or collected and disposed of with the rest of

the solid waste by a licensed service provider

As mentioned previously there will be a wastewater treatment plant on site which will

neutralise process water (012 Mlweek) in order to ensure it is of a standard

acceptable for discharge to sewer Waste in the form of sludge from the

neutralization or spent acid must be disposed of as a hazardous waste Solid waste

from the filters used for air quality control is also in this category These wastes can

usually be tested and then delisted which means that it can be placed in a general

purpose landfill

Hazardous effluent from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-

site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored

and removed on a monthly basis is limited to 10 m3

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-4

A number of substances classified as hazardous are used in the galvanizing process

(Table 2) and the transport and handling of these is subject to certain rules and

guidelines In particular the material safety data sheets (cf Appendix H) should be

referred to for inter alia hazards identification accidental release measures

handling and storage precautions exposure controlpersonal protection ecological

information and transport information The Hazardous Chemical Substances

Regulations 1995 should also be adhered to in respect of the transport and storage

of hazardous chemical substances

Table 2 Hazardous materials to be used on site

Major Input Materials

Substance

listed in the

SABS 0228

Group II

hazardous

substances

Volumes to be

stored on site at

any one time

Diesel radic 2000 litres

Liquid petroleum radic 20 000 liters

Sodium hydroxide (NaOH)

(used for degreasing) 8 radic 1000m

3

Hydrochloric acid (HCI)

(used for pickling) 8 radic 800m

3

Zinc (used for galvanising) - TBD

Trivalent chromium (CR+3

)

(used for chromating) 8 radic 10m

3

Sulphuric acid (H2SO4) (used for

treatment of waste water on site) 8 radic TBD

Ammonium Hydroxide (NH4OH) 8 radic TBD

TBD ndash To be determined

Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one

time) and is classified as a flammable substance Specification for flammable storage

facilities in accordance with the requirements of the Nelson Mandela Bay

Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for

quantities between 5000 and 20 000 liters the substance must be kept in a

flammable liquid store which complies with the requirements of a specification

obtainable from the Department Some of the requirements are

Flammable liquid and solid storage facilities are only permitted on the ground

floor

Decanting of flammable liquids and solids are not permitted within any building

Due to the fact that there are flammable materials on site a certificate may be

required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and

Emergency Services Department to confirm that facilities for flammable storage

are in accordance with their requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-5

Because of the permanent installation and high quantity of liquid petroleum on site

the Major Hazard Installation Regulations 2001 promulgated under the Occupational

Health and Safety Act No 85 of 1993 applies A written application for approval of

the installation is required to be submitted to the chief inspector Department of

Labour provincial director Department of Labour and NMBM prior to construction

In addition a risk assessment should be formulated covering all hazardous materials

together with an emergency preparedness and response plan

56 HEALTH AND SAFETY

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling instructions as well as occupational exposure limits

are indicated in the material safety data sheets of the various substances used

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as

provide site supervision including executing tests (individual test cold run and hot

run) during 3 months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the

EMP

In addition the emergency preparedness and response plan will cover the health and

safety aspects related to emergency situations

57 TRAFFIC

The volumes of traffic at the IDZ are currently relatively low and variable depending

on the different zones in the IDZ however these volumes will increase as more

developments are implemented

The construction phase of the Casa Steel development will take about 12 months

and will essentially consist of erecting a building to house the galvanizing line and

other equipment and preparing a concrete laydown area adjacent to the building

The traffic that would be generated during the construction phase can be expected to

be less than the traffic that would be generated by the Casa Steel development when

it is fully operational

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-6

In the operation phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and

from the Port of Ngqura

The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the

Casa Steel development would be off Ring Road 1 The other roads of significance

for the Casa Steel development are the N2 Neptune Road MR435 and MR450

Access to the port is given by Neptune Road Road Link NEP-03 has not yet been

built

Figure 8 Coega IDZ road network identification

(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-7

Figure 9 Coega IDZ road network

Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No

01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-8

The distribution of freight trips is fixed as the majority of trips will be made between

the Port of Ngqura and the Casa Steel site With regard to personnel trips there are

various points of origins (the surrounding residential areas) that could be used by

staff going to the Casa Steel site The distribution of personnel trips is based on

existing traffic count information and is shown in Figure 10

Figure 10 Trip distribution for freight and personnel trips

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The resultant expected Casa Steel traffic assignment is shown in Figure 11

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-9

Figure 11 Morning peak hour Casa Steel development traffic

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The traffic that is expected to be generated by the Casa Steel development is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low

and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)

Consultation has taken place with Transnet Port Authority (TPA) to establish the

impact of the galvanizing plant operations on traffic inside the port The additional

ships entering and exiting the port of Ngqura as a result of the proposed development

will have a negligible impact on port traffic and TPA indicated that it would be well

within the portrsquos capacity

58 NOISE

Noise is not foreseen to be a significant issue insofar as the noise levels inside the

plant and at the boundary of the site will not exceed the limits prescribed by the CDC

Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels

during the day and 60 decibels at night

Mitigation of noise impacts will be addressed in the design of the noise-emitting

components of the plant and their enclosures

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-10

59 SOCIO-ECONOMIC ASPECTS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of

NMBM There are no residents within the IDZ

The direct socio-economic impacts of the proposed project are thus limited to the

employment generated by the project during construction and operation Job creation

remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)

and the IDZ and Port of Ngqura are expected to become a significant catalyst to the

economic growth of the Municipality and the region with current investments at

Coega creating more jobs and stimulating the economy

In this context the proposed galvanizing plant will make a positive contribution

towards the achievement of these goals

There will be 50 to 60 employees during operation phase distributed as follows

Figure 12 Casa Steel organisation chart

Even though a large part of the inputs will be imported and the bulk of the production

output will be exported there will be some positive impacts for the economy of the

region and of South Africa in general Notably the requirements of the plant for

water electricity waste collection and disposal waste water treatment and transport

for example will create business for the various service providers and have an

indirect impact on employment and fiscal revenues as a result

From a visual impact point of view it can be anticipated that the landscape in the IDZ

will be significantly affected over time by developments related to the establishment

of the port and various industries

HEAD ( WORKS )

MGR ( COMM) MGR ( ADMNHR ) Manager marketing

MANAGER OPERATION MANAGER MANAGER MANAGER Q C

AC FIN PUR ampSTORE

PPC SH-GALV SH-tech

SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF

1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO

JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF

2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO

WORKERS WORKERS 7NOS

15 7

RAW MAT amp

DESP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 6-1

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY

A description of the nature of the impact any specific legal requirements and the

stage (constructiondecommissioning or operation) will be given Impacts are

considered to be the same during construction and decommissioning The

significance of the potential impacts will be considered before and after identified

mitigation is implemented

The following criteria will be used to evaluate significance

Nature The nature of the impact will be classified as positive or negative and

direct or indirect

Extent and location Magnitude of the impact and is classified as

Local the impacted area is only at the site ndash the actual extent of the activity

Regional the impacted area extends to the surrounding immediate and

neighbouring properties

National the impact can be considered to be of national importance

Duration This measures the lifetime of the impact and is classified as

o Short term the impact will be for 0 ndash 3 years or only last for the period of

construction

o Medium term three to ten years

o Long term longer than 10 years or the impact will continue for the entire

operational lifetime of the project

o Permanent this applies to the impact that will remain after the operational

lifetime of the project

Intensity This is the degree to which the project affects or changes the

environment and is classified as

o Low the change is slight and often not noticeable and the natural functioning

of the environment is not affected

o Medium The environment is remarkably altered but still functions in a

modified way

o High Functioning of the affected environment is disturbed and can cease

Probability This is the likelihood or the chances that the impact will occur and

is classified as

o Low during the normal operation of the project no impacts are expected

o Medium the impact is likely to occur if extra care is not taken to mitigate

them

o High the environment will be affected irrespectively in some cases such

impact can be reduced

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 6-2

Confidence This is the level knowledgeinformation the environmental impact

practitioner or a specialist had in hisher judgement and is rated as

o Low the judgement is based on intuition and not on knowledge or

information

o Medium common sense and general knowledge informs the decision

o High Scientific and or proven information has been used to give such a

judgment

Significance Based on the above criteria the significance of issues will be

determined This is the importance of the impact in terms of physical extent and

time scale and is rated as

o Low the impacts are less important

o Medium the impacts are important and require attention mitigation is

required to reduce the negative impacts

o High the impacts are of great importance Mitigation is therefore crucial

Cumulative Impacts The possible cumulative impacts will also be considered

Mitigation Mitigation for significant issues is incorporated into the EMP for

construction

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 7-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS

71 IMPACTS DURING CONSTRUCTION

711 Air quality

Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris

handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine

particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural

operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks

and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)

Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Fugitive particulate emissions (dust)

related to construction activities Regional

Short

term Medium High High Medium Regional

Short

term Low High High Low

Construction vehicle gas emissions Regional Short

term Medium High High Medium Regional

Short

term Low High High Low

712 Heritage and archaeological resources

Naturedescription of impact excavation activities may impact on unidentified heritage resources

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-2

Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based

on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments

Heritage and archaeological

resources Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on unidentified heritage

resources Local

Short

term

Medium -

high Low High Low

713 Biodiversity and conservation

Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation

importance and cause soil contamination

Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species

Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan

and has compiled a list of protected species to be rescued (see draft EMP)

Biodiversity and conservation Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Loss of fauna and flora Local Perma

nent

Medium -

high High High High Local

Permanen

t Medium High High Medium

Soil contamination Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-3

714 Water related impacts

Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater

runoff spills and leaks Soil erosion

Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of

spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste

disposal Stormwater quality monitoring (see draft EMP)

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Soil erosion Local Short

term Medium Medium High Medium Local

Short

term Medium Low High Low

715 Waste management

Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed

Commentmitigation see draft EMP and waste management plan

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-4

Waste management Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Local

Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

716 Health and safety

Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Short

term

Medium -

high

Medium -

high High High Local

Short

term

Medium -

high Low High Low

717 Traffic

Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and

construction workers from surrounding areas and transport of equipment from the port

Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low

Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and

accurate estimates of quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-5

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Increased traffic on N2 and within the

IDZ Regional

Short

term Low High High Low

718 Noise

Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Short

term

Medium-

high High High Medium Local

Short

term Medium High High Medium

719 Socio-economic

Naturedescription of impact temporary employment will be created during the construction phase

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-6

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Temporary employment Regional Short

term Medium High High Medium

72 IMPACTS DURING OPERATION

721 Air quality

NatureDescription of impact gas and particulate emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning

Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local

sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and

veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute

to background fine particulate concentrations (von Gruenewaldt 2011b)

Assumptions and limitations Potential release of CR6+

As no emission factors are available for trivalent chromium processing the

potential impacts due to these activities could not be quantified

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Dust emitted from traffic on paved roads Regional Long Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-7

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

term

Hydrogen chloride emissions from

pickling process Local

Long

term Low High High Low

Particulate emissions (smoke) from

galvanizing process (due to the

volatilization of flux)

Local Long

term Low High High Low

Particulate oxides of nitrogen carbon

monoxide and sulphur dioxide emissions

from LNG burner

Local Long

term Low High High Low

Nuisance related to odour Local Long

term Low Low High Low

Abnormally high hydrogen chloride and

particulate emissions due to scrubber

malfunction

Local Short

term Medium Low High Medium

Gases (eg SOx NOx CO etc) and

smoke emitted in case of a fire Local

Short

term High Low High Medium

722 Water quality

NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks

Commentmitigation see draft EMP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-8

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Stormwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

723 Waste management and hazardous substances

NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous

waste both can affect environmental quality and human health

Commentmitigation see draft EMP and waste management plan

Waste management and hazardous

substances Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Regional

Long

term High

Medium -

high High High Regional Long term High Low High Low

Soilwaterair pollution due to improper

transport storage and handling of

hazardous substances

Regional Long

term High

Medium -

high High High Regional Long term High Low High Low

Health hazard Local Long

term High

Medium -

high High High Local Long term High Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-9

724 Health and safety

Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Long

term

Medium-

high

Medium-

high High High Local Long term

Medium-

high Low High Low

725 Traffic

Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on

the road network

Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak

hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road

network within Zone 6 of the IDZ (Iliso 2011)

Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)

Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of

quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-10

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on traffic and capacity of the N2 Regional Long

term Low High High Low

Impact on traffic and capacity of ring

road 1 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR435 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR450 Local

Long

term Low High High Low

Impact on traffic and capacity of

Neptune road Local

Long

term Low High High Low

726 Noise

Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Long

term Medium High High Medium Local Long term Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-11

727 Socio-economic

Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate

revenue for the municipality and the region as a whole

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Employment and economic growth Regional Short

term Medium High High Medium

73 COMPARATIVE ASSESSMENT OF IMPACTS

During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as

low during operation after mitigation

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 8-1

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

As a tenant operating in the IDZ Casa Steel will be required to comply with all

current and future CDC requirements as well as with the relevant conditions of

permits licences issued to CDC (eg Integrated Stormwater Masterplan for the

eastern side of the Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)

In particular the CDC has its own requirements regarding the monitoring of certain

aspects of the project such as the quality of the effluent and the noise levels These

have been incorporated into the EMP

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 9-1

9 ENVIRONMENTAL IMPACT STATEMENT

All predicted negative impacts can be mitigated to a low significance The only

exceptions are biodiversity as the construction of the plant will result in the

destruction of habitat and loss of fauna and flora and noise impacts inherent to

construction activities Mitigation measures have been included in the EMP for these

impacts and they have a medium significance post-mitigation

Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium to

long term similar impacts are likely to occur due to ongoing developments in the IDZ

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 10-1

10 CONCLUSION AND RECOMMENDATIONS

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as

other infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified

and assessed No fatal flaws have been identified

It is recommended that the project be approved subject to the conditions listed in

chapter 9 and adherence to the EMP requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 11-1

11 REFERENCES

Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ

Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants

Bennie JS (2010) The historical component (built environment) of the Heritage

Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port

Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report

compiled for Eastern Cape Heritage Consultants

Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater

Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay

Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage

Consultants

BKS (2006) Coega Industrial Development Zone Transport Study Volume 3

Demand Modelling Report Final Draft

Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I

Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6

Report compiled for SRK Consulting

Coastal amp Environmental Services (2010) Environmental Impact Assessment for the

Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone

Volume 3 Environmental Impact Assessment Report CES Grahamstown

Coega Development Corporation (2008) Industry Waste Management Plan -

Strategic Master Plan Report

Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants

Report No CDCSHE 03 8122

Department of Water Affairs and Forestry (1998) Waste Management Series

ldquoMinimum Requirements For The Handling Classification And Disposal Of

Hazardous Wasterdquo Second Edition

Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising

Plant in the Coega Industrial Development Zone

Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the

Coega Industrial Development Zone (IDZ) Specialist Water Study

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 11-2

Jacobs E (2008) Final Environmental Impact Report and Draft Environmental

Management Plan Proposed Steel Recycling and Processing Facility within the

Coega IDZ Report compiled for SRK Consulting

Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY

Galvanising Plant in the Coega Industrial Development Zone Waste Management

and Hazardous Substances Report compiled for ILISO Consulting

RSA National air quality standard for thoracic particulates (PM10) SA standards

(Government Gazette No 32816)

von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed

Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape

Report compiled for ILISO Consulting

von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel

Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report

compiled for ILISO Consulting

Additional sources

Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed

Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared

for Coastal Environmental Services

Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed

Kalagadi Manganese smelter in the Coega Industrial Development Zone Port

Elizabeth Eastern Cape Province Report prepared for Coastal Environmental

Services

Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia

steel recycling facility at the Coega Industrial Development Area Port Elizabeth

Prepared for SRK Consulting Port Elizabeth

APPENDIX A

LIST OF INTERESTED AND

AFFECTED PARTIES

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

DEDEARegional Manager

and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza

DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza

DEA Ocean and

CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza

DEA Ocean and

Coast

Oceanographer land-

based sources of

marine pollution

Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza

DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza

CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza

CDCEnvironmental

Project

Manager

Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza

TNPAPort of Ngqura

Environmental

Manager

Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet

NMBMEnvironmental

ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza

NMBMEnvironmental

ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza

DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza

DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza

WESSASenior Conservation

Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza

Zwartkops

ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700

hughlauegmailcom

zwartkopstrustiafricacom

SANParksNational Marine

CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza

Department Of

LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza

NMBM Air Quality

Division

Assistant

DirectorAir

Pollution and Noise

Templeton Titima 079 490 0574 Ttitimamandelametrogovza

NMBM Air Quality

DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza

NUMSARegional

RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

Department of

HealthNadiema

van der

Bergh083 378 2103

nadiemavanderberghimpiloecprovgov

za

DWA Chief Services

Officer

Joseph Jacobs 041 586 4884 jjacobsdwafgovza

EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza

NUMSecretary of union

officesZandile Xhentsa 043 743 6597 zxhentsanumorgza

DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza

Dynamic

CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom

EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza

Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza

UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom

lprincezago2uticom

Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza

Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza

Absa Mr Johann Steyn 082 3775820 johannstabsacoza

Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza

PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza

Universal

EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza

Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza

GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom

Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza

NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom

DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza

DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza

TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet

DWA Mr Landile Jack JackLdwagovza

DWA Ms Lizna Fourie FourieL4dwagovza

APPENDIX B

NOTICE OF ATMOSPHERIC

EMISSIONS LICENCE APPLICATION

AND ADVERTISEMENT

APPENDIX C

NOTICE OF COMMENT PERIOD FOR

DRAFT SCOPING REPORT

APPENDIX D

SUMMARY OF ISSUES RAISED AND

RESPONSES THERETO

April 2012

1

PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL

DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))

IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt

AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt

This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses

provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process

conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the

Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

2

IssueCommentQuestion Date

received Origin Response

1 Please provide more information with respect to the potential

dangers including the toxicity of the proposed project

07032011

By email

Wayne Poulton

(Bosun Brick

tenant at the

IDZ)

An Environmental Impact Assessment (EIA) was undertaken

which assessed the potential toxicity of the emissions and

effluent Mitigation measures were also recommended in the draft

Environmental Management Programme (EMP) to avoid

minimise or compensate any significant impacts The Draft

Environmental Impact Report and draft EMP were made available

to stakeholders for comment in March 2012

2 Do you have a Background Information Document (BID) or

similar that provides more information on the project

27032011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The BID was sent to all registered IampAPs on 4 May 2011

3 The RoD issued to the CDC on 632007 for the change in

land use for the remaining area of the Coega IDZ includes a

number of requirements with respect to

atmospheric emissions that should be considered in the

Atmospheric Emissions Licence (AEL) application such as

prohibiting and monitoring where possible visible emission

plumes to the atmosphere In particular the

recommendations on pp87-91 of the final revised Scoping

Report dated Nov 2006 must be implemented (clause 421)

04042011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

We have obtained copies of the documents referred to and ensure

that these requirements were taken into account in the

environmental assessment and AEL application

4 If the Port of Ngqura is used for import and export the scope

of the traffic impact assessment (TIA) should also include the

port

10052011

By email

Elliot

Motsoahole

(TNPA Port of

Ngqura)

The scope of the TIA was extended to include port related traffic

The TNPA at the Port of Ngqura was consulted and does not

have any objection to the project TNPA has indicated that the

development would require a minimum number of vessels per

year which would have minimal impact on the Port operations

However due notice would have to be given to the Port of Ngqura

before a vessel is scheduled to arrive so that the vessel can be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

3

IssueCommentQuestion Date

received Origin Response

accommodated at an available berth

5 Concerns with respect to potential stormwater pollution

draining into the Coega catchment and the port of Ngqura

The port needs to be dredged and heavy metals present a

risk in that regard

16052011

By

telephone

Andrew Lucas

(Department of

Water Affairs)

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination by effluent waste or

hazardousdangerous substances is very low

Thus no metals oils or other contaminants are expected to be

present in the stormwater

However stormwater pollution can occur in exceptional

circumstances such as accidents and emergencies The

emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

6 All steel sheets bathing unit must be under roof

7 The sludge out of the decreasing bath will be high in Na and

pH Therefore handling and disposal must be clarified up front

in this project

8 Per se the wastewater from decreasing bath will have high

ph and the component from the pickling unit will have low ph

Then it may be assumed that both streams will neutralize

each other Please then clarify proposed sewer discharge

with Nelson Mandela Bay Municipality up-front for acceptance

of influent as per the documented proposal

9 Pickling may result in dissolved metals How does your team

expect to deal with this As it is planned for discharge into

24052011

By email

Landile Jack

(Department of

Water Affairs)

All bathing units will be under roof

Effluent from the degreasing and pickling baths will be discharged

to the wastewater treatment plant The respectively alkaline and

acidic effluents will mix and neutralise each other in the

wastewater treatment plant Calcium or gypsum will be added if

required to complete the neutralisation process Effluent from the

treatment plant will be discharged to sewer Contact has been

made with the relevant officials and the Municipalityrsquos

requirements have been obtained The effluent discharged to

sewer will notably comply with the applicable discharge standards

Traces of metals (eg iron) may be present but will not exceed

prescribed thresholds The necessary authorisation will be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

4

IssueCommentQuestion Date

received Origin Response

sewer Clarity and acceptance needs to be agreed with

Nelson Mandela Bay Municipality Who owns the sewer

10 Quenching unit will results to Zinc particles How will this

affect sewer discharge This again must be dealt with within

the negotiations with the Municipality

11 Once all has been agreed with the Municipality and at the

same time due negotiations must be done with hazardous

waste courier and disposal facility to accept the hazardous

waste identified in all production lines

12 Of note is the low volume of the proposed WWTW facility ie

250 cubmweek And the no discharge of the quenching

water ie over-flow and cooling only Hence Zinc particles

generation

obtained from the municipality

The sludge from the treatment plant will be collected by a licensed

service provider and disposed of at a permitted site

The quenching bath will be periodically emptied (every 6 months)

and the water discharged will go to the water treatment plant Zinc

particles will settle in the sludge which will be disposed of at a

permitted site

Contact has been made with EnviroServ who manages the

Aloes II HH waste site regarding collection and disposal of

hazardous waste (See waste management report)

13 Investigate the potential effects of toxicity andor influence of

emissions waste and hazardous substances both in

terrestrial and marine fauna

14 With regards to water usage where is the plant going to

extract its waters used in galvanization andor waste

management process ie rainfall rivers or even from the

sea) and which avenues would be more environmental

friendly and effective

31052011

By email

A Bewana

(SANPARKS)

Emissions waste and hazardous substances are not expected to

affect terrestrial or marine ecosystems The air quality study

concluded that atmospheric emissions would not be harmful to

human health and by extension terrestrial fauna There are no

standards for air quality for defining faunal impacts therefore by

ensuring that standards for humans are complied with the impact

on fauna is deemed to be acceptable In this case the impact of

emissions on terrestrial and marine fauna are thus not significant

Solid and liquid wastes both general and hazardous as well as

hazardous substances will be stored handled and disposed of

appropriately to as not to cause harm to terrestrial or marine

fauna

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

5

IssueCommentQuestion Date

received Origin Response

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination and hence land-based

marine pollution by effluent waste or hazardousdangerous

substances is very low

The risk of emissions waste and hazardous substances to

terrestrial and marine fauna is thus very low

However pollution of terrestrial and marine ecosystems can occur

in exceptional circumstances such as accidents and emergencies

The emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

The CDC has an agreement with the NMBM to supply potable

water to the Coega IDZ Currently the infrastructure to supply

return effluent (RE) to the IDZ is not in place therefore Casa Steel

will be supplied with potable water up until such time as the

following 2 options of RE are available

1) Upgrading of the existing Fishwater Flats waste water

treatment works (between IDZ amp PE) including RE plant

and infrastructure to pipe RE to the IDZ (EIA for the

upgrade is underway)

2) Construction of a new waste water treatment works

including RE plant in Zone 9 of the Coega IDZ

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option should be investigated further between Agni and Casa The

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

6

IssueCommentQuestion Date

received Origin Response

CDC can facilitate discussions between the 2 investors

Compliance with CDC Permits amp Requirements

15 It should be made clear that tenants will be required to

comply with CDC requirements and the relevant conditions of

permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water

Licence for its Storm Water Systems on the

East Side of the Coega River that tenants will

need to take cognizance of The contents of the

ldquoIntegrated Stormwater Masterplan for the

eastern side of the Coega IDZ Oct 2010rdquo

especially the Table of best practice p53

onwards may need to be taken cognizance of

o CDC is developing an Operations

Environmental Management Plan that will place

certain obligations on tenants

16 Environmental audits and data collected during monitoring

(eg stack emissions stormwater) will need to be shared with

CDC

Air Emissions

17 Presumably permanent in stack monitoring will be required in

terms of AEL permit requirements

18 Abnormal operating conditions resulting in air emissions ndash I

could find nothing in the EIR to indicate under what

circumstances these could occur (eg start-up) potential

frequency and duration and the impact on ambient air quality

ndash these events usually result in the most problems wrt air

emissions

09042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

15 Compliance with the CDCrsquos Permits amp Requirements has

been included explicitly as a requirement in the EIR (p8-1) and

EMP (pp18 and 25) in the following terms

ldquoAs a tenant operating in the IDZ Casa Steel will be required to

comply with all current and future CDC requirements as well as

with the relevant conditions of permits licences issued to CDC

(eg Integrated Stormwater Masterplan for the eastern side of the

Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)rdquo

16 The need to communicate with the CDC on monitoring and

auditing activities was emphasised in Chapter 8 of the EMP The

following paragraphs were added

ldquoDuring construction the environmental officer will be responsible

for monitoring compliance with the EMP and authorisation

conditions and keeping records as required in the EMP andor

authorisation conditions

The ECO will conduct site inspections every two weeks audit the

records kept by the environmental officer and submit an

environmental compliance report every two months to the

authorities and the CDC (via the Environmental Monitoring

Committeersquos ECO)

During operation the health and safety officer will monitor

compliance with the EMP and the conditions of the Environmental

Authorisation Data collected during monitoring activities and any

environmental audits conducted will be shared with authorities

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

7

IssueCommentQuestion Date

received Origin Response

Water

19 Large volumes of (2000 m3mth) of water are required of

which only 400m3 needs to be potable The NMBM return

effluent system will provide non-potable water once it is

constructed What other water recycling initiatives can be

utilized to reduce potable water requirements (the ISWMP for

the eastern side of the Coega IDZ has some best practice

guidelines collecting rainwater from the roof etc)

General

20 There is no mention of how the CDC Architectural Guidelines

will be incorporated into the development (eg to prevent a

stark uniform warehouse type development)

21 Does NMBM have adequate fire services to cover this

development Apart from the large petroleum store are there

any other large fire hazards

22 Reports from the tenantrsquos ECO during construction and from

the SHE Officer during operations should be channeled to the

Coega Environmental Monitoring Committee This can be

directly or preferably via the EMCrsquos ECO (this will be while

the EMC and ECO are in place) A precedent has been set

for this in the Environmental Authorisations for Agni-Steel and

Kalagadi Manganese Smelter

23 All mitigation actions emanating from the EIR should be

summarized (preferably in a table) If compliance with them is

to be part of the Environmental Authorization from DEDEAT

then they (or the ones that DEDEAT deems to be applicable)

and the CDC (via the Environmental Monitoring Committeersquos

ECO)

The ECO (during construction) and the health and safety officer

(during operation) will report to the Coega Environmental

Monitoring Committee (EMC) via the EMCrsquos ECO (this will be

while the EMC and ECO are in place)rdquo

17 The draft EMP recommends regular monitoring of emissions

from the scrubbers and from the chromating process Additional

emissions monitoring requirements will be confirmed once the

AEL is issued Mention has been made in the EMP (pp11 and 19)

that all AEL conditions including monitoring and reporting

requirements should be adhered to

18 Abnormal emissions can occur in exceptional circumstances

Start-up will not cause abnormal emissions as the scrubbers

will be commissioned first and will be functioning once the plant

starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions

would be emitted as a building fugitive

The hourly hydrogen chloride ground level concentrations

(directly offsite) were predicted to be 239 microgmsup3 (based on the

emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits

as stipulated for listed activities for galvanising processes) using a

screen model which assumes worst case meteorological

conditions The health effect screening level for hourly HCl

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

8

IssueCommentQuestion Date

received Origin Response

should be attached to the EA as an Appendix (otherwise no

one knows about them or takes cognizance of them)

concentrations is 2100 microgmsup3 Assuming abnormal emissions

emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset

conditions will still be well within the health effect screening

levels

Similarly the hourly particulate emissions from the building

fugitives during upset conditions would amount to 293 microgmsup3

(based on the emission limits as stipulated for listed activities for

galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1

January 2015) directly off-site

Therefore if emissions are 5 times higher normal they will still be

within health effect screening levels and the daily PM10 NAAQS

levels

In the case of a fire a cocktail of gases and particulates could be

emitted and could be over the recommended levels This

situation will however be dealt with as an emergency and

normalised as quickly as is possible

The above has been added to the impact identificationdescription

and assessment sections of the EIR

19 The CDC has an agreement with the NMBM to supply

potable water to the Coega IDZ Currently the infrastructure to

supply return effluent to the IDZ is not in place therefore Casa

Steel will be supplied with potable water up until such time as the

infrastructure is in place

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

9

IssueCommentQuestion Date

received Origin Response

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option will be investigated further between Agni and Casa The

CDC has come forward to facilitate discussions between the two

investors

Other water recycling initiatives such as rainwater harvesting

have been considered but are not practical

20 The CDCrsquos Architectural and Landscape Design guidelines

contain requirements pertaining to such aspects as the height

orientation and mass and form of buildings as well as guidelines

for landscaping and signage in order to ensure an attractive

development and achieve an architectural integrity within the

Coega IDZ The plans for the proposed galvanizing plant will be

submitted to the Design Review Committee for approval as

required by the CDC

21 Casa Steel will be required to install fire hydrants according

to the NMBMrsquos standardsrequirements The CDC will provide

potable water (up until such time as return effluent is available)

and a connection to the boundary of the site which will be

connected to the fire hydrants The installation of the fire hydrants

will require approval by the Metrorsquos Fire Chief as was done for

Agni-Steel one of the investors in Zone 6

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

10

IssueCommentQuestion Date

received Origin Response

The Coega IDZ falls within the NMBM and therefore the rates and

taxes paid by the CDC covers the fire services for which the Metro

is responsible Currently the Metro has sufficient capacity to

provide fire services to the tenants within the IDZ This was

confirmed in discussion with the CDCrsquos Infrastructure

Development Unit It is however unknown at which point the

Metrorsquos Disaster Management Plan would not be able to

accommodate servicing tenants in the IDZ

The LNG burner is the only major fire hazard on the plant

22 See response to item 16 above

23 Key mitigation and management measures emanating from

the EIR were recapitulated in Chapter 9 of the EIR to form part of

the conditions attached to the Environmental Authorization from

DEDEAT All mitigation measures recommended as a result of the

impact assessment are presented in a table in the draft EMP

which is appended to the EIR (Appendix J)

24 Hydrogen chloride is one of the main emissions There are no

ambient air quality guidelines for HCl and the EIR says

concentrations will be well within health parameters

However the main problem with HCl is its corrosive effect -

there is absolutely no mention of this in the draft EIR nor air

specialist report

There needs to be some sort of comment assessment as to

whether HCl emissions are likely to impact on for example

the adjacent Agni-Steel Plant wrt corrosion - their factory

structure will be made of steel

11042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The atmospheric corrosion of metals is a complex process with

both the extent of deterioration and the mechanisms varying

considerably depending on the metal Depending on the way

pollutants are transported from the atmosphere to the corroding

surface two types of deposition processes are recognized in

atmospheric corrosion ndash dry deposition and wet deposition Wet

deposition refers to precipitation whereas dry deposition refers to

the remaining processes including gas phase deposition and

particle deposition The most important pollutants acting as

corrosive agents are sulphur and nitrogen compounds including

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

11

IssueCommentQuestion Date

received Origin Response

The EIR specialist rpt suggests monitoring HCl at ground

level on the property boundary and this is supported in case

there are complaints from neighbours

secondary pollutants and particulates Pollutants can contribute to

corrosivity individually however there may be a synergistic effect

when more than one of these pollutants is present in the

environment being affected In the field of atmospheric corrosion

sulphur dioxide is the single most investigated gaseous pollutant

and the quantification of the direct contribution of sulphur dioxide

to the corrosion process of metallic materials is comparatively well

understood (Tidblad amp Kucera 1998)

Very little work has reported on the effect of HCl on the

degradation of materials in the environment with no local dose-

response thresholds developed for corrosion occurring due to HCl

exposures This is probably because HCl which is present

outdoors in markedly reduced concentrations when compared

with SO2 has not been considered to contribute to significant

degradation of materials (Syed 2006) For this reason the

incremental corrosion due to HCl from the Coega Galvanising

Plant cannot be quantified

25 It is unacceptable for ILISO to be using CDC maps (see

figure 9 ndash pg5-6) without these maps being referenced

accordingly particularly when it appears that a CDC map has

been used and then overlaid with features by an unknown

author (ie CASA steel site Port (where the boundaries

depicted are incorrect) and a North legend which is out of

keeping with the overall cartographic intent of the original

work

26 Figure 10 is not referenced appropriately and I believe that I

commented previously in respect to references to roads not

12042012

By email

Graham Taylor

(Spatial

Development

Manager -

Infrastructure

Development

CDC)

This has been rectified in the final version of the report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

12

IssueCommentQuestion Date

received Origin Response

yet built As a result Figure 10 is confusing and clarity needs

to be provided in terms of referencing In addition the Port

shape is irregular and similar to the comment above

27 I acknowledge the emergency preparedness and response

plan but please confirm that this includes pro-active routine

monitoring of storm water leaving your premises to verify that

your assumptions of clean storm water are correct

13042012

By post

Andrew Lucas

(Director

WRampU

Department of

Water Affairs)

Pro-active routine monitoring of stormwater leaving the premises

will be undertaken This has been explicitly emphasised in

chapter 8 of the draft EMP

28 Will portablechemical toilets be used during construction

29 What provisions have been made for storm water drainage

during construction

18042012

By

telephone

Department of

Water Affairs

Port Elizabeth

Chemical toilets will be used during construction

The Casa Steel site will be located at the corner of two roads

drainage of stormwater from the site will take place through the

roadsrsquo drainage system

From Lea September [mailtoleailisocom]

Sent 11 March 2011 0935 AM

To Wayne Poulton

Cc Terry Baker

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Wayne

An Environmental Impact Assessment (EIA) will be undertaken for this project during the

next 10 to 12 months

We foresee that some of the key environmental impacts of the project will be in terms of air

quality water quality waste and hazardous substances

At this stage I am not able to give you any details regarding the potential toxicity of the

emissions andor effluent However specialist studies will be conducted as part of the EIA

that will determine the key impacts of the project Mitigation measures will also be identified

to avoid minimise or compensate any significant impacts

You are registered on the stakeholder database and you will be kept informed of progress in

the EIA process you will notably get the opportunity to access the reports produced and

provide any feedback on them

Please feel free to contact me should you need any further information

Best regards

Lea September

From Wayne Poulton [mailtowaynepbosuncoza]

Sent 07 March 2011 1257 PM

To Lea September

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

Please can you provide me with some more information as to the potential dangers including

the toxicity of this

Kind regards

Wayne

From Lea September [mailtoleailisocom]

Sent 04 March 2011 1123

To Lea September

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 March 2011 0745 AM

To Paul Martin

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 05 April 2011 0847 AM

To Paul Martin

Cc Terry Baker Renee von Gruenewaldt

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Thank you Paul for this information

I have downloaded a copy of the RoD and Scoping report you referred to and will make sure

these requirements are taken into account in the environmental assessment

Best regards

Lea September

From Paul Martin [mailtopmartinaxxesscoza]

Sent 04 April 2011 0955 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Further to my comments on 27311

Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in

the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega

IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised

scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions

including prohibiting and monitoring where possible visible emission plumes to the atmosphere

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Paul Martin

Sent Monday March 28 2011 745 AM

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 10 May 2011 0327 PM

To ElliotMotsoaholetransnetnet

Cc Terry Baker

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Mr Motsoahole

Thank you for your input on this issue

The Port of Ngqura will indeed be used for import and export At the moment the scope of

the traffic impact assessment only covers road traffic I have however relayed the matter to

our traffic specialist and we will consider this issue in the finalization of the Scoping Report I

will keep you informed of any developments in that regard

I trust this is acceptable to you

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]

Sent 10 May 2011 0855 AM

To Lea September

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

It has been noted that Casa Steel will source steel coils from various markets internationally and

in South Africa and the bulk of the plantrsquos production output will be exported to African countries

However there is no mention of logistic requirements

Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will

be used the scope of traffic impact assessment should also include the port

Regards

From Lea September [mailtoleailisocom]

Sent 04 May 2011 0747 AM

To Lea September

Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

Please find attached a letter announcing the EIA process underway for the proposed 80 000

tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as

a Background Information Document (BID) outlining the details of the project

Please contact me should you require any further information on this project

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

Elliot Motsoahole

Manager - Environment

Transnet National Ports Authority

Port of Nqqura

Port Control Building Klub Road Port Elizabeth 6212

PO Box 612054 Bluewater Bay 6212

+27 41 507 8450

+27 86 674 7729

Cell +27 83 542 5619

E-mail Elliotmotsoaholetransnetnet

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

DISCLAIMER The information contained in this communication is subject to copyright and

intended only for the use of leailisocom Unauthorised use disclosure or copying is

strictly prohibited Should a virus infection occur as a result of this communication the sender

will not be liable If you have received this communication in error please notify

elliotmotsoaholetransnetnet

From Lea September [mailtoleailisocom]

Sent 25 May 2011 1147 AM

To Jack Landile (ELS)

Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi

Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Landile

Thank you for your input

Contact has been made with the relevant Municipal Directorate and we will follow up with

them to obtain clarifications on all these issues

I have added both Lizna and yourself on the database and will keep you updated on

progress on this project

Best regards

Lea September

From Jack Landile (ELS) [mailtoJackLdwagovza]

Sent 24 May 2011 0524 PM

To Fourie Lizna (ELS)

Cc Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Hi Lizna

I missed you on this sorry

I linked Pieter twice Instead

Regards

Landile

From Jack Landile (ELS)

Sent 24 May 2011 0445 PM

To leailisocom

Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Lea

The e-mail you sent to Mr Kooverji dated 19 May 2011 refer

Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are

All steel sheets bathing unit must be under roof

The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project

Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal

Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer

Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality

Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines

Of note is the low volume of the proposed WWTW facility ie 250 cubmweek

And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles

generation

Regards

Landile

From Lea September [mailtoleailisocom]

Sent 19 May 2011 0947 AM

To Lea September

Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Stakeholder

Please find attached the remaining appendices to the draft Scoping report for the proposed

80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 June 2011 0411 PM

To Aphiwe Bewana

Subject RE Proposed 80 000 TPY Galvanizing plant in Coega

Dear Mr Bewana

Thank you for your input and apologies for the late reply

We have taken note of your comments and are will be taking them forward in the EIA phase

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Aphiwe Bewana [mailtoaphiwebewanagmailcom]

Sent 31 May 2011 1205 PM

To Lea September

Subject Re Proposed 80 000 TPY Galvanizing plant in Coega

Comment

Re Proposed 80 000 TPY Galvanizing plant in Coega

As SANParks we would like the EIA phase to investigate the potential effects of toxicity

andor influence of emissions waste and hazardous substances both in terrestrial and

marine fauna In the draft scoping report reference has been made with regards to the

terrestrial fauna but there is no attention to potential effects to marine fauna

Equally with regards to water usage where is the plant going to extract its waters used in

galvanization andor waste management process ie rainfall rivers or even from the sea)

and which avenues would be more environmental friendly and effective

Regards

Aphiwe Bewana

Marine Planner

South African National Parks

POBox 76693

NMMU

Port Elizabeth

6031

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 06 July 2011 1031 AM

To Lea September

Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Hi Lea

Irsquove reviewed the Final Scoping Report Herewith a few comments

1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the

Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a

revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the

NMBLP Please include only those in the IDZ as part of your IAP list

Regards

Andrea

From Lea September [mailtoleailisocom]

Sent Wednesday July 06 2011 859 AM

To Lea Septemberrsquo

Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Dear Stakeholder

The final scoping report for the above-mentioned project (attached) is available for comment

until 27 July 2011

The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic

commentaryrdquo tab

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 09 April 2012 1159 AM

To Lea September

Subject Comments on Galvanising Plant EIR Coega IDZ

Lea

Attached are my comments on the Draft EIR for the Coega IDZ galvanising

plant

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

Email attachment

COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ

Dr Paul Martin PO Box 61029

Bluewater Bay 6212 Tel 041 4665698

Email pmartinaxxesscoza

Compliance with CDC Permits amp Requirements

It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of

o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants

Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC

Air Emissions

Presumably permanent in stack monitoring will be required in terms of AEL permit requirements

Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions

Water

Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)

General

There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)

Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards

Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter

All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 11 April 2012 1245 PM

To Lea September

Subject Fw Comments on Galvanising Plant EIR Coega IDZ

Lea

One other comment on that I have on the Galvanising Plant Draft EIR

Hydrogen chloride is one of the main emissions There are no ambient air

quality guidelines for HCl and the EIR says concentrations will be well

within health parameters

However the main problem with HCl is its corrosive effect - there is

absolutely no mention of this in the draft EIR nor air specialist report

There needs to be some sort of comment assessment as to whether HCl

emissions are likely to impact on for example the adjacent Agni-Steel

Plant wrt corrosion - their factory structure will be made of steel

The EIR specialist rpt suggests monitoring HCl at ground level on the

property boundary and this is supported in case there are complaints from

neighbours

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Paul Martin ltpmartinaxxesscozagt

To Lea September ltleailisocomgt

Sent Monday April 09 2012 1158 AM

Subject Comments on Galvanising Plant EIR Coega IDZ

gt Lea

gt

gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising

gt plant

gt

gt

gt Dr Paul Martin

gt PO Box 61029

gt Bluewater Bay 6212

gt Tel 041 4665698

gt Cell 0732524111

gt email pmartinaxxesscoza

gt

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 12 April 2012 1139 AM

To Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Hi Lea

Hope yoursquore keeping well

I have requested comments from my colleagues and the CDC Casa team on the Draft EIR

Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report

Regards

Andrea

From Graham Taylor

Sent Thursday April 12 2012 838 AM

To Andrea Von Holdt Firhana Sam

Cc Johan Fourie Maria van Zyl Melikhaya Sihawu

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Andrea Firhana

Firhana if you could please ensure that the co-ordinates provided in the EIR correspond

with our records (pages 4-1 amp 4-2)

My comments are as follows

It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work

Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above

Regards

Graham Taylor

Spatial Development Manager - Infrastructure Development

Mobile 0832283055

Office 0414030454

Facsimile 0865185033

Email GrahamTaylorcoegacoza

Website wwwcoegacom

right PLACE | right TIME | right CHOICE

This email and all contents are subject to the following disclaimer

httpwwwcoegacomemaildisclaimerhtml

From Lea September [mailtoleailisocom]

Sent 04 May 2012 0411 PM

To Andrea Von Holdt

Cc Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Dear Andrea

We have taken note of the comments from the GIS Unit These issues have been rectified in

the final version of the EIR

Please can you forward to the relevant persons at the GIS Unit

Thank you

Best regards

Lea September

APPENDIX E

BACKGROUND INFORMATION

DOCUMENT

APPENDIX F

AIR QUALITY IMPACT ASSESSMENT

APPENDIX G

TRAFFIC IMPACT ASSESSMENT

APPENDIX H

WASTE MANAGEMENT AND HAZARDOUS

SUBSTANCES SPECIALIST STUDY

APPENDIX I

WATER QUALITY SPECIALIST STUDY

APPENDIX J

ENVIRONMENTAL MANAGEMENT

PROGRAMME

Page 4: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 ii

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS 5-2

53 BIODIVERSITY AND CONSERVATION 5-2

54 WATER QUALITY 5-2 55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES 5-3

56 HEALTH AND SAFETY 5-5

57 TRAFFIC 5-5

58 NOISE 5-9

59 SOCIO-ECONOMIC ASPECTS 5-10

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY 6-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS 7-1

71 IMPACTS DURING CONSTRUCTION 7-1

711 Air quality 7-1

712 Heritage and archaeological resources 7-1

713 Biodiversity and conservation 7-2

714 Water related impacts 7-3

715 Waste management 7-3

716 Health and safety 7-4

717 Traffic 7-4

718 Noise 7-5

719 Socio-economic 7-5

72 IMPACTS DURING OPERATION 7-6

721 Air quality 7-6

722 Water quality 7-7

723 Waste management and hazardous substances 7-8

724 Health and safety 7-9

725 Traffic 7-9

726 Noise 7-10

727 Socio-economic 7-11

73 COMPARATIVE ASSESSMENT OF IMPACTS 7-11

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME 8-1

9 ENVIRONMENTAL IMPACT STATEMENT 9-1

10 CONCLUSION AND RECOMMENDATIONS 10-1

11 REFERENCES 11-1

LIST OF FIGURES

Figure 1 Process flow diagram for proposed galvanizing plant 2-2

Figure 2 Continuous Galvanizing Line 2-3

Figure 3 Location of the proposed galvanizing plant 2-5

Figure 4 Zone layout in the Coega IDZ 4-1

Figure 5 Site location 4-2

Figure 6 Coega IDZ Open Space Management Plan (OSMP) 4-5

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble gravels

exposed by tracks in Zone 6 (Source Binneman 2010) 4-8

Figure 8 Coega IDZ road network layout (Adapted from BKS 2006) 5-6

Figure 9 Coega IDZ road network 5-7

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 iii

Figure 10 Trip distribution for freight and personnel trips 5-8

Figure 11 Morning peak hour Casa Steel development traffic 5-9

Figure 12 Casa Steel organisation chart 5-10

LIST OF TABLES

Table 1 Coordinates of site corners for the proposed galvanizing plant 4-1

Table 2 Hazardous materials to be used on site 5-4

APPENDICES

APPENDIX A List of registered stakeholders

APPENDIX B Notice of AEL application and advertisements

APPENDIX C Notice of comment period for draft scoping report

APPENDIX D Summary of issues raised and responses thereto

APPENDIX E Background Information Document

APPENDIX F Air Quality Impact Assessment

APPENDIX G Traffic Impact Assessment

APPENDIX H Waste Management and Hazardous Substances specialist study

APPENDIX I Water Quality Specialist Study

APPENDIX J Environmental Management Programme (EMP)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 iv

ACRONYMS

AEL Atmospheric Emissions Licence

BID Background Information Document

CCA Custom Controlled Area

CDC Coega Development Corporation

DEA Department of Environmental Affairs

DEDEAT Department of Economic Development Environmental Affairs and Tourism

DWA Department of Water Affairs

EAP Environmental Assessment Practitioner

EIA Environmental Impact Assessment

ELC Environmental Liaison Committee

EMP Environmental Management Programme

GN Government Notice

IampAPs Interested and Affected Parties

IDZ Industrial Development Zone

LNG Liquid natural gas

masl Meters above sea level

MSDS Material Safety Data sheet

NEMA National Environmental Management Act

NEMBA National Environment Management Biodiversity Act (No10 of 2004)

NMBM Nelson Mandela Bay Municipality

OSMP Open Space Management Plan

PoS Plan of Study

SAHRA South African Heritage Resources Agency

TNPA Transnet National Ports Authority

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 v

EXECUTIVE SUMMARY

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone

(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province

Galvanizing consists of coating steel with zinc in order to protect it from corrosion An

Environmental Impact Assessment (EIA) is required as the proposed project involves several

activities listed in terms of Section 24 of the National Environmental Management Act

(NEMA) 107 of 1998 as amended and requires an environmental authorisation The

project also involves activities listed in terms of the National Environmental Management Air

Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008

which respectively require an Atmospheric Emissions Licence and a Waste Management

Licence

The Scoping and Environmental Impact Assessment process underway covers all aspects of

the project and informs all three applications

Scoping was the first phase of investigations and aimed to inter alia identify potential key

environmental issues and impacts to be addressed in the EIA phase

The following environmental issues and potential impacts identified in the Scoping Phase

were investigated in the EIA

Air quality

The galvanizing process generates atmospheric emissions which are regulated in terms

of the National Environmental Management Air Quality Act and appropriate measures

are required in order to adhere to the applicable standards Other sources of impact on

air quality include emissions from the LNG burner emissions and dust from the transport

of steel and other materials in trucks as well as dust and gas emissions related to

construction activities Mitigation measures recommended in the EMP will ensure that air

quality impacts are kept to a minimum and compliance with emissions standards is

maintained

Biodiversity and conservation

Certain types of vegetation in the IDZ are of high conservation importance Protected

species will be rescued as per the CDCrsquos requirements

Water quality

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through spills

or leaks This risk can however be minimized if not avoided altogether through design

choices (bunded areas) and the adherence to best practice guidelines for the handling or

the transport of hazardous substances and waste

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vi

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

Waste management and hazardous substances

The plant will generate a relatively small amount of solid waste which will be re-used

recycled or disposed of in accordance with the EMP recommendations

There will be a wastewater treatment plant on site which will neutralise process water

(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer

Hazardous waste from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site

at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and

removed on a monthly basis is limited to 10 m3

A number of substances classified as hazardous are used in the galvanizing process and

the transport and handling of these is subject to certain rules and guidelines

In addition the permanent storage of a high quantity of liquid petroleum on site (20 000

litres at any one time) is subject to certain specifications and requires approval from the

municipality

Health and safety

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling of the various substances used will be done in

accordance with applicable instructions (cf material safety data sheets)

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as provide

site supervision including executing tests (individual test cold run and hot run) during 3

months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the EMP

Traffic

In the operational phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and from

the Port of Ngqura

The traffic expected to be generated during construction as well as operation is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low and

the total traffic generated by Casa Steel is also relatively low

The impact on port traffic is also negligible and well within the portrsquos capacity

Socio-economic aspects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vii

The proposed galvanizing plant will make a positive contribution by creating jobs during

construction and operation and generating business for the various service providers

Fatal flaws

No fatal flaws have been identified

The significance of these potential key environmental impacts were assessed in the EIA

phase and the findings of this phase of investigations are presented in this report

The main findings of the EIA are as follows

During construction impacts post-mitigation are low with the exception of noise and

biodiversity as the construction of the plant will result in the destruction of habitat

and loss of fauna and flora and noise impacts inherent to construction activities

Mitigation measures have been included in the EMP for these impacts and they have

a medium significance post-mitigation

All impacts were assessed as low during operation after mitigation

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium

to long term similar impacts are likely to occur due to ongoing developments in the

IDZ

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

The CDC has its own requirements regarding the monitoring of certain aspects of the

project such as the quality of the effluent and the noise levels These have been

incorporated into the EMP Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as other

infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified and

assessed No fatal flaws have been identified

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 viii

It is recommended that the project be approved subject to the conditions listed above

and adherence to the EMP recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-1

1 INTRODUCTION

11 BACKGROUND

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)

Nelson Mandela Bay Municipality Eastern Cape Province

The demand for galvanised steel products is high in South Africa and Africa and is

expected to increase in the foreseeable future From an economic point of view the

proposed project has therefore been found to be viable

Casa Steel will source the steel coils from various markets internationally and in

South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is

destined to be exported mainly to African countries

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

An Environmental Impact Assessment (EIA) is required as the proposed project

involves several activities listed in terms of Section 24 of the National Environmental

Management Act (NEMA) No 107 of 1998 as amended and requires an

environmental authorisation

The following listed activities requiring environmental authorisation have been

identified

Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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 metres

Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped

land to industrial use greater than 1 ha but less than 20 ha in size outside an

urban area

Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any

process or activity requiring a license in terms of national or provincial legislation

governing the generation or release of emissions

Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5

hectares or more of vegetation where 75 or more of the vegetative cover

constitutes indigenous vegetation except where such removal of vegetation is

required for

(i) purposes of agriculture or afforestation inside areas identified in

spatial instruments adopted by the competent authority for

agriculture or afforestation purposes

(ii) the undertaking of a process or activity included in the list of waste

management activities published in terms of section 19 of the

National Environmental Management Waste Act 2008 (Act No 59

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-2

of 2008) in which case the activity is regarded to be excluded from

this list

(iii) the undertaking of a linear activity falling below the thresholds in

Notice 544 of 2010

Hot dip galvanizing is a listed activity in terms of section 21 of the National

Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires

an Atmospheric Emissions Licence (AEL)

In addition the treatment of wastewater with an annual throughput capacity of more

than 2000 m3 is a listed activity in terms of the National Environmental Management

Waste Act 59 of 2008 and requires a waste management licence

ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental

Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact

Assessment process in terms of section 24 of NEMA for the construction and

operation of the proposed galvanizing plant The EIA process covers all aspects of

the project and informs all three applications (for environmental authorisation waste

management licence and AEL)

13 PURPOSE OF THIS REPORT

This report builds on the scoping report submitted to the Eastern Cape Department of

Economic Development and Environmental Affairs (DEDEA) and the Nelson

Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It

describes the proposed project and presents the findings of the second phase of

investigations (EIA phase)

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT

PRACTITIONER (EAP)

The EIA was managed by Ms Terry Baker a certified Environmental Assessment

Practitioner with 20 years of working experience She has a MA in Environmental

Management and specialises in Environmental Impact Assessments and Project

Management She has been involved in a variety of different types of EIAs including

for water supply projects dams transmission lines roads and airports in South

Africa Botswana Uganda Lesotho and Mozambique She has been involved in

water resource management and public participation programmes on a number of

projects Terry has also been involved in the use of Geographic Information Systems

environmental status quo reports water quality assessments socio-economic and

institutional development projects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-3

15 PROJECT TEAM

In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen

(water quality specialist) and Lea September (EAP) with specialist input from Renee

von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous

substances) and Seniel Pillay (Traffic Impact Assessor)

The Business Unit Head of the ILISO Environmental Management Discipline Group

Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is

a Fellow of the South African Institution of Civil Engineers a member of the South

African Society of Aquatic Scientists of the Environmental Scientific Association of

the International Water Association of the Water Institute of South Africa and of the

Vaal River Catchment Association He is a certified Environmental Assessment

Practitioner with 30 years experience who specialises in project management

environmental impact assessments and water resource planning He specifically has

extensive experience in water quality especially water quality management water

quality monitoring and water quality assessment Martin has experience in managing

projects that involve multi-disciplinary teams and public consultation and

participation in South Africa and abroad

Lea September is an Environmental Assessment Practitioner with a Masters degree

in Environmental Management She has experience in impact assessment and

environmental management and has been responsible for drafting impact

assessment reports and Environmental Management Programmes and conducting

public participation processes as well as high level environmental screenings for a

variety of projects in the energy water transport and industrial sectors

Renee von Gruenewaldt has nine-years experience in the field of air pollution

impact assessment and air quality management Prior to becoming involved in air

quality consultation she was part of the Highveld Boundary Layer Wind Research

Group based at the University of Pretoria Since joining Environmental Management

Services (the company now Airshed Planning Professionals) she has undertaken

numerous air pollution impact studies and has provided extensive guidance to both

industry and government on air quality management practices

Pieter Smuts graduated as a Civil Engineer and became involved in the field of

municipal engineering and infrastructure construction He has specialized during the

last twelve years in solid waste management He has completed waste management

plans feasibility studies and final designs of waste management facilities in South

Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and

the review of the Mavoco hazardous waste landfill design in Maputo Mozambique

and completed a study on hazardous waste (textile factory sludge) management in

Maseru Lesotho

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-4

Seniel Pillay is a transportation engineer with over 16 years experience in

transportation planning and traffic engineering He has been involved in a wide

range of projects ranging from developing the Transport Operations Plan for the

FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System

for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller

traffic impact assessments for inter alia road improvement schemes Of particular

relevance to this project his experience includes Heavy Goods Vehicle Study for

eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact

Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash

Preliminary Transportation Assessment

16 STRUCTURE OF THIS REPORT

The proposed project and the alternatives considered are described in Chapter 2

Chapter 3 details the approach adopted for the EIA phase

The biophysical and socio-economic environment affected by the activity is described

in Chapter 4

The environmental impacts identified are discussed in Chapter 5

The EIA methodology is described in Chapter 6 and Chapter 7 presents the results

of the impact assessment

The environmental impact statement is presented in Chapter 8

Finally Chapter 9 spell out the conclusions and recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-1

2 DESCRIPTION OF THE PROPOSED PROJECT

21 TECHNICAL ASPECTS

211 The galvanizing process

Galvanizing consists of coating steel with zinc in order to protect it from corrosion

Before steel strips can be galvanized they undergo a pre-treatment in order to

ensure that the steel sheets are free from any surface oxides as they enter the

molten zinc coating Bath This is done by removing the oil from the steel sheets (in

the degreasing unit) and then removing the rust from the surface of the sheet (in the

pickling unit)

The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The

melting zinc on the strip surface will be cooled and solidified through air cooling in the

cooling tower

Finally the galvanised steel sheets are dipped into a water quenching tank in order to

further cool the sheets from about 150degC to 40degC

It is possible to make galvanised steel more durable by chromating it Approximately

50 of the galvanised steel production output will receive chromate passivation

treatment after quenching the galvanised steel sheets will be sprayed with a chrome

solution (3 kgcm2)

After galvanizing and chromating the steel sheets are cut to achieve the desired coil

size and weight and transported to the storage yard

The process flow diagram below (Figure 1) illustrates the main stages of the

galvanizing process and indicates the major inputs and outputs as well as the

resulting effluent and atmospheric emissions

Draft Environmenal Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-2

Figure 1 Process flow diagram for proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-3

212 Main inputs and outputs in operational phase

In view of the above the main inputs will be as follows

Steel coils 85 000 tonsyear

Zinc 870 tonsyear

Electricity 2500 kVA

Water 2000 m3month (of which 400 m3 will be potable water)

Liquid Natural Gas (LNG) 270 NM3hour

Sodium hydroxide (NaOH) 1000 m3year

Hydrochloric acid (HCl) 800 m3year

Chrome (Cr+3) 10 m3year

The main outputs will be

Galvanized steel 80 000 tonsyear

Scrap metal 20 tonsyear

General waste 65 tonsyear

Hazardous waste 2 m3month

Wastewater 012 Mlweek

Atmospheric emissions lt 5 ppm

213 Installations on site

The bulk of the operations involved in the galvanizing process occur along a

continuous galvanizing line (See Figure 2 below) which is the main piece of

machinery required for the proposed galvanising plant

Figure 2 Continuous Galvanizing Line

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-4

Water is one of the major inputs and is used throughout the galvanizing process notably

for rinsing and cooling purposes and as a mixing agent for the various chemical

solutions The plant will have a water treatment plant on site to treat the water used in

the various processes (approx 250 m3

of wastewater per week) The wastewater

treatment facility will be operated by a professional water treatment company as Casa

Steel does not have the required expertise in house to treat its process water Sulphuric

acid (H2SO4) is used as part of the treatment process to reduce caustic soda The

neutralised water is discharged to the sewer while any sludge is disposed of as

hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)

will be disposed of

Some critical areas of the galvanizing process such as the zinc pot require uninterrupted

power It is therefore proposed to install an LNG burner to maintain the zinc bath at a

temperature of between 450 and 460degC

22 LOCATION OF THE PROPOSED GALVANIZING PLANT

The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast

of Port Elizabeth in the Eastern Cape (Figure 3)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-5

Figure 3 Location of the proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-6

23 NEED AND DESIRABILITY

The profitability of the proposed project has been established by Casa Steel and a

pre-feasibility study has confirmed that the proposed project was feasible from a

technical and financial point of view The Coega IDZ is specifically designed to host

facilities such as a galvanizing plant and can provide the necessary infrastructure

and services to its investors It therefore constitutes a very suitable location for the

project

24 ALTERNATIVES IDENTIFIED

Zone 6 has been specifically earmarked for heavy ferrous metal industries and is

therefore a suitable location for the proposed galvanizing plant as such no site

alternatives have been provided for and assessed in this EIA However prior to the

commencement of the EIA process Casa Steel was presented with a number of

different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the

selection of the site were

(a) The dimensions of the land the site should be at least 200 m long and

50 m wide in order to accommodate the galvanizing line and adjacent lay

down area and additional land should be available next to the site for future

expansion

(b) The fiscal arrangements applying to the site the site should be located

within the future Custom Controlled Area (CCA) as the bulk of the

production output of the plant will be exported

The no-go alternative is assessed in this report

25 CONSTRUCTION ASPECTS

The construction phase of the project will take about 12 months and will essentially

consist of erecting a building to house the galvanizing line and other equipment and

preparing a concrete laydown area adjacent to the building

The CDC will provide an access point from the existing tarred road that will lead to

the site

Approximately 100 workers from the surrounding areas will be contracted for the

construction work

The requirements in terms of services during construction are listed below

Water 1000 m3month

Electricity 2500 kVA

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-7

The CDC will provide temporary services for the construction phase including a

conservancy tank for flush toilets Sewage infrastructure will only be provided for the

operational phase

26 OPERATION ASPECTS

Before the plant can become fully operational the equipment and machinery will be

tested for approximately 3 months The supplier will supervise these tests as part of

the transfer of know-how and training of staff on the plant

Casa Steel will start operating the plant at a reduced capacity (about 50 000

tonsyear) for a period of time (mostly determined by market aspects) before bringing

production to full capacity (80 000 tonsyear) This is done by operating the line for

longer hours

Approximately 50 to 60 people will be working on the plant Approximately 6-10 of

these will be unskilled 40-45 skilled and about 5 people in managerial positions

The requirements in terms of services during operation are as follows

Water 2000 m3month

Electricity 2500 kVA

Effluent discharge 24 m3day

The CDC has entered into agreements with the municipality to secure the provision

of services such as water and electricity to its tenants Tenants in the IDZ have their

own agreements with the NMBM for electricity while the agreements for water and

sewage are with the Facilities Unit of the CDC

Regarding discharge of wastewater to the sewer the municipality indicated that the

only requirement is that the water discharged complies with applicable municipal

discharge standards

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 3-1

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT

31 OBJECTIVES

The main objectives of the EIA phase are to

Assess the significance of the environmental issues and impacts identified in the

scoping phase focusing on key impacts

Recommend appropriate measures to mitigate negative impacts and enhance the

benefits and include them in the draft EMP

Undertake a public participation process that provides opportunities for all

interested and affected parties (IampAPs) to be involved

32 AUTHORITY CONSULTATION

The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental

Liaison Committeersquo (ELC) which comprises representatives of various authorities

including DEDEAT the Department of Environmental Affairs (DEA) and Department

of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the

Coega Development Corporation (CDC) and Transnet National Ports Authority

(TNPA) The ELC has been specifically formed to facilitate EIA applications in the

IDZ

Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to

the clearance of vegetation should be included in the application A formal request

was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the

application and all registered stakeholders were informed of the request in writing on

19 October 2011

33 PUBLIC PARTICIPATION PROCESS CONDUCTED

On-site notices were replaced by a notification displayed on the CDCrsquos digital notice

board at the business centre in Zone 1 of the IDZ The eNotice was placed on

13 April 2011 and will remain for the full duration of the EIA process

Registered stakeholders will be notified in writing of the availability of the draft EIA

report and EMP which will also be advertised in a local newspaper Stakeholders

including state departments and the public will have forty (40) days to comment on

the draft EIA report and EMP The draft EIA report and EMP will be sent by email

where possible and made available for download on the ILISO website

(wwwilisocom)

A summary of all issues and comments received during the stakeholder consultation

process as well as of correspondence in that regard will be captured in an Issues

and Responses Report that will form an Appendix to the EIA Report

The list of registered IampAPs is included in Appendix A

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 3-2

34 LEGISLATION AND GUIDELINES CONSIDERED

The following legislation and guidelines were considered in the preparation of this

report

National Environmental Management Act Act No 107 of 1998

NEMA EIA Regulations 2010

National Environmental Management Air Quality Act Act No 39 of 2004

National Environmental Management Waste Act Act No 59 of 2008

Hazardous Substances Act Act 15 of 1993

Occupational Health and Safety Act Act 85 of 1993

Hazardous Chemical Substances Regulations 1995 (GNR 1179)

Major Hazard Installation Regulations 2001 (GNR 692)

National Water Act Act 36 of 1998

National Heritage Resources Act Act 25 of 1999

DEAT Integrated Environmental Management Information Series 1-5 and 12-15

NEMA draft Implementation Guideline

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Public Participation (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Alternatives (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Draft Guideline for Determining the Scope of Specialist

Involvement in EIA Processes (2005)

IAIA guidelines

National air quality standard for thoracic particulates Government Gazette

No 32816

Listed activities and associated minimum standards identified in terms of section

21 of the National Environmental Management Air Quality Act Act No 39 of

2004 Government Notice 248 of 2009

Minimum Requirements for the Handling Classification and Disposal of

Hazardous Waste DWAF Waste Management Series (1998)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-1

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION

The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega

IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay

to the north of the N2 highway between Port Elizabeth and Grahamstown east of the

Coega River

The co-ordinates of the corners of the site are shown in Table 1

Table 1 Coordinates of site corners for the proposed galvanizing plant

Point Longitude Latitude

A 25deg411126E 33deg45587S

B 25deg411156E 33deg45499S

C 25deg411938E 33deg45131S

D 25deg412174E 33deg45481S

E 25deg412508E 33deg45979S

F 25deg412634E 33deg451160S

G 25deg411782E 33deg451560S

H 25deg411692E 33deg451428S

J 25deg411314E 33deg45868S

Figure 4 Zone layout in the Coega IDZ

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-2

Figure 5 Site location

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-3

42 SOCIO-ECONOMIC CHARACTERISTICS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the

NMBM There are no residents within the IDZ

As far as the broader NMBM and Eastern Cape Province are concerned the

following can be noted The NMBM is located within the Eastern Cape Province the

2nd largest Province in South Africa (3rd in terms of population) characterised by a

predominantly black population with low incomes and high levels of unemployment

(CES 2010)

The NMBM has a population of just above 11 million and covers an area of

1 950 km2 It is the main urban and industrial centre of the province and Port

Elizabeth in particular which forms part of the NMBM is the commercial capital of

the Eastern Cape 52 of the NMBM population is female and 37 is below the

age of 20 these two groups are particularly affected by unemployment

43 BIOPHYSICAL CHARACTERISTICS

431 Surface and ground water

No rivers occur in Zone 6 There is however a natural attenuation pond on the

southern most part of the site which will have to be avoided

The IDZ is underlain by calcrete sand and gravel deposits that overlie low

permeability clays These clays limit the vertical infiltration of rainwater and induce a

horizontal groundwater flow towards the Coega River channel which is the most

significant surface water feature in the Coega IDZ Consequently rapid run-off takes

place following precipitation (Jacobs 2008)

Groundwater levels at Coega are generally about 3 to 5 m below surface ie just

above the contact between the permeable sands and the underlying impermeable

clays The groundwater flow direction is to the southeast following the surface water

drainage direction (Jacobs 2008)

432 Climate and atmospheric conditions

Port Elizabeth has a warm temperate climate and the temperature ranges are not

extreme Exceptionally high temperatures may be experienced during berg wind

conditions which occur frequently during autumn and winter Extreme temperatures

also occur during summer with little accompanying wind

The wind regime for the area largely reflects the synoptic scale circulation with

dominant westerly and northwesterly flow fields representing the pre-frontal

conditions and south-westerly flow fields representing the frontal conditions The

south-easterly and south-westerly wind flow (land breeze) increases during daytime

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-4

conditions with westerly and north-westerly wind flow increasing during the night (sea

breeze)

The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of

Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15

km southwest) and Port Elizabeth (~23 km southwest)

An ambient air monitoring network has been established in the Coega IDZ which

consists of three monitors Saltworks Motherwell and Amsterdamplein Although

NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative

impacts due to the proposed Galvanising Plant is PM10 A maximum daily average

PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed

SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3

was exceeded on 17 days in 2007 and 26 days in 2008

Existing sources of emissions in the vicinity of the proposed galvanizing plant include

industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other

fugitive dust sources (von Gruenewaldt 2011b)

433 Geology and soils

Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel

and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly

limestone and conglomerate

434 Terrestrial ecology

This section draws from the EIA report compiled for the Agni Steel (formerly Afro-

Asia) steel processing facility which is adjacent to the proposed site for the

galvanizing plant (Jacobs 2008)

The area consists largely of grasses succulents and scrubby bush with alien

species making up the greater part of the more dense vegetation

Zone 6 falls within the inland vegetation and is characterised by a vegetation type

referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the

Coega IDZ and has been found to have three times the level of endemism of other

vegetation communities in the Coega IDZ Bontveld therefore has a high

conservation status Two Bontveld conservation areas have been identified within the

IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)

Bontveld that will be destroyed as a result of development in the IDZ will be given

conservation status in these two areas

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-5

Figure 6 Coega IDZ Open Space Management Plan (OSMP)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-6

Certain areas in the IDZ are invaded by alien plant species The most common

invader species is rooikrans (Acacia cyclops) which presently forms large

monospecific stands in areas throughout the Coega IDZ There are several other

aliens present that pose a threat to the flora of this area including the prickly pear

(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)

Loss of vegetation and alien plant invasion due to human activity has resulted in a

reduction in the diversity of terrestrial fauna

The majority of mammals present in the Coega IDZ are small or medium-sized Of

the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed

gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of

Algoa Bay however it is not considered threatened The gerbil is common in

foredune and dune thicket habitat in the Coega region and is therefore unlikely to

occur on the proposed site

A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird

species are resident or common to the area Most diversity occurs in the thicket

although the coastal area also supports specialised avifauna Two species of tern

the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well

as the Cape gannet (Morus capensis) and the African penguin (Spheniscus

demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne

caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant

(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser

flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns

are two of the most endangered coastal species in South Africa Other bird species

of conservation concern include the Whitefronted plover (Charadrius marginatus)

African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus

bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus

ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides

paradisea) Breeding pairs of Damara terns and African black oyster catchers have

been observed in the coastal dunes of the IDZ but should not be affected by

developments that fall outside the dune areas

The Eastern Cape supports nearly a third (approximately 133 species) of the reptile

species recorded in South Africa More than half of the Eastern Capersquos endemic

reptile species occur in the Algoa Bay area giving the region a high conservation

value A total of 63 reptile species are believed to occur within the Coega IDZ The

majority of these are found in Succulent Thicket and riverine habitats Only a few

reptile species occur in the coastal dunes and estuarine habitats More than a third of

the species are described as relatively tolerant of disturbed environments provided

that migration corridors of suitable habitat are maintained to link pristine habitats

Twenty two reptiles are of special concern including five endemic species (two of

which may also be endangered) four endangered sea turtles eight species listed

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-7

with CITES one rare species and four species at the periphery of their range

Fourteen of these species of special concern are confirmed as occurring on or within

2 km of the Coega IDZ

A total of 32 amphibian species and sub-species occur in the Eastern Cape

representing almost a third of the species recorded in South Africa However none of

the species are endemic or Red Data Book species Based on previous studies in the

area it is estimated that approximately 17 amphibian species occur within the Coega

IDZ Four species are listed as peripheral but none are threatened internationally

These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog

(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and

the bubbling kassina (Kassina senegalensis)

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated

vegetation has not been extensively studied One grasshopper species Acrotylos

hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue

(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis

pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in

four localities in the Eastern Cape one of which is within the Coega IDZ The Coega

copper Aloeides clarki is endemic to this particular region of the Eastern Cape and

is currently known to occur in three localities two of which are in the Coega IDZ The

localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the

Coega IDZ and their distributions were taken into account when defining Coegarsquos

open space system and Development Framework Plan

435 Land use and topography

The land is currently undeveloped and earmarked for industrial development The

site is relatively flat ranging from an elevation of 66 masl on the northern-most

corner to 59 masl at the southern-most corner

436 Heritage and archaeological survey

Extensive studies have been undertaken in Zone 6 with respect to heritage aspects

Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a

2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond

2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is

currently being finalised

Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing

Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha

in extent and was located next to the R102 road to Motherwell Kaplan conducted

HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi

Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will

now be located in Zone 5)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-8

The various archaeological investigations reached similar observations and

conclusions Stone tools of various densities and types were found throughout the

zone The majority of the stone tools were mainly of Earlier and Middle Stone Age

and occasional Later Stone Age origins (Figure 4)

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble

gravels exposed by tracks in Zone 6 (Source Binneman 2010)

The stone tools which comprised of quartzite flakes chunks flaked pebblecobble

and cores were randomly distributed across the landscape and are in secondary

context There were no lsquoconcentrationsrsquo of tools observed which suggested any

spatial patterning or activity areas although these may be present or covered by soil

and vegetation

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 5-1

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED

The following environmental issues and potential impacts were identified in the

Scoping phase

51 AIR QUALITY

The galvanizing process generates atmospheric emissions with particulates and

hydrogen chloride representing the main pollutants of concern The plant is fitted with

air extraction as well as scrubber systems which are designed to retain the bulk of

pollutants and particles for each of the processes in such a way that less than 5 ppm

of gases and particles will be released into the atmosphere after the fume scrubber

Other sources of impact on air quality include emissions from the LNG burner as well

as emissions and dust from the transport of steel and other materials in trucks

Construction activities will also create dust and gas emissions due to the clearing of

groundcover tipping of material to storage pile levelling of area wind erosion from

storage piles vehicle and construction equipment activity and tailpipe emissions

from vehicles and construction equipment such as graders scrapers and dozers

Overall the air quality impact assessment (Gruenewaldt 2011b) found that

The predicted particulate oxides of nitrogen carbon monoxide and sulphur

dioxide concentrations are all below the National Ambient Air Quality Standards

for all averaging periods

The predicted off-site concentrations of hydrogen chloride are well below the

most stringent effect screening levels

No odour threshold exceedances for hydrogen chloride were predicted to occur

due to routine operations at the Steel Galvanising Plant The South Wales

Environmental Protection Authority stipulates that an odour unit of 20 is

acceptable for urban areas The odour unit would be lt10 directly off-site for

hydrogen chloride

Abnormal emissions can occur in exceptional circumstances Start-up will not

cause abnormal emissions as the scrubbers will be commissioned first and will be

functioning once the plant starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions would be emitted as a

building fugitive

The hourly hydrogen chloride ground level concentrations (directly offsite) were

predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based

on the emission limits as stipulated for listed activities for galvanising processes)

using a screen model which assumes worst case meteorological conditions The

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-2

health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming

abnormal emissions emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset conditions will still

be well within the health effect screening levels

Similarly the hourly particulate emissions from the building fugitives during upset

conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for

listed activities for galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly

off-site

Therefore if emissions are 5 times higher normal they will still be within health effect

screening levels and the daily PM10 NAAQS levels

In the case of a fire a cocktail of gases and particulates could be emitted and could

be over the recommended levels This situation will however be dealt with as an

emergency and normalised as quickly as is possible

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS

The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of

its heritage potential and there are no proposed protected geosites in Zone 6

Should any artefacts be discovered during construction procedures stipulated in the

draft EMP will apply

53 BIODIVERSITY AND CONSERVATION

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

In terms of terrestrial fauna the CDCrsquos open space management plan provides for

the preservation of certain corridors The destruction of certain habitats as a result of

the development will therefore not automatically result in the loss of certain species

54 WATER QUALITY

There is a natural attenuation pond on the southern most part of the site which will be

avoided

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through

spills or leaks

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-3

This risk can however be minimized if not avoided altogether The floor of the factory

will be designed as a bunded area to contain any spills and the entire process will be

contained Potential spills or leaks will therefore be contained and will not impact on

water resources Storm water is therefore considered clean water under normal

operational conditions An oil trap will be placed at the exit of the site to ensure that

no grease from the laydown area enters the stormwater system

Spills and leaks can occur during the handling or the transport of hazardous

substances Best practice guidelines will be followed to ensure that this risk is

adequately managed

Wastewater discharged to sewer will be treated to comply with municipal discharge

standards and is not expected to have an impact on the chemical characteristics of

the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be

discharged from the plant is small in relation to the total volume received at the

Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works

(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently

operated at 61 of its capacity which is approximately 80 Mℓday Thus the

0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore

not have any significant impact on the WWTW

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES

The plant will generate a relatively small amount of solid waste in the form of scrap

metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)

The scrap metal may be sold to other steel processing facilities such as Agni Steel

which will be located next to the plant or collected and disposed of with the rest of

the solid waste by a licensed service provider

As mentioned previously there will be a wastewater treatment plant on site which will

neutralise process water (012 Mlweek) in order to ensure it is of a standard

acceptable for discharge to sewer Waste in the form of sludge from the

neutralization or spent acid must be disposed of as a hazardous waste Solid waste

from the filters used for air quality control is also in this category These wastes can

usually be tested and then delisted which means that it can be placed in a general

purpose landfill

Hazardous effluent from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-

site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored

and removed on a monthly basis is limited to 10 m3

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-4

A number of substances classified as hazardous are used in the galvanizing process

(Table 2) and the transport and handling of these is subject to certain rules and

guidelines In particular the material safety data sheets (cf Appendix H) should be

referred to for inter alia hazards identification accidental release measures

handling and storage precautions exposure controlpersonal protection ecological

information and transport information The Hazardous Chemical Substances

Regulations 1995 should also be adhered to in respect of the transport and storage

of hazardous chemical substances

Table 2 Hazardous materials to be used on site

Major Input Materials

Substance

listed in the

SABS 0228

Group II

hazardous

substances

Volumes to be

stored on site at

any one time

Diesel radic 2000 litres

Liquid petroleum radic 20 000 liters

Sodium hydroxide (NaOH)

(used for degreasing) 8 radic 1000m

3

Hydrochloric acid (HCI)

(used for pickling) 8 radic 800m

3

Zinc (used for galvanising) - TBD

Trivalent chromium (CR+3

)

(used for chromating) 8 radic 10m

3

Sulphuric acid (H2SO4) (used for

treatment of waste water on site) 8 radic TBD

Ammonium Hydroxide (NH4OH) 8 radic TBD

TBD ndash To be determined

Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one

time) and is classified as a flammable substance Specification for flammable storage

facilities in accordance with the requirements of the Nelson Mandela Bay

Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for

quantities between 5000 and 20 000 liters the substance must be kept in a

flammable liquid store which complies with the requirements of a specification

obtainable from the Department Some of the requirements are

Flammable liquid and solid storage facilities are only permitted on the ground

floor

Decanting of flammable liquids and solids are not permitted within any building

Due to the fact that there are flammable materials on site a certificate may be

required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and

Emergency Services Department to confirm that facilities for flammable storage

are in accordance with their requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-5

Because of the permanent installation and high quantity of liquid petroleum on site

the Major Hazard Installation Regulations 2001 promulgated under the Occupational

Health and Safety Act No 85 of 1993 applies A written application for approval of

the installation is required to be submitted to the chief inspector Department of

Labour provincial director Department of Labour and NMBM prior to construction

In addition a risk assessment should be formulated covering all hazardous materials

together with an emergency preparedness and response plan

56 HEALTH AND SAFETY

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling instructions as well as occupational exposure limits

are indicated in the material safety data sheets of the various substances used

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as

provide site supervision including executing tests (individual test cold run and hot

run) during 3 months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the

EMP

In addition the emergency preparedness and response plan will cover the health and

safety aspects related to emergency situations

57 TRAFFIC

The volumes of traffic at the IDZ are currently relatively low and variable depending

on the different zones in the IDZ however these volumes will increase as more

developments are implemented

The construction phase of the Casa Steel development will take about 12 months

and will essentially consist of erecting a building to house the galvanizing line and

other equipment and preparing a concrete laydown area adjacent to the building

The traffic that would be generated during the construction phase can be expected to

be less than the traffic that would be generated by the Casa Steel development when

it is fully operational

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-6

In the operation phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and

from the Port of Ngqura

The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the

Casa Steel development would be off Ring Road 1 The other roads of significance

for the Casa Steel development are the N2 Neptune Road MR435 and MR450

Access to the port is given by Neptune Road Road Link NEP-03 has not yet been

built

Figure 8 Coega IDZ road network identification

(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-7

Figure 9 Coega IDZ road network

Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No

01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-8

The distribution of freight trips is fixed as the majority of trips will be made between

the Port of Ngqura and the Casa Steel site With regard to personnel trips there are

various points of origins (the surrounding residential areas) that could be used by

staff going to the Casa Steel site The distribution of personnel trips is based on

existing traffic count information and is shown in Figure 10

Figure 10 Trip distribution for freight and personnel trips

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The resultant expected Casa Steel traffic assignment is shown in Figure 11

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-9

Figure 11 Morning peak hour Casa Steel development traffic

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The traffic that is expected to be generated by the Casa Steel development is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low

and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)

Consultation has taken place with Transnet Port Authority (TPA) to establish the

impact of the galvanizing plant operations on traffic inside the port The additional

ships entering and exiting the port of Ngqura as a result of the proposed development

will have a negligible impact on port traffic and TPA indicated that it would be well

within the portrsquos capacity

58 NOISE

Noise is not foreseen to be a significant issue insofar as the noise levels inside the

plant and at the boundary of the site will not exceed the limits prescribed by the CDC

Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels

during the day and 60 decibels at night

Mitigation of noise impacts will be addressed in the design of the noise-emitting

components of the plant and their enclosures

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-10

59 SOCIO-ECONOMIC ASPECTS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of

NMBM There are no residents within the IDZ

The direct socio-economic impacts of the proposed project are thus limited to the

employment generated by the project during construction and operation Job creation

remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)

and the IDZ and Port of Ngqura are expected to become a significant catalyst to the

economic growth of the Municipality and the region with current investments at

Coega creating more jobs and stimulating the economy

In this context the proposed galvanizing plant will make a positive contribution

towards the achievement of these goals

There will be 50 to 60 employees during operation phase distributed as follows

Figure 12 Casa Steel organisation chart

Even though a large part of the inputs will be imported and the bulk of the production

output will be exported there will be some positive impacts for the economy of the

region and of South Africa in general Notably the requirements of the plant for

water electricity waste collection and disposal waste water treatment and transport

for example will create business for the various service providers and have an

indirect impact on employment and fiscal revenues as a result

From a visual impact point of view it can be anticipated that the landscape in the IDZ

will be significantly affected over time by developments related to the establishment

of the port and various industries

HEAD ( WORKS )

MGR ( COMM) MGR ( ADMNHR ) Manager marketing

MANAGER OPERATION MANAGER MANAGER MANAGER Q C

AC FIN PUR ampSTORE

PPC SH-GALV SH-tech

SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF

1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO

JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF

2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO

WORKERS WORKERS 7NOS

15 7

RAW MAT amp

DESP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 6-1

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY

A description of the nature of the impact any specific legal requirements and the

stage (constructiondecommissioning or operation) will be given Impacts are

considered to be the same during construction and decommissioning The

significance of the potential impacts will be considered before and after identified

mitigation is implemented

The following criteria will be used to evaluate significance

Nature The nature of the impact will be classified as positive or negative and

direct or indirect

Extent and location Magnitude of the impact and is classified as

Local the impacted area is only at the site ndash the actual extent of the activity

Regional the impacted area extends to the surrounding immediate and

neighbouring properties

National the impact can be considered to be of national importance

Duration This measures the lifetime of the impact and is classified as

o Short term the impact will be for 0 ndash 3 years or only last for the period of

construction

o Medium term three to ten years

o Long term longer than 10 years or the impact will continue for the entire

operational lifetime of the project

o Permanent this applies to the impact that will remain after the operational

lifetime of the project

Intensity This is the degree to which the project affects or changes the

environment and is classified as

o Low the change is slight and often not noticeable and the natural functioning

of the environment is not affected

o Medium The environment is remarkably altered but still functions in a

modified way

o High Functioning of the affected environment is disturbed and can cease

Probability This is the likelihood or the chances that the impact will occur and

is classified as

o Low during the normal operation of the project no impacts are expected

o Medium the impact is likely to occur if extra care is not taken to mitigate

them

o High the environment will be affected irrespectively in some cases such

impact can be reduced

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 6-2

Confidence This is the level knowledgeinformation the environmental impact

practitioner or a specialist had in hisher judgement and is rated as

o Low the judgement is based on intuition and not on knowledge or

information

o Medium common sense and general knowledge informs the decision

o High Scientific and or proven information has been used to give such a

judgment

Significance Based on the above criteria the significance of issues will be

determined This is the importance of the impact in terms of physical extent and

time scale and is rated as

o Low the impacts are less important

o Medium the impacts are important and require attention mitigation is

required to reduce the negative impacts

o High the impacts are of great importance Mitigation is therefore crucial

Cumulative Impacts The possible cumulative impacts will also be considered

Mitigation Mitigation for significant issues is incorporated into the EMP for

construction

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 7-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS

71 IMPACTS DURING CONSTRUCTION

711 Air quality

Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris

handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine

particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural

operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks

and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)

Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Fugitive particulate emissions (dust)

related to construction activities Regional

Short

term Medium High High Medium Regional

Short

term Low High High Low

Construction vehicle gas emissions Regional Short

term Medium High High Medium Regional

Short

term Low High High Low

712 Heritage and archaeological resources

Naturedescription of impact excavation activities may impact on unidentified heritage resources

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-2

Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based

on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments

Heritage and archaeological

resources Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on unidentified heritage

resources Local

Short

term

Medium -

high Low High Low

713 Biodiversity and conservation

Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation

importance and cause soil contamination

Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species

Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan

and has compiled a list of protected species to be rescued (see draft EMP)

Biodiversity and conservation Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Loss of fauna and flora Local Perma

nent

Medium -

high High High High Local

Permanen

t Medium High High Medium

Soil contamination Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-3

714 Water related impacts

Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater

runoff spills and leaks Soil erosion

Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of

spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste

disposal Stormwater quality monitoring (see draft EMP)

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Soil erosion Local Short

term Medium Medium High Medium Local

Short

term Medium Low High Low

715 Waste management

Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed

Commentmitigation see draft EMP and waste management plan

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-4

Waste management Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Local

Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

716 Health and safety

Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Short

term

Medium -

high

Medium -

high High High Local

Short

term

Medium -

high Low High Low

717 Traffic

Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and

construction workers from surrounding areas and transport of equipment from the port

Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low

Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and

accurate estimates of quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-5

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Increased traffic on N2 and within the

IDZ Regional

Short

term Low High High Low

718 Noise

Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Short

term

Medium-

high High High Medium Local

Short

term Medium High High Medium

719 Socio-economic

Naturedescription of impact temporary employment will be created during the construction phase

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-6

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Temporary employment Regional Short

term Medium High High Medium

72 IMPACTS DURING OPERATION

721 Air quality

NatureDescription of impact gas and particulate emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning

Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local

sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and

veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute

to background fine particulate concentrations (von Gruenewaldt 2011b)

Assumptions and limitations Potential release of CR6+

As no emission factors are available for trivalent chromium processing the

potential impacts due to these activities could not be quantified

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Dust emitted from traffic on paved roads Regional Long Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-7

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

term

Hydrogen chloride emissions from

pickling process Local

Long

term Low High High Low

Particulate emissions (smoke) from

galvanizing process (due to the

volatilization of flux)

Local Long

term Low High High Low

Particulate oxides of nitrogen carbon

monoxide and sulphur dioxide emissions

from LNG burner

Local Long

term Low High High Low

Nuisance related to odour Local Long

term Low Low High Low

Abnormally high hydrogen chloride and

particulate emissions due to scrubber

malfunction

Local Short

term Medium Low High Medium

Gases (eg SOx NOx CO etc) and

smoke emitted in case of a fire Local

Short

term High Low High Medium

722 Water quality

NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks

Commentmitigation see draft EMP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-8

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Stormwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

723 Waste management and hazardous substances

NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous

waste both can affect environmental quality and human health

Commentmitigation see draft EMP and waste management plan

Waste management and hazardous

substances Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Regional

Long

term High

Medium -

high High High Regional Long term High Low High Low

Soilwaterair pollution due to improper

transport storage and handling of

hazardous substances

Regional Long

term High

Medium -

high High High Regional Long term High Low High Low

Health hazard Local Long

term High

Medium -

high High High Local Long term High Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-9

724 Health and safety

Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Long

term

Medium-

high

Medium-

high High High Local Long term

Medium-

high Low High Low

725 Traffic

Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on

the road network

Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak

hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road

network within Zone 6 of the IDZ (Iliso 2011)

Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)

Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of

quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-10

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on traffic and capacity of the N2 Regional Long

term Low High High Low

Impact on traffic and capacity of ring

road 1 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR435 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR450 Local

Long

term Low High High Low

Impact on traffic and capacity of

Neptune road Local

Long

term Low High High Low

726 Noise

Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Long

term Medium High High Medium Local Long term Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-11

727 Socio-economic

Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate

revenue for the municipality and the region as a whole

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Employment and economic growth Regional Short

term Medium High High Medium

73 COMPARATIVE ASSESSMENT OF IMPACTS

During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as

low during operation after mitigation

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 8-1

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

As a tenant operating in the IDZ Casa Steel will be required to comply with all

current and future CDC requirements as well as with the relevant conditions of

permits licences issued to CDC (eg Integrated Stormwater Masterplan for the

eastern side of the Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)

In particular the CDC has its own requirements regarding the monitoring of certain

aspects of the project such as the quality of the effluent and the noise levels These

have been incorporated into the EMP

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 9-1

9 ENVIRONMENTAL IMPACT STATEMENT

All predicted negative impacts can be mitigated to a low significance The only

exceptions are biodiversity as the construction of the plant will result in the

destruction of habitat and loss of fauna and flora and noise impacts inherent to

construction activities Mitigation measures have been included in the EMP for these

impacts and they have a medium significance post-mitigation

Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium to

long term similar impacts are likely to occur due to ongoing developments in the IDZ

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 10-1

10 CONCLUSION AND RECOMMENDATIONS

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as

other infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified

and assessed No fatal flaws have been identified

It is recommended that the project be approved subject to the conditions listed in

chapter 9 and adherence to the EMP requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 11-1

11 REFERENCES

Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ

Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants

Bennie JS (2010) The historical component (built environment) of the Heritage

Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port

Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report

compiled for Eastern Cape Heritage Consultants

Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater

Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay

Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage

Consultants

BKS (2006) Coega Industrial Development Zone Transport Study Volume 3

Demand Modelling Report Final Draft

Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I

Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6

Report compiled for SRK Consulting

Coastal amp Environmental Services (2010) Environmental Impact Assessment for the

Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone

Volume 3 Environmental Impact Assessment Report CES Grahamstown

Coega Development Corporation (2008) Industry Waste Management Plan -

Strategic Master Plan Report

Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants

Report No CDCSHE 03 8122

Department of Water Affairs and Forestry (1998) Waste Management Series

ldquoMinimum Requirements For The Handling Classification And Disposal Of

Hazardous Wasterdquo Second Edition

Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising

Plant in the Coega Industrial Development Zone

Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the

Coega Industrial Development Zone (IDZ) Specialist Water Study

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 11-2

Jacobs E (2008) Final Environmental Impact Report and Draft Environmental

Management Plan Proposed Steel Recycling and Processing Facility within the

Coega IDZ Report compiled for SRK Consulting

Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY

Galvanising Plant in the Coega Industrial Development Zone Waste Management

and Hazardous Substances Report compiled for ILISO Consulting

RSA National air quality standard for thoracic particulates (PM10) SA standards

(Government Gazette No 32816)

von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed

Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape

Report compiled for ILISO Consulting

von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel

Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report

compiled for ILISO Consulting

Additional sources

Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed

Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared

for Coastal Environmental Services

Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed

Kalagadi Manganese smelter in the Coega Industrial Development Zone Port

Elizabeth Eastern Cape Province Report prepared for Coastal Environmental

Services

Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia

steel recycling facility at the Coega Industrial Development Area Port Elizabeth

Prepared for SRK Consulting Port Elizabeth

APPENDIX A

LIST OF INTERESTED AND

AFFECTED PARTIES

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

DEDEARegional Manager

and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza

DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza

DEA Ocean and

CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza

DEA Ocean and

Coast

Oceanographer land-

based sources of

marine pollution

Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza

DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza

CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza

CDCEnvironmental

Project

Manager

Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza

TNPAPort of Ngqura

Environmental

Manager

Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet

NMBMEnvironmental

ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza

NMBMEnvironmental

ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza

DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza

DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza

WESSASenior Conservation

Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza

Zwartkops

ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700

hughlauegmailcom

zwartkopstrustiafricacom

SANParksNational Marine

CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza

Department Of

LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza

NMBM Air Quality

Division

Assistant

DirectorAir

Pollution and Noise

Templeton Titima 079 490 0574 Ttitimamandelametrogovza

NMBM Air Quality

DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza

NUMSARegional

RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

Department of

HealthNadiema

van der

Bergh083 378 2103

nadiemavanderberghimpiloecprovgov

za

DWA Chief Services

Officer

Joseph Jacobs 041 586 4884 jjacobsdwafgovza

EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza

NUMSecretary of union

officesZandile Xhentsa 043 743 6597 zxhentsanumorgza

DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza

Dynamic

CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom

EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza

Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza

UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom

lprincezago2uticom

Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza

Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza

Absa Mr Johann Steyn 082 3775820 johannstabsacoza

Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza

PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza

Universal

EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza

Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza

GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom

Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza

NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom

DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza

DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza

TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet

DWA Mr Landile Jack JackLdwagovza

DWA Ms Lizna Fourie FourieL4dwagovza

APPENDIX B

NOTICE OF ATMOSPHERIC

EMISSIONS LICENCE APPLICATION

AND ADVERTISEMENT

APPENDIX C

NOTICE OF COMMENT PERIOD FOR

DRAFT SCOPING REPORT

APPENDIX D

SUMMARY OF ISSUES RAISED AND

RESPONSES THERETO

April 2012

1

PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL

DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))

IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt

AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt

This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses

provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process

conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the

Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

2

IssueCommentQuestion Date

received Origin Response

1 Please provide more information with respect to the potential

dangers including the toxicity of the proposed project

07032011

By email

Wayne Poulton

(Bosun Brick

tenant at the

IDZ)

An Environmental Impact Assessment (EIA) was undertaken

which assessed the potential toxicity of the emissions and

effluent Mitigation measures were also recommended in the draft

Environmental Management Programme (EMP) to avoid

minimise or compensate any significant impacts The Draft

Environmental Impact Report and draft EMP were made available

to stakeholders for comment in March 2012

2 Do you have a Background Information Document (BID) or

similar that provides more information on the project

27032011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The BID was sent to all registered IampAPs on 4 May 2011

3 The RoD issued to the CDC on 632007 for the change in

land use for the remaining area of the Coega IDZ includes a

number of requirements with respect to

atmospheric emissions that should be considered in the

Atmospheric Emissions Licence (AEL) application such as

prohibiting and monitoring where possible visible emission

plumes to the atmosphere In particular the

recommendations on pp87-91 of the final revised Scoping

Report dated Nov 2006 must be implemented (clause 421)

04042011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

We have obtained copies of the documents referred to and ensure

that these requirements were taken into account in the

environmental assessment and AEL application

4 If the Port of Ngqura is used for import and export the scope

of the traffic impact assessment (TIA) should also include the

port

10052011

By email

Elliot

Motsoahole

(TNPA Port of

Ngqura)

The scope of the TIA was extended to include port related traffic

The TNPA at the Port of Ngqura was consulted and does not

have any objection to the project TNPA has indicated that the

development would require a minimum number of vessels per

year which would have minimal impact on the Port operations

However due notice would have to be given to the Port of Ngqura

before a vessel is scheduled to arrive so that the vessel can be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

3

IssueCommentQuestion Date

received Origin Response

accommodated at an available berth

5 Concerns with respect to potential stormwater pollution

draining into the Coega catchment and the port of Ngqura

The port needs to be dredged and heavy metals present a

risk in that regard

16052011

By

telephone

Andrew Lucas

(Department of

Water Affairs)

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination by effluent waste or

hazardousdangerous substances is very low

Thus no metals oils or other contaminants are expected to be

present in the stormwater

However stormwater pollution can occur in exceptional

circumstances such as accidents and emergencies The

emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

6 All steel sheets bathing unit must be under roof

7 The sludge out of the decreasing bath will be high in Na and

pH Therefore handling and disposal must be clarified up front

in this project

8 Per se the wastewater from decreasing bath will have high

ph and the component from the pickling unit will have low ph

Then it may be assumed that both streams will neutralize

each other Please then clarify proposed sewer discharge

with Nelson Mandela Bay Municipality up-front for acceptance

of influent as per the documented proposal

9 Pickling may result in dissolved metals How does your team

expect to deal with this As it is planned for discharge into

24052011

By email

Landile Jack

(Department of

Water Affairs)

All bathing units will be under roof

Effluent from the degreasing and pickling baths will be discharged

to the wastewater treatment plant The respectively alkaline and

acidic effluents will mix and neutralise each other in the

wastewater treatment plant Calcium or gypsum will be added if

required to complete the neutralisation process Effluent from the

treatment plant will be discharged to sewer Contact has been

made with the relevant officials and the Municipalityrsquos

requirements have been obtained The effluent discharged to

sewer will notably comply with the applicable discharge standards

Traces of metals (eg iron) may be present but will not exceed

prescribed thresholds The necessary authorisation will be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

4

IssueCommentQuestion Date

received Origin Response

sewer Clarity and acceptance needs to be agreed with

Nelson Mandela Bay Municipality Who owns the sewer

10 Quenching unit will results to Zinc particles How will this

affect sewer discharge This again must be dealt with within

the negotiations with the Municipality

11 Once all has been agreed with the Municipality and at the

same time due negotiations must be done with hazardous

waste courier and disposal facility to accept the hazardous

waste identified in all production lines

12 Of note is the low volume of the proposed WWTW facility ie

250 cubmweek And the no discharge of the quenching

water ie over-flow and cooling only Hence Zinc particles

generation

obtained from the municipality

The sludge from the treatment plant will be collected by a licensed

service provider and disposed of at a permitted site

The quenching bath will be periodically emptied (every 6 months)

and the water discharged will go to the water treatment plant Zinc

particles will settle in the sludge which will be disposed of at a

permitted site

Contact has been made with EnviroServ who manages the

Aloes II HH waste site regarding collection and disposal of

hazardous waste (See waste management report)

13 Investigate the potential effects of toxicity andor influence of

emissions waste and hazardous substances both in

terrestrial and marine fauna

14 With regards to water usage where is the plant going to

extract its waters used in galvanization andor waste

management process ie rainfall rivers or even from the

sea) and which avenues would be more environmental

friendly and effective

31052011

By email

A Bewana

(SANPARKS)

Emissions waste and hazardous substances are not expected to

affect terrestrial or marine ecosystems The air quality study

concluded that atmospheric emissions would not be harmful to

human health and by extension terrestrial fauna There are no

standards for air quality for defining faunal impacts therefore by

ensuring that standards for humans are complied with the impact

on fauna is deemed to be acceptable In this case the impact of

emissions on terrestrial and marine fauna are thus not significant

Solid and liquid wastes both general and hazardous as well as

hazardous substances will be stored handled and disposed of

appropriately to as not to cause harm to terrestrial or marine

fauna

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

5

IssueCommentQuestion Date

received Origin Response

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination and hence land-based

marine pollution by effluent waste or hazardousdangerous

substances is very low

The risk of emissions waste and hazardous substances to

terrestrial and marine fauna is thus very low

However pollution of terrestrial and marine ecosystems can occur

in exceptional circumstances such as accidents and emergencies

The emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

The CDC has an agreement with the NMBM to supply potable

water to the Coega IDZ Currently the infrastructure to supply

return effluent (RE) to the IDZ is not in place therefore Casa Steel

will be supplied with potable water up until such time as the

following 2 options of RE are available

1) Upgrading of the existing Fishwater Flats waste water

treatment works (between IDZ amp PE) including RE plant

and infrastructure to pipe RE to the IDZ (EIA for the

upgrade is underway)

2) Construction of a new waste water treatment works

including RE plant in Zone 9 of the Coega IDZ

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option should be investigated further between Agni and Casa The

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

6

IssueCommentQuestion Date

received Origin Response

CDC can facilitate discussions between the 2 investors

Compliance with CDC Permits amp Requirements

15 It should be made clear that tenants will be required to

comply with CDC requirements and the relevant conditions of

permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water

Licence for its Storm Water Systems on the

East Side of the Coega River that tenants will

need to take cognizance of The contents of the

ldquoIntegrated Stormwater Masterplan for the

eastern side of the Coega IDZ Oct 2010rdquo

especially the Table of best practice p53

onwards may need to be taken cognizance of

o CDC is developing an Operations

Environmental Management Plan that will place

certain obligations on tenants

16 Environmental audits and data collected during monitoring

(eg stack emissions stormwater) will need to be shared with

CDC

Air Emissions

17 Presumably permanent in stack monitoring will be required in

terms of AEL permit requirements

18 Abnormal operating conditions resulting in air emissions ndash I

could find nothing in the EIR to indicate under what

circumstances these could occur (eg start-up) potential

frequency and duration and the impact on ambient air quality

ndash these events usually result in the most problems wrt air

emissions

09042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

15 Compliance with the CDCrsquos Permits amp Requirements has

been included explicitly as a requirement in the EIR (p8-1) and

EMP (pp18 and 25) in the following terms

ldquoAs a tenant operating in the IDZ Casa Steel will be required to

comply with all current and future CDC requirements as well as

with the relevant conditions of permits licences issued to CDC

(eg Integrated Stormwater Masterplan for the eastern side of the

Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)rdquo

16 The need to communicate with the CDC on monitoring and

auditing activities was emphasised in Chapter 8 of the EMP The

following paragraphs were added

ldquoDuring construction the environmental officer will be responsible

for monitoring compliance with the EMP and authorisation

conditions and keeping records as required in the EMP andor

authorisation conditions

The ECO will conduct site inspections every two weeks audit the

records kept by the environmental officer and submit an

environmental compliance report every two months to the

authorities and the CDC (via the Environmental Monitoring

Committeersquos ECO)

During operation the health and safety officer will monitor

compliance with the EMP and the conditions of the Environmental

Authorisation Data collected during monitoring activities and any

environmental audits conducted will be shared with authorities

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

7

IssueCommentQuestion Date

received Origin Response

Water

19 Large volumes of (2000 m3mth) of water are required of

which only 400m3 needs to be potable The NMBM return

effluent system will provide non-potable water once it is

constructed What other water recycling initiatives can be

utilized to reduce potable water requirements (the ISWMP for

the eastern side of the Coega IDZ has some best practice

guidelines collecting rainwater from the roof etc)

General

20 There is no mention of how the CDC Architectural Guidelines

will be incorporated into the development (eg to prevent a

stark uniform warehouse type development)

21 Does NMBM have adequate fire services to cover this

development Apart from the large petroleum store are there

any other large fire hazards

22 Reports from the tenantrsquos ECO during construction and from

the SHE Officer during operations should be channeled to the

Coega Environmental Monitoring Committee This can be

directly or preferably via the EMCrsquos ECO (this will be while

the EMC and ECO are in place) A precedent has been set

for this in the Environmental Authorisations for Agni-Steel and

Kalagadi Manganese Smelter

23 All mitigation actions emanating from the EIR should be

summarized (preferably in a table) If compliance with them is

to be part of the Environmental Authorization from DEDEAT

then they (or the ones that DEDEAT deems to be applicable)

and the CDC (via the Environmental Monitoring Committeersquos

ECO)

The ECO (during construction) and the health and safety officer

(during operation) will report to the Coega Environmental

Monitoring Committee (EMC) via the EMCrsquos ECO (this will be

while the EMC and ECO are in place)rdquo

17 The draft EMP recommends regular monitoring of emissions

from the scrubbers and from the chromating process Additional

emissions monitoring requirements will be confirmed once the

AEL is issued Mention has been made in the EMP (pp11 and 19)

that all AEL conditions including monitoring and reporting

requirements should be adhered to

18 Abnormal emissions can occur in exceptional circumstances

Start-up will not cause abnormal emissions as the scrubbers

will be commissioned first and will be functioning once the plant

starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions

would be emitted as a building fugitive

The hourly hydrogen chloride ground level concentrations

(directly offsite) were predicted to be 239 microgmsup3 (based on the

emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits

as stipulated for listed activities for galvanising processes) using a

screen model which assumes worst case meteorological

conditions The health effect screening level for hourly HCl

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

8

IssueCommentQuestion Date

received Origin Response

should be attached to the EA as an Appendix (otherwise no

one knows about them or takes cognizance of them)

concentrations is 2100 microgmsup3 Assuming abnormal emissions

emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset

conditions will still be well within the health effect screening

levels

Similarly the hourly particulate emissions from the building

fugitives during upset conditions would amount to 293 microgmsup3

(based on the emission limits as stipulated for listed activities for

galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1

January 2015) directly off-site

Therefore if emissions are 5 times higher normal they will still be

within health effect screening levels and the daily PM10 NAAQS

levels

In the case of a fire a cocktail of gases and particulates could be

emitted and could be over the recommended levels This

situation will however be dealt with as an emergency and

normalised as quickly as is possible

The above has been added to the impact identificationdescription

and assessment sections of the EIR

19 The CDC has an agreement with the NMBM to supply

potable water to the Coega IDZ Currently the infrastructure to

supply return effluent to the IDZ is not in place therefore Casa

Steel will be supplied with potable water up until such time as the

infrastructure is in place

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

9

IssueCommentQuestion Date

received Origin Response

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option will be investigated further between Agni and Casa The

CDC has come forward to facilitate discussions between the two

investors

Other water recycling initiatives such as rainwater harvesting

have been considered but are not practical

20 The CDCrsquos Architectural and Landscape Design guidelines

contain requirements pertaining to such aspects as the height

orientation and mass and form of buildings as well as guidelines

for landscaping and signage in order to ensure an attractive

development and achieve an architectural integrity within the

Coega IDZ The plans for the proposed galvanizing plant will be

submitted to the Design Review Committee for approval as

required by the CDC

21 Casa Steel will be required to install fire hydrants according

to the NMBMrsquos standardsrequirements The CDC will provide

potable water (up until such time as return effluent is available)

and a connection to the boundary of the site which will be

connected to the fire hydrants The installation of the fire hydrants

will require approval by the Metrorsquos Fire Chief as was done for

Agni-Steel one of the investors in Zone 6

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

10

IssueCommentQuestion Date

received Origin Response

The Coega IDZ falls within the NMBM and therefore the rates and

taxes paid by the CDC covers the fire services for which the Metro

is responsible Currently the Metro has sufficient capacity to

provide fire services to the tenants within the IDZ This was

confirmed in discussion with the CDCrsquos Infrastructure

Development Unit It is however unknown at which point the

Metrorsquos Disaster Management Plan would not be able to

accommodate servicing tenants in the IDZ

The LNG burner is the only major fire hazard on the plant

22 See response to item 16 above

23 Key mitigation and management measures emanating from

the EIR were recapitulated in Chapter 9 of the EIR to form part of

the conditions attached to the Environmental Authorization from

DEDEAT All mitigation measures recommended as a result of the

impact assessment are presented in a table in the draft EMP

which is appended to the EIR (Appendix J)

24 Hydrogen chloride is one of the main emissions There are no

ambient air quality guidelines for HCl and the EIR says

concentrations will be well within health parameters

However the main problem with HCl is its corrosive effect -

there is absolutely no mention of this in the draft EIR nor air

specialist report

There needs to be some sort of comment assessment as to

whether HCl emissions are likely to impact on for example

the adjacent Agni-Steel Plant wrt corrosion - their factory

structure will be made of steel

11042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The atmospheric corrosion of metals is a complex process with

both the extent of deterioration and the mechanisms varying

considerably depending on the metal Depending on the way

pollutants are transported from the atmosphere to the corroding

surface two types of deposition processes are recognized in

atmospheric corrosion ndash dry deposition and wet deposition Wet

deposition refers to precipitation whereas dry deposition refers to

the remaining processes including gas phase deposition and

particle deposition The most important pollutants acting as

corrosive agents are sulphur and nitrogen compounds including

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

11

IssueCommentQuestion Date

received Origin Response

The EIR specialist rpt suggests monitoring HCl at ground

level on the property boundary and this is supported in case

there are complaints from neighbours

secondary pollutants and particulates Pollutants can contribute to

corrosivity individually however there may be a synergistic effect

when more than one of these pollutants is present in the

environment being affected In the field of atmospheric corrosion

sulphur dioxide is the single most investigated gaseous pollutant

and the quantification of the direct contribution of sulphur dioxide

to the corrosion process of metallic materials is comparatively well

understood (Tidblad amp Kucera 1998)

Very little work has reported on the effect of HCl on the

degradation of materials in the environment with no local dose-

response thresholds developed for corrosion occurring due to HCl

exposures This is probably because HCl which is present

outdoors in markedly reduced concentrations when compared

with SO2 has not been considered to contribute to significant

degradation of materials (Syed 2006) For this reason the

incremental corrosion due to HCl from the Coega Galvanising

Plant cannot be quantified

25 It is unacceptable for ILISO to be using CDC maps (see

figure 9 ndash pg5-6) without these maps being referenced

accordingly particularly when it appears that a CDC map has

been used and then overlaid with features by an unknown

author (ie CASA steel site Port (where the boundaries

depicted are incorrect) and a North legend which is out of

keeping with the overall cartographic intent of the original

work

26 Figure 10 is not referenced appropriately and I believe that I

commented previously in respect to references to roads not

12042012

By email

Graham Taylor

(Spatial

Development

Manager -

Infrastructure

Development

CDC)

This has been rectified in the final version of the report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

12

IssueCommentQuestion Date

received Origin Response

yet built As a result Figure 10 is confusing and clarity needs

to be provided in terms of referencing In addition the Port

shape is irregular and similar to the comment above

27 I acknowledge the emergency preparedness and response

plan but please confirm that this includes pro-active routine

monitoring of storm water leaving your premises to verify that

your assumptions of clean storm water are correct

13042012

By post

Andrew Lucas

(Director

WRampU

Department of

Water Affairs)

Pro-active routine monitoring of stormwater leaving the premises

will be undertaken This has been explicitly emphasised in

chapter 8 of the draft EMP

28 Will portablechemical toilets be used during construction

29 What provisions have been made for storm water drainage

during construction

18042012

By

telephone

Department of

Water Affairs

Port Elizabeth

Chemical toilets will be used during construction

The Casa Steel site will be located at the corner of two roads

drainage of stormwater from the site will take place through the

roadsrsquo drainage system

From Lea September [mailtoleailisocom]

Sent 11 March 2011 0935 AM

To Wayne Poulton

Cc Terry Baker

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Wayne

An Environmental Impact Assessment (EIA) will be undertaken for this project during the

next 10 to 12 months

We foresee that some of the key environmental impacts of the project will be in terms of air

quality water quality waste and hazardous substances

At this stage I am not able to give you any details regarding the potential toxicity of the

emissions andor effluent However specialist studies will be conducted as part of the EIA

that will determine the key impacts of the project Mitigation measures will also be identified

to avoid minimise or compensate any significant impacts

You are registered on the stakeholder database and you will be kept informed of progress in

the EIA process you will notably get the opportunity to access the reports produced and

provide any feedback on them

Please feel free to contact me should you need any further information

Best regards

Lea September

From Wayne Poulton [mailtowaynepbosuncoza]

Sent 07 March 2011 1257 PM

To Lea September

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

Please can you provide me with some more information as to the potential dangers including

the toxicity of this

Kind regards

Wayne

From Lea September [mailtoleailisocom]

Sent 04 March 2011 1123

To Lea September

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 March 2011 0745 AM

To Paul Martin

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 05 April 2011 0847 AM

To Paul Martin

Cc Terry Baker Renee von Gruenewaldt

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Thank you Paul for this information

I have downloaded a copy of the RoD and Scoping report you referred to and will make sure

these requirements are taken into account in the environmental assessment

Best regards

Lea September

From Paul Martin [mailtopmartinaxxesscoza]

Sent 04 April 2011 0955 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Further to my comments on 27311

Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in

the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega

IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised

scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions

including prohibiting and monitoring where possible visible emission plumes to the atmosphere

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Paul Martin

Sent Monday March 28 2011 745 AM

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 10 May 2011 0327 PM

To ElliotMotsoaholetransnetnet

Cc Terry Baker

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Mr Motsoahole

Thank you for your input on this issue

The Port of Ngqura will indeed be used for import and export At the moment the scope of

the traffic impact assessment only covers road traffic I have however relayed the matter to

our traffic specialist and we will consider this issue in the finalization of the Scoping Report I

will keep you informed of any developments in that regard

I trust this is acceptable to you

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]

Sent 10 May 2011 0855 AM

To Lea September

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

It has been noted that Casa Steel will source steel coils from various markets internationally and

in South Africa and the bulk of the plantrsquos production output will be exported to African countries

However there is no mention of logistic requirements

Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will

be used the scope of traffic impact assessment should also include the port

Regards

From Lea September [mailtoleailisocom]

Sent 04 May 2011 0747 AM

To Lea September

Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

Please find attached a letter announcing the EIA process underway for the proposed 80 000

tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as

a Background Information Document (BID) outlining the details of the project

Please contact me should you require any further information on this project

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

Elliot Motsoahole

Manager - Environment

Transnet National Ports Authority

Port of Nqqura

Port Control Building Klub Road Port Elizabeth 6212

PO Box 612054 Bluewater Bay 6212

+27 41 507 8450

+27 86 674 7729

Cell +27 83 542 5619

E-mail Elliotmotsoaholetransnetnet

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

DISCLAIMER The information contained in this communication is subject to copyright and

intended only for the use of leailisocom Unauthorised use disclosure or copying is

strictly prohibited Should a virus infection occur as a result of this communication the sender

will not be liable If you have received this communication in error please notify

elliotmotsoaholetransnetnet

From Lea September [mailtoleailisocom]

Sent 25 May 2011 1147 AM

To Jack Landile (ELS)

Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi

Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Landile

Thank you for your input

Contact has been made with the relevant Municipal Directorate and we will follow up with

them to obtain clarifications on all these issues

I have added both Lizna and yourself on the database and will keep you updated on

progress on this project

Best regards

Lea September

From Jack Landile (ELS) [mailtoJackLdwagovza]

Sent 24 May 2011 0524 PM

To Fourie Lizna (ELS)

Cc Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Hi Lizna

I missed you on this sorry

I linked Pieter twice Instead

Regards

Landile

From Jack Landile (ELS)

Sent 24 May 2011 0445 PM

To leailisocom

Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Lea

The e-mail you sent to Mr Kooverji dated 19 May 2011 refer

Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are

All steel sheets bathing unit must be under roof

The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project

Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal

Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer

Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality

Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines

Of note is the low volume of the proposed WWTW facility ie 250 cubmweek

And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles

generation

Regards

Landile

From Lea September [mailtoleailisocom]

Sent 19 May 2011 0947 AM

To Lea September

Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Stakeholder

Please find attached the remaining appendices to the draft Scoping report for the proposed

80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 June 2011 0411 PM

To Aphiwe Bewana

Subject RE Proposed 80 000 TPY Galvanizing plant in Coega

Dear Mr Bewana

Thank you for your input and apologies for the late reply

We have taken note of your comments and are will be taking them forward in the EIA phase

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Aphiwe Bewana [mailtoaphiwebewanagmailcom]

Sent 31 May 2011 1205 PM

To Lea September

Subject Re Proposed 80 000 TPY Galvanizing plant in Coega

Comment

Re Proposed 80 000 TPY Galvanizing plant in Coega

As SANParks we would like the EIA phase to investigate the potential effects of toxicity

andor influence of emissions waste and hazardous substances both in terrestrial and

marine fauna In the draft scoping report reference has been made with regards to the

terrestrial fauna but there is no attention to potential effects to marine fauna

Equally with regards to water usage where is the plant going to extract its waters used in

galvanization andor waste management process ie rainfall rivers or even from the sea)

and which avenues would be more environmental friendly and effective

Regards

Aphiwe Bewana

Marine Planner

South African National Parks

POBox 76693

NMMU

Port Elizabeth

6031

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 06 July 2011 1031 AM

To Lea September

Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Hi Lea

Irsquove reviewed the Final Scoping Report Herewith a few comments

1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the

Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a

revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the

NMBLP Please include only those in the IDZ as part of your IAP list

Regards

Andrea

From Lea September [mailtoleailisocom]

Sent Wednesday July 06 2011 859 AM

To Lea Septemberrsquo

Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Dear Stakeholder

The final scoping report for the above-mentioned project (attached) is available for comment

until 27 July 2011

The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic

commentaryrdquo tab

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 09 April 2012 1159 AM

To Lea September

Subject Comments on Galvanising Plant EIR Coega IDZ

Lea

Attached are my comments on the Draft EIR for the Coega IDZ galvanising

plant

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

Email attachment

COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ

Dr Paul Martin PO Box 61029

Bluewater Bay 6212 Tel 041 4665698

Email pmartinaxxesscoza

Compliance with CDC Permits amp Requirements

It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of

o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants

Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC

Air Emissions

Presumably permanent in stack monitoring will be required in terms of AEL permit requirements

Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions

Water

Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)

General

There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)

Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards

Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter

All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 11 April 2012 1245 PM

To Lea September

Subject Fw Comments on Galvanising Plant EIR Coega IDZ

Lea

One other comment on that I have on the Galvanising Plant Draft EIR

Hydrogen chloride is one of the main emissions There are no ambient air

quality guidelines for HCl and the EIR says concentrations will be well

within health parameters

However the main problem with HCl is its corrosive effect - there is

absolutely no mention of this in the draft EIR nor air specialist report

There needs to be some sort of comment assessment as to whether HCl

emissions are likely to impact on for example the adjacent Agni-Steel

Plant wrt corrosion - their factory structure will be made of steel

The EIR specialist rpt suggests monitoring HCl at ground level on the

property boundary and this is supported in case there are complaints from

neighbours

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Paul Martin ltpmartinaxxesscozagt

To Lea September ltleailisocomgt

Sent Monday April 09 2012 1158 AM

Subject Comments on Galvanising Plant EIR Coega IDZ

gt Lea

gt

gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising

gt plant

gt

gt

gt Dr Paul Martin

gt PO Box 61029

gt Bluewater Bay 6212

gt Tel 041 4665698

gt Cell 0732524111

gt email pmartinaxxesscoza

gt

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 12 April 2012 1139 AM

To Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Hi Lea

Hope yoursquore keeping well

I have requested comments from my colleagues and the CDC Casa team on the Draft EIR

Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report

Regards

Andrea

From Graham Taylor

Sent Thursday April 12 2012 838 AM

To Andrea Von Holdt Firhana Sam

Cc Johan Fourie Maria van Zyl Melikhaya Sihawu

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Andrea Firhana

Firhana if you could please ensure that the co-ordinates provided in the EIR correspond

with our records (pages 4-1 amp 4-2)

My comments are as follows

It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work

Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above

Regards

Graham Taylor

Spatial Development Manager - Infrastructure Development

Mobile 0832283055

Office 0414030454

Facsimile 0865185033

Email GrahamTaylorcoegacoza

Website wwwcoegacom

right PLACE | right TIME | right CHOICE

This email and all contents are subject to the following disclaimer

httpwwwcoegacomemaildisclaimerhtml

From Lea September [mailtoleailisocom]

Sent 04 May 2012 0411 PM

To Andrea Von Holdt

Cc Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Dear Andrea

We have taken note of the comments from the GIS Unit These issues have been rectified in

the final version of the EIR

Please can you forward to the relevant persons at the GIS Unit

Thank you

Best regards

Lea September

APPENDIX E

BACKGROUND INFORMATION

DOCUMENT

APPENDIX F

AIR QUALITY IMPACT ASSESSMENT

APPENDIX G

TRAFFIC IMPACT ASSESSMENT

APPENDIX H

WASTE MANAGEMENT AND HAZARDOUS

SUBSTANCES SPECIALIST STUDY

APPENDIX I

WATER QUALITY SPECIALIST STUDY

APPENDIX J

ENVIRONMENTAL MANAGEMENT

PROGRAMME

Page 5: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 iii

Figure 10 Trip distribution for freight and personnel trips 5-8

Figure 11 Morning peak hour Casa Steel development traffic 5-9

Figure 12 Casa Steel organisation chart 5-10

LIST OF TABLES

Table 1 Coordinates of site corners for the proposed galvanizing plant 4-1

Table 2 Hazardous materials to be used on site 5-4

APPENDICES

APPENDIX A List of registered stakeholders

APPENDIX B Notice of AEL application and advertisements

APPENDIX C Notice of comment period for draft scoping report

APPENDIX D Summary of issues raised and responses thereto

APPENDIX E Background Information Document

APPENDIX F Air Quality Impact Assessment

APPENDIX G Traffic Impact Assessment

APPENDIX H Waste Management and Hazardous Substances specialist study

APPENDIX I Water Quality Specialist Study

APPENDIX J Environmental Management Programme (EMP)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 iv

ACRONYMS

AEL Atmospheric Emissions Licence

BID Background Information Document

CCA Custom Controlled Area

CDC Coega Development Corporation

DEA Department of Environmental Affairs

DEDEAT Department of Economic Development Environmental Affairs and Tourism

DWA Department of Water Affairs

EAP Environmental Assessment Practitioner

EIA Environmental Impact Assessment

ELC Environmental Liaison Committee

EMP Environmental Management Programme

GN Government Notice

IampAPs Interested and Affected Parties

IDZ Industrial Development Zone

LNG Liquid natural gas

masl Meters above sea level

MSDS Material Safety Data sheet

NEMA National Environmental Management Act

NEMBA National Environment Management Biodiversity Act (No10 of 2004)

NMBM Nelson Mandela Bay Municipality

OSMP Open Space Management Plan

PoS Plan of Study

SAHRA South African Heritage Resources Agency

TNPA Transnet National Ports Authority

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 v

EXECUTIVE SUMMARY

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone

(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province

Galvanizing consists of coating steel with zinc in order to protect it from corrosion An

Environmental Impact Assessment (EIA) is required as the proposed project involves several

activities listed in terms of Section 24 of the National Environmental Management Act

(NEMA) 107 of 1998 as amended and requires an environmental authorisation The

project also involves activities listed in terms of the National Environmental Management Air

Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008

which respectively require an Atmospheric Emissions Licence and a Waste Management

Licence

The Scoping and Environmental Impact Assessment process underway covers all aspects of

the project and informs all three applications

Scoping was the first phase of investigations and aimed to inter alia identify potential key

environmental issues and impacts to be addressed in the EIA phase

The following environmental issues and potential impacts identified in the Scoping Phase

were investigated in the EIA

Air quality

The galvanizing process generates atmospheric emissions which are regulated in terms

of the National Environmental Management Air Quality Act and appropriate measures

are required in order to adhere to the applicable standards Other sources of impact on

air quality include emissions from the LNG burner emissions and dust from the transport

of steel and other materials in trucks as well as dust and gas emissions related to

construction activities Mitigation measures recommended in the EMP will ensure that air

quality impacts are kept to a minimum and compliance with emissions standards is

maintained

Biodiversity and conservation

Certain types of vegetation in the IDZ are of high conservation importance Protected

species will be rescued as per the CDCrsquos requirements

Water quality

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through spills

or leaks This risk can however be minimized if not avoided altogether through design

choices (bunded areas) and the adherence to best practice guidelines for the handling or

the transport of hazardous substances and waste

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vi

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

Waste management and hazardous substances

The plant will generate a relatively small amount of solid waste which will be re-used

recycled or disposed of in accordance with the EMP recommendations

There will be a wastewater treatment plant on site which will neutralise process water

(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer

Hazardous waste from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site

at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and

removed on a monthly basis is limited to 10 m3

A number of substances classified as hazardous are used in the galvanizing process and

the transport and handling of these is subject to certain rules and guidelines

In addition the permanent storage of a high quantity of liquid petroleum on site (20 000

litres at any one time) is subject to certain specifications and requires approval from the

municipality

Health and safety

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling of the various substances used will be done in

accordance with applicable instructions (cf material safety data sheets)

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as provide

site supervision including executing tests (individual test cold run and hot run) during 3

months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the EMP

Traffic

In the operational phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and from

the Port of Ngqura

The traffic expected to be generated during construction as well as operation is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low and

the total traffic generated by Casa Steel is also relatively low

The impact on port traffic is also negligible and well within the portrsquos capacity

Socio-economic aspects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vii

The proposed galvanizing plant will make a positive contribution by creating jobs during

construction and operation and generating business for the various service providers

Fatal flaws

No fatal flaws have been identified

The significance of these potential key environmental impacts were assessed in the EIA

phase and the findings of this phase of investigations are presented in this report

The main findings of the EIA are as follows

During construction impacts post-mitigation are low with the exception of noise and

biodiversity as the construction of the plant will result in the destruction of habitat

and loss of fauna and flora and noise impacts inherent to construction activities

Mitigation measures have been included in the EMP for these impacts and they have

a medium significance post-mitigation

All impacts were assessed as low during operation after mitigation

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium

to long term similar impacts are likely to occur due to ongoing developments in the

IDZ

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

The CDC has its own requirements regarding the monitoring of certain aspects of the

project such as the quality of the effluent and the noise levels These have been

incorporated into the EMP Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as other

infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified and

assessed No fatal flaws have been identified

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 viii

It is recommended that the project be approved subject to the conditions listed above

and adherence to the EMP recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-1

1 INTRODUCTION

11 BACKGROUND

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)

Nelson Mandela Bay Municipality Eastern Cape Province

The demand for galvanised steel products is high in South Africa and Africa and is

expected to increase in the foreseeable future From an economic point of view the

proposed project has therefore been found to be viable

Casa Steel will source the steel coils from various markets internationally and in

South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is

destined to be exported mainly to African countries

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

An Environmental Impact Assessment (EIA) is required as the proposed project

involves several activities listed in terms of Section 24 of the National Environmental

Management Act (NEMA) No 107 of 1998 as amended and requires an

environmental authorisation

The following listed activities requiring environmental authorisation have been

identified

Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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 metres

Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped

land to industrial use greater than 1 ha but less than 20 ha in size outside an

urban area

Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any

process or activity requiring a license in terms of national or provincial legislation

governing the generation or release of emissions

Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5

hectares or more of vegetation where 75 or more of the vegetative cover

constitutes indigenous vegetation except where such removal of vegetation is

required for

(i) purposes of agriculture or afforestation inside areas identified in

spatial instruments adopted by the competent authority for

agriculture or afforestation purposes

(ii) the undertaking of a process or activity included in the list of waste

management activities published in terms of section 19 of the

National Environmental Management Waste Act 2008 (Act No 59

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-2

of 2008) in which case the activity is regarded to be excluded from

this list

(iii) the undertaking of a linear activity falling below the thresholds in

Notice 544 of 2010

Hot dip galvanizing is a listed activity in terms of section 21 of the National

Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires

an Atmospheric Emissions Licence (AEL)

In addition the treatment of wastewater with an annual throughput capacity of more

than 2000 m3 is a listed activity in terms of the National Environmental Management

Waste Act 59 of 2008 and requires a waste management licence

ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental

Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact

Assessment process in terms of section 24 of NEMA for the construction and

operation of the proposed galvanizing plant The EIA process covers all aspects of

the project and informs all three applications (for environmental authorisation waste

management licence and AEL)

13 PURPOSE OF THIS REPORT

This report builds on the scoping report submitted to the Eastern Cape Department of

Economic Development and Environmental Affairs (DEDEA) and the Nelson

Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It

describes the proposed project and presents the findings of the second phase of

investigations (EIA phase)

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT

PRACTITIONER (EAP)

The EIA was managed by Ms Terry Baker a certified Environmental Assessment

Practitioner with 20 years of working experience She has a MA in Environmental

Management and specialises in Environmental Impact Assessments and Project

Management She has been involved in a variety of different types of EIAs including

for water supply projects dams transmission lines roads and airports in South

Africa Botswana Uganda Lesotho and Mozambique She has been involved in

water resource management and public participation programmes on a number of

projects Terry has also been involved in the use of Geographic Information Systems

environmental status quo reports water quality assessments socio-economic and

institutional development projects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-3

15 PROJECT TEAM

In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen

(water quality specialist) and Lea September (EAP) with specialist input from Renee

von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous

substances) and Seniel Pillay (Traffic Impact Assessor)

The Business Unit Head of the ILISO Environmental Management Discipline Group

Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is

a Fellow of the South African Institution of Civil Engineers a member of the South

African Society of Aquatic Scientists of the Environmental Scientific Association of

the International Water Association of the Water Institute of South Africa and of the

Vaal River Catchment Association He is a certified Environmental Assessment

Practitioner with 30 years experience who specialises in project management

environmental impact assessments and water resource planning He specifically has

extensive experience in water quality especially water quality management water

quality monitoring and water quality assessment Martin has experience in managing

projects that involve multi-disciplinary teams and public consultation and

participation in South Africa and abroad

Lea September is an Environmental Assessment Practitioner with a Masters degree

in Environmental Management She has experience in impact assessment and

environmental management and has been responsible for drafting impact

assessment reports and Environmental Management Programmes and conducting

public participation processes as well as high level environmental screenings for a

variety of projects in the energy water transport and industrial sectors

Renee von Gruenewaldt has nine-years experience in the field of air pollution

impact assessment and air quality management Prior to becoming involved in air

quality consultation she was part of the Highveld Boundary Layer Wind Research

Group based at the University of Pretoria Since joining Environmental Management

Services (the company now Airshed Planning Professionals) she has undertaken

numerous air pollution impact studies and has provided extensive guidance to both

industry and government on air quality management practices

Pieter Smuts graduated as a Civil Engineer and became involved in the field of

municipal engineering and infrastructure construction He has specialized during the

last twelve years in solid waste management He has completed waste management

plans feasibility studies and final designs of waste management facilities in South

Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and

the review of the Mavoco hazardous waste landfill design in Maputo Mozambique

and completed a study on hazardous waste (textile factory sludge) management in

Maseru Lesotho

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-4

Seniel Pillay is a transportation engineer with over 16 years experience in

transportation planning and traffic engineering He has been involved in a wide

range of projects ranging from developing the Transport Operations Plan for the

FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System

for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller

traffic impact assessments for inter alia road improvement schemes Of particular

relevance to this project his experience includes Heavy Goods Vehicle Study for

eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact

Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash

Preliminary Transportation Assessment

16 STRUCTURE OF THIS REPORT

The proposed project and the alternatives considered are described in Chapter 2

Chapter 3 details the approach adopted for the EIA phase

The biophysical and socio-economic environment affected by the activity is described

in Chapter 4

The environmental impacts identified are discussed in Chapter 5

The EIA methodology is described in Chapter 6 and Chapter 7 presents the results

of the impact assessment

The environmental impact statement is presented in Chapter 8

Finally Chapter 9 spell out the conclusions and recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-1

2 DESCRIPTION OF THE PROPOSED PROJECT

21 TECHNICAL ASPECTS

211 The galvanizing process

Galvanizing consists of coating steel with zinc in order to protect it from corrosion

Before steel strips can be galvanized they undergo a pre-treatment in order to

ensure that the steel sheets are free from any surface oxides as they enter the

molten zinc coating Bath This is done by removing the oil from the steel sheets (in

the degreasing unit) and then removing the rust from the surface of the sheet (in the

pickling unit)

The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The

melting zinc on the strip surface will be cooled and solidified through air cooling in the

cooling tower

Finally the galvanised steel sheets are dipped into a water quenching tank in order to

further cool the sheets from about 150degC to 40degC

It is possible to make galvanised steel more durable by chromating it Approximately

50 of the galvanised steel production output will receive chromate passivation

treatment after quenching the galvanised steel sheets will be sprayed with a chrome

solution (3 kgcm2)

After galvanizing and chromating the steel sheets are cut to achieve the desired coil

size and weight and transported to the storage yard

The process flow diagram below (Figure 1) illustrates the main stages of the

galvanizing process and indicates the major inputs and outputs as well as the

resulting effluent and atmospheric emissions

Draft Environmenal Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-2

Figure 1 Process flow diagram for proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-3

212 Main inputs and outputs in operational phase

In view of the above the main inputs will be as follows

Steel coils 85 000 tonsyear

Zinc 870 tonsyear

Electricity 2500 kVA

Water 2000 m3month (of which 400 m3 will be potable water)

Liquid Natural Gas (LNG) 270 NM3hour

Sodium hydroxide (NaOH) 1000 m3year

Hydrochloric acid (HCl) 800 m3year

Chrome (Cr+3) 10 m3year

The main outputs will be

Galvanized steel 80 000 tonsyear

Scrap metal 20 tonsyear

General waste 65 tonsyear

Hazardous waste 2 m3month

Wastewater 012 Mlweek

Atmospheric emissions lt 5 ppm

213 Installations on site

The bulk of the operations involved in the galvanizing process occur along a

continuous galvanizing line (See Figure 2 below) which is the main piece of

machinery required for the proposed galvanising plant

Figure 2 Continuous Galvanizing Line

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-4

Water is one of the major inputs and is used throughout the galvanizing process notably

for rinsing and cooling purposes and as a mixing agent for the various chemical

solutions The plant will have a water treatment plant on site to treat the water used in

the various processes (approx 250 m3

of wastewater per week) The wastewater

treatment facility will be operated by a professional water treatment company as Casa

Steel does not have the required expertise in house to treat its process water Sulphuric

acid (H2SO4) is used as part of the treatment process to reduce caustic soda The

neutralised water is discharged to the sewer while any sludge is disposed of as

hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)

will be disposed of

Some critical areas of the galvanizing process such as the zinc pot require uninterrupted

power It is therefore proposed to install an LNG burner to maintain the zinc bath at a

temperature of between 450 and 460degC

22 LOCATION OF THE PROPOSED GALVANIZING PLANT

The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast

of Port Elizabeth in the Eastern Cape (Figure 3)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-5

Figure 3 Location of the proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-6

23 NEED AND DESIRABILITY

The profitability of the proposed project has been established by Casa Steel and a

pre-feasibility study has confirmed that the proposed project was feasible from a

technical and financial point of view The Coega IDZ is specifically designed to host

facilities such as a galvanizing plant and can provide the necessary infrastructure

and services to its investors It therefore constitutes a very suitable location for the

project

24 ALTERNATIVES IDENTIFIED

Zone 6 has been specifically earmarked for heavy ferrous metal industries and is

therefore a suitable location for the proposed galvanizing plant as such no site

alternatives have been provided for and assessed in this EIA However prior to the

commencement of the EIA process Casa Steel was presented with a number of

different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the

selection of the site were

(a) The dimensions of the land the site should be at least 200 m long and

50 m wide in order to accommodate the galvanizing line and adjacent lay

down area and additional land should be available next to the site for future

expansion

(b) The fiscal arrangements applying to the site the site should be located

within the future Custom Controlled Area (CCA) as the bulk of the

production output of the plant will be exported

The no-go alternative is assessed in this report

25 CONSTRUCTION ASPECTS

The construction phase of the project will take about 12 months and will essentially

consist of erecting a building to house the galvanizing line and other equipment and

preparing a concrete laydown area adjacent to the building

The CDC will provide an access point from the existing tarred road that will lead to

the site

Approximately 100 workers from the surrounding areas will be contracted for the

construction work

The requirements in terms of services during construction are listed below

Water 1000 m3month

Electricity 2500 kVA

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-7

The CDC will provide temporary services for the construction phase including a

conservancy tank for flush toilets Sewage infrastructure will only be provided for the

operational phase

26 OPERATION ASPECTS

Before the plant can become fully operational the equipment and machinery will be

tested for approximately 3 months The supplier will supervise these tests as part of

the transfer of know-how and training of staff on the plant

Casa Steel will start operating the plant at a reduced capacity (about 50 000

tonsyear) for a period of time (mostly determined by market aspects) before bringing

production to full capacity (80 000 tonsyear) This is done by operating the line for

longer hours

Approximately 50 to 60 people will be working on the plant Approximately 6-10 of

these will be unskilled 40-45 skilled and about 5 people in managerial positions

The requirements in terms of services during operation are as follows

Water 2000 m3month

Electricity 2500 kVA

Effluent discharge 24 m3day

The CDC has entered into agreements with the municipality to secure the provision

of services such as water and electricity to its tenants Tenants in the IDZ have their

own agreements with the NMBM for electricity while the agreements for water and

sewage are with the Facilities Unit of the CDC

Regarding discharge of wastewater to the sewer the municipality indicated that the

only requirement is that the water discharged complies with applicable municipal

discharge standards

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 3-1

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT

31 OBJECTIVES

The main objectives of the EIA phase are to

Assess the significance of the environmental issues and impacts identified in the

scoping phase focusing on key impacts

Recommend appropriate measures to mitigate negative impacts and enhance the

benefits and include them in the draft EMP

Undertake a public participation process that provides opportunities for all

interested and affected parties (IampAPs) to be involved

32 AUTHORITY CONSULTATION

The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental

Liaison Committeersquo (ELC) which comprises representatives of various authorities

including DEDEAT the Department of Environmental Affairs (DEA) and Department

of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the

Coega Development Corporation (CDC) and Transnet National Ports Authority

(TNPA) The ELC has been specifically formed to facilitate EIA applications in the

IDZ

Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to

the clearance of vegetation should be included in the application A formal request

was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the

application and all registered stakeholders were informed of the request in writing on

19 October 2011

33 PUBLIC PARTICIPATION PROCESS CONDUCTED

On-site notices were replaced by a notification displayed on the CDCrsquos digital notice

board at the business centre in Zone 1 of the IDZ The eNotice was placed on

13 April 2011 and will remain for the full duration of the EIA process

Registered stakeholders will be notified in writing of the availability of the draft EIA

report and EMP which will also be advertised in a local newspaper Stakeholders

including state departments and the public will have forty (40) days to comment on

the draft EIA report and EMP The draft EIA report and EMP will be sent by email

where possible and made available for download on the ILISO website

(wwwilisocom)

A summary of all issues and comments received during the stakeholder consultation

process as well as of correspondence in that regard will be captured in an Issues

and Responses Report that will form an Appendix to the EIA Report

The list of registered IampAPs is included in Appendix A

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 3-2

34 LEGISLATION AND GUIDELINES CONSIDERED

The following legislation and guidelines were considered in the preparation of this

report

National Environmental Management Act Act No 107 of 1998

NEMA EIA Regulations 2010

National Environmental Management Air Quality Act Act No 39 of 2004

National Environmental Management Waste Act Act No 59 of 2008

Hazardous Substances Act Act 15 of 1993

Occupational Health and Safety Act Act 85 of 1993

Hazardous Chemical Substances Regulations 1995 (GNR 1179)

Major Hazard Installation Regulations 2001 (GNR 692)

National Water Act Act 36 of 1998

National Heritage Resources Act Act 25 of 1999

DEAT Integrated Environmental Management Information Series 1-5 and 12-15

NEMA draft Implementation Guideline

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Public Participation (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Alternatives (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Draft Guideline for Determining the Scope of Specialist

Involvement in EIA Processes (2005)

IAIA guidelines

National air quality standard for thoracic particulates Government Gazette

No 32816

Listed activities and associated minimum standards identified in terms of section

21 of the National Environmental Management Air Quality Act Act No 39 of

2004 Government Notice 248 of 2009

Minimum Requirements for the Handling Classification and Disposal of

Hazardous Waste DWAF Waste Management Series (1998)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-1

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION

The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega

IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay

to the north of the N2 highway between Port Elizabeth and Grahamstown east of the

Coega River

The co-ordinates of the corners of the site are shown in Table 1

Table 1 Coordinates of site corners for the proposed galvanizing plant

Point Longitude Latitude

A 25deg411126E 33deg45587S

B 25deg411156E 33deg45499S

C 25deg411938E 33deg45131S

D 25deg412174E 33deg45481S

E 25deg412508E 33deg45979S

F 25deg412634E 33deg451160S

G 25deg411782E 33deg451560S

H 25deg411692E 33deg451428S

J 25deg411314E 33deg45868S

Figure 4 Zone layout in the Coega IDZ

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-2

Figure 5 Site location

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-3

42 SOCIO-ECONOMIC CHARACTERISTICS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the

NMBM There are no residents within the IDZ

As far as the broader NMBM and Eastern Cape Province are concerned the

following can be noted The NMBM is located within the Eastern Cape Province the

2nd largest Province in South Africa (3rd in terms of population) characterised by a

predominantly black population with low incomes and high levels of unemployment

(CES 2010)

The NMBM has a population of just above 11 million and covers an area of

1 950 km2 It is the main urban and industrial centre of the province and Port

Elizabeth in particular which forms part of the NMBM is the commercial capital of

the Eastern Cape 52 of the NMBM population is female and 37 is below the

age of 20 these two groups are particularly affected by unemployment

43 BIOPHYSICAL CHARACTERISTICS

431 Surface and ground water

No rivers occur in Zone 6 There is however a natural attenuation pond on the

southern most part of the site which will have to be avoided

The IDZ is underlain by calcrete sand and gravel deposits that overlie low

permeability clays These clays limit the vertical infiltration of rainwater and induce a

horizontal groundwater flow towards the Coega River channel which is the most

significant surface water feature in the Coega IDZ Consequently rapid run-off takes

place following precipitation (Jacobs 2008)

Groundwater levels at Coega are generally about 3 to 5 m below surface ie just

above the contact between the permeable sands and the underlying impermeable

clays The groundwater flow direction is to the southeast following the surface water

drainage direction (Jacobs 2008)

432 Climate and atmospheric conditions

Port Elizabeth has a warm temperate climate and the temperature ranges are not

extreme Exceptionally high temperatures may be experienced during berg wind

conditions which occur frequently during autumn and winter Extreme temperatures

also occur during summer with little accompanying wind

The wind regime for the area largely reflects the synoptic scale circulation with

dominant westerly and northwesterly flow fields representing the pre-frontal

conditions and south-westerly flow fields representing the frontal conditions The

south-easterly and south-westerly wind flow (land breeze) increases during daytime

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-4

conditions with westerly and north-westerly wind flow increasing during the night (sea

breeze)

The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of

Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15

km southwest) and Port Elizabeth (~23 km southwest)

An ambient air monitoring network has been established in the Coega IDZ which

consists of three monitors Saltworks Motherwell and Amsterdamplein Although

NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative

impacts due to the proposed Galvanising Plant is PM10 A maximum daily average

PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed

SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3

was exceeded on 17 days in 2007 and 26 days in 2008

Existing sources of emissions in the vicinity of the proposed galvanizing plant include

industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other

fugitive dust sources (von Gruenewaldt 2011b)

433 Geology and soils

Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel

and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly

limestone and conglomerate

434 Terrestrial ecology

This section draws from the EIA report compiled for the Agni Steel (formerly Afro-

Asia) steel processing facility which is adjacent to the proposed site for the

galvanizing plant (Jacobs 2008)

The area consists largely of grasses succulents and scrubby bush with alien

species making up the greater part of the more dense vegetation

Zone 6 falls within the inland vegetation and is characterised by a vegetation type

referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the

Coega IDZ and has been found to have three times the level of endemism of other

vegetation communities in the Coega IDZ Bontveld therefore has a high

conservation status Two Bontveld conservation areas have been identified within the

IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)

Bontveld that will be destroyed as a result of development in the IDZ will be given

conservation status in these two areas

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-5

Figure 6 Coega IDZ Open Space Management Plan (OSMP)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-6

Certain areas in the IDZ are invaded by alien plant species The most common

invader species is rooikrans (Acacia cyclops) which presently forms large

monospecific stands in areas throughout the Coega IDZ There are several other

aliens present that pose a threat to the flora of this area including the prickly pear

(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)

Loss of vegetation and alien plant invasion due to human activity has resulted in a

reduction in the diversity of terrestrial fauna

The majority of mammals present in the Coega IDZ are small or medium-sized Of

the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed

gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of

Algoa Bay however it is not considered threatened The gerbil is common in

foredune and dune thicket habitat in the Coega region and is therefore unlikely to

occur on the proposed site

A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird

species are resident or common to the area Most diversity occurs in the thicket

although the coastal area also supports specialised avifauna Two species of tern

the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well

as the Cape gannet (Morus capensis) and the African penguin (Spheniscus

demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne

caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant

(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser

flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns

are two of the most endangered coastal species in South Africa Other bird species

of conservation concern include the Whitefronted plover (Charadrius marginatus)

African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus

bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus

ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides

paradisea) Breeding pairs of Damara terns and African black oyster catchers have

been observed in the coastal dunes of the IDZ but should not be affected by

developments that fall outside the dune areas

The Eastern Cape supports nearly a third (approximately 133 species) of the reptile

species recorded in South Africa More than half of the Eastern Capersquos endemic

reptile species occur in the Algoa Bay area giving the region a high conservation

value A total of 63 reptile species are believed to occur within the Coega IDZ The

majority of these are found in Succulent Thicket and riverine habitats Only a few

reptile species occur in the coastal dunes and estuarine habitats More than a third of

the species are described as relatively tolerant of disturbed environments provided

that migration corridors of suitable habitat are maintained to link pristine habitats

Twenty two reptiles are of special concern including five endemic species (two of

which may also be endangered) four endangered sea turtles eight species listed

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-7

with CITES one rare species and four species at the periphery of their range

Fourteen of these species of special concern are confirmed as occurring on or within

2 km of the Coega IDZ

A total of 32 amphibian species and sub-species occur in the Eastern Cape

representing almost a third of the species recorded in South Africa However none of

the species are endemic or Red Data Book species Based on previous studies in the

area it is estimated that approximately 17 amphibian species occur within the Coega

IDZ Four species are listed as peripheral but none are threatened internationally

These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog

(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and

the bubbling kassina (Kassina senegalensis)

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated

vegetation has not been extensively studied One grasshopper species Acrotylos

hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue

(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis

pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in

four localities in the Eastern Cape one of which is within the Coega IDZ The Coega

copper Aloeides clarki is endemic to this particular region of the Eastern Cape and

is currently known to occur in three localities two of which are in the Coega IDZ The

localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the

Coega IDZ and their distributions were taken into account when defining Coegarsquos

open space system and Development Framework Plan

435 Land use and topography

The land is currently undeveloped and earmarked for industrial development The

site is relatively flat ranging from an elevation of 66 masl on the northern-most

corner to 59 masl at the southern-most corner

436 Heritage and archaeological survey

Extensive studies have been undertaken in Zone 6 with respect to heritage aspects

Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a

2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond

2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is

currently being finalised

Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing

Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha

in extent and was located next to the R102 road to Motherwell Kaplan conducted

HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi

Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will

now be located in Zone 5)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-8

The various archaeological investigations reached similar observations and

conclusions Stone tools of various densities and types were found throughout the

zone The majority of the stone tools were mainly of Earlier and Middle Stone Age

and occasional Later Stone Age origins (Figure 4)

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble

gravels exposed by tracks in Zone 6 (Source Binneman 2010)

The stone tools which comprised of quartzite flakes chunks flaked pebblecobble

and cores were randomly distributed across the landscape and are in secondary

context There were no lsquoconcentrationsrsquo of tools observed which suggested any

spatial patterning or activity areas although these may be present or covered by soil

and vegetation

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 5-1

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED

The following environmental issues and potential impacts were identified in the

Scoping phase

51 AIR QUALITY

The galvanizing process generates atmospheric emissions with particulates and

hydrogen chloride representing the main pollutants of concern The plant is fitted with

air extraction as well as scrubber systems which are designed to retain the bulk of

pollutants and particles for each of the processes in such a way that less than 5 ppm

of gases and particles will be released into the atmosphere after the fume scrubber

Other sources of impact on air quality include emissions from the LNG burner as well

as emissions and dust from the transport of steel and other materials in trucks

Construction activities will also create dust and gas emissions due to the clearing of

groundcover tipping of material to storage pile levelling of area wind erosion from

storage piles vehicle and construction equipment activity and tailpipe emissions

from vehicles and construction equipment such as graders scrapers and dozers

Overall the air quality impact assessment (Gruenewaldt 2011b) found that

The predicted particulate oxides of nitrogen carbon monoxide and sulphur

dioxide concentrations are all below the National Ambient Air Quality Standards

for all averaging periods

The predicted off-site concentrations of hydrogen chloride are well below the

most stringent effect screening levels

No odour threshold exceedances for hydrogen chloride were predicted to occur

due to routine operations at the Steel Galvanising Plant The South Wales

Environmental Protection Authority stipulates that an odour unit of 20 is

acceptable for urban areas The odour unit would be lt10 directly off-site for

hydrogen chloride

Abnormal emissions can occur in exceptional circumstances Start-up will not

cause abnormal emissions as the scrubbers will be commissioned first and will be

functioning once the plant starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions would be emitted as a

building fugitive

The hourly hydrogen chloride ground level concentrations (directly offsite) were

predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based

on the emission limits as stipulated for listed activities for galvanising processes)

using a screen model which assumes worst case meteorological conditions The

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-2

health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming

abnormal emissions emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset conditions will still

be well within the health effect screening levels

Similarly the hourly particulate emissions from the building fugitives during upset

conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for

listed activities for galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly

off-site

Therefore if emissions are 5 times higher normal they will still be within health effect

screening levels and the daily PM10 NAAQS levels

In the case of a fire a cocktail of gases and particulates could be emitted and could

be over the recommended levels This situation will however be dealt with as an

emergency and normalised as quickly as is possible

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS

The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of

its heritage potential and there are no proposed protected geosites in Zone 6

Should any artefacts be discovered during construction procedures stipulated in the

draft EMP will apply

53 BIODIVERSITY AND CONSERVATION

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

In terms of terrestrial fauna the CDCrsquos open space management plan provides for

the preservation of certain corridors The destruction of certain habitats as a result of

the development will therefore not automatically result in the loss of certain species

54 WATER QUALITY

There is a natural attenuation pond on the southern most part of the site which will be

avoided

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through

spills or leaks

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-3

This risk can however be minimized if not avoided altogether The floor of the factory

will be designed as a bunded area to contain any spills and the entire process will be

contained Potential spills or leaks will therefore be contained and will not impact on

water resources Storm water is therefore considered clean water under normal

operational conditions An oil trap will be placed at the exit of the site to ensure that

no grease from the laydown area enters the stormwater system

Spills and leaks can occur during the handling or the transport of hazardous

substances Best practice guidelines will be followed to ensure that this risk is

adequately managed

Wastewater discharged to sewer will be treated to comply with municipal discharge

standards and is not expected to have an impact on the chemical characteristics of

the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be

discharged from the plant is small in relation to the total volume received at the

Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works

(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently

operated at 61 of its capacity which is approximately 80 Mℓday Thus the

0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore

not have any significant impact on the WWTW

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES

The plant will generate a relatively small amount of solid waste in the form of scrap

metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)

The scrap metal may be sold to other steel processing facilities such as Agni Steel

which will be located next to the plant or collected and disposed of with the rest of

the solid waste by a licensed service provider

As mentioned previously there will be a wastewater treatment plant on site which will

neutralise process water (012 Mlweek) in order to ensure it is of a standard

acceptable for discharge to sewer Waste in the form of sludge from the

neutralization or spent acid must be disposed of as a hazardous waste Solid waste

from the filters used for air quality control is also in this category These wastes can

usually be tested and then delisted which means that it can be placed in a general

purpose landfill

Hazardous effluent from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-

site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored

and removed on a monthly basis is limited to 10 m3

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-4

A number of substances classified as hazardous are used in the galvanizing process

(Table 2) and the transport and handling of these is subject to certain rules and

guidelines In particular the material safety data sheets (cf Appendix H) should be

referred to for inter alia hazards identification accidental release measures

handling and storage precautions exposure controlpersonal protection ecological

information and transport information The Hazardous Chemical Substances

Regulations 1995 should also be adhered to in respect of the transport and storage

of hazardous chemical substances

Table 2 Hazardous materials to be used on site

Major Input Materials

Substance

listed in the

SABS 0228

Group II

hazardous

substances

Volumes to be

stored on site at

any one time

Diesel radic 2000 litres

Liquid petroleum radic 20 000 liters

Sodium hydroxide (NaOH)

(used for degreasing) 8 radic 1000m

3

Hydrochloric acid (HCI)

(used for pickling) 8 radic 800m

3

Zinc (used for galvanising) - TBD

Trivalent chromium (CR+3

)

(used for chromating) 8 radic 10m

3

Sulphuric acid (H2SO4) (used for

treatment of waste water on site) 8 radic TBD

Ammonium Hydroxide (NH4OH) 8 radic TBD

TBD ndash To be determined

Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one

time) and is classified as a flammable substance Specification for flammable storage

facilities in accordance with the requirements of the Nelson Mandela Bay

Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for

quantities between 5000 and 20 000 liters the substance must be kept in a

flammable liquid store which complies with the requirements of a specification

obtainable from the Department Some of the requirements are

Flammable liquid and solid storage facilities are only permitted on the ground

floor

Decanting of flammable liquids and solids are not permitted within any building

Due to the fact that there are flammable materials on site a certificate may be

required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and

Emergency Services Department to confirm that facilities for flammable storage

are in accordance with their requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-5

Because of the permanent installation and high quantity of liquid petroleum on site

the Major Hazard Installation Regulations 2001 promulgated under the Occupational

Health and Safety Act No 85 of 1993 applies A written application for approval of

the installation is required to be submitted to the chief inspector Department of

Labour provincial director Department of Labour and NMBM prior to construction

In addition a risk assessment should be formulated covering all hazardous materials

together with an emergency preparedness and response plan

56 HEALTH AND SAFETY

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling instructions as well as occupational exposure limits

are indicated in the material safety data sheets of the various substances used

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as

provide site supervision including executing tests (individual test cold run and hot

run) during 3 months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the

EMP

In addition the emergency preparedness and response plan will cover the health and

safety aspects related to emergency situations

57 TRAFFIC

The volumes of traffic at the IDZ are currently relatively low and variable depending

on the different zones in the IDZ however these volumes will increase as more

developments are implemented

The construction phase of the Casa Steel development will take about 12 months

and will essentially consist of erecting a building to house the galvanizing line and

other equipment and preparing a concrete laydown area adjacent to the building

The traffic that would be generated during the construction phase can be expected to

be less than the traffic that would be generated by the Casa Steel development when

it is fully operational

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-6

In the operation phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and

from the Port of Ngqura

The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the

Casa Steel development would be off Ring Road 1 The other roads of significance

for the Casa Steel development are the N2 Neptune Road MR435 and MR450

Access to the port is given by Neptune Road Road Link NEP-03 has not yet been

built

Figure 8 Coega IDZ road network identification

(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-7

Figure 9 Coega IDZ road network

Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No

01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-8

The distribution of freight trips is fixed as the majority of trips will be made between

the Port of Ngqura and the Casa Steel site With regard to personnel trips there are

various points of origins (the surrounding residential areas) that could be used by

staff going to the Casa Steel site The distribution of personnel trips is based on

existing traffic count information and is shown in Figure 10

Figure 10 Trip distribution for freight and personnel trips

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The resultant expected Casa Steel traffic assignment is shown in Figure 11

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-9

Figure 11 Morning peak hour Casa Steel development traffic

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The traffic that is expected to be generated by the Casa Steel development is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low

and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)

Consultation has taken place with Transnet Port Authority (TPA) to establish the

impact of the galvanizing plant operations on traffic inside the port The additional

ships entering and exiting the port of Ngqura as a result of the proposed development

will have a negligible impact on port traffic and TPA indicated that it would be well

within the portrsquos capacity

58 NOISE

Noise is not foreseen to be a significant issue insofar as the noise levels inside the

plant and at the boundary of the site will not exceed the limits prescribed by the CDC

Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels

during the day and 60 decibels at night

Mitigation of noise impacts will be addressed in the design of the noise-emitting

components of the plant and their enclosures

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-10

59 SOCIO-ECONOMIC ASPECTS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of

NMBM There are no residents within the IDZ

The direct socio-economic impacts of the proposed project are thus limited to the

employment generated by the project during construction and operation Job creation

remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)

and the IDZ and Port of Ngqura are expected to become a significant catalyst to the

economic growth of the Municipality and the region with current investments at

Coega creating more jobs and stimulating the economy

In this context the proposed galvanizing plant will make a positive contribution

towards the achievement of these goals

There will be 50 to 60 employees during operation phase distributed as follows

Figure 12 Casa Steel organisation chart

Even though a large part of the inputs will be imported and the bulk of the production

output will be exported there will be some positive impacts for the economy of the

region and of South Africa in general Notably the requirements of the plant for

water electricity waste collection and disposal waste water treatment and transport

for example will create business for the various service providers and have an

indirect impact on employment and fiscal revenues as a result

From a visual impact point of view it can be anticipated that the landscape in the IDZ

will be significantly affected over time by developments related to the establishment

of the port and various industries

HEAD ( WORKS )

MGR ( COMM) MGR ( ADMNHR ) Manager marketing

MANAGER OPERATION MANAGER MANAGER MANAGER Q C

AC FIN PUR ampSTORE

PPC SH-GALV SH-tech

SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF

1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO

JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF

2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO

WORKERS WORKERS 7NOS

15 7

RAW MAT amp

DESP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 6-1

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY

A description of the nature of the impact any specific legal requirements and the

stage (constructiondecommissioning or operation) will be given Impacts are

considered to be the same during construction and decommissioning The

significance of the potential impacts will be considered before and after identified

mitigation is implemented

The following criteria will be used to evaluate significance

Nature The nature of the impact will be classified as positive or negative and

direct or indirect

Extent and location Magnitude of the impact and is classified as

Local the impacted area is only at the site ndash the actual extent of the activity

Regional the impacted area extends to the surrounding immediate and

neighbouring properties

National the impact can be considered to be of national importance

Duration This measures the lifetime of the impact and is classified as

o Short term the impact will be for 0 ndash 3 years or only last for the period of

construction

o Medium term three to ten years

o Long term longer than 10 years or the impact will continue for the entire

operational lifetime of the project

o Permanent this applies to the impact that will remain after the operational

lifetime of the project

Intensity This is the degree to which the project affects or changes the

environment and is classified as

o Low the change is slight and often not noticeable and the natural functioning

of the environment is not affected

o Medium The environment is remarkably altered but still functions in a

modified way

o High Functioning of the affected environment is disturbed and can cease

Probability This is the likelihood or the chances that the impact will occur and

is classified as

o Low during the normal operation of the project no impacts are expected

o Medium the impact is likely to occur if extra care is not taken to mitigate

them

o High the environment will be affected irrespectively in some cases such

impact can be reduced

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 6-2

Confidence This is the level knowledgeinformation the environmental impact

practitioner or a specialist had in hisher judgement and is rated as

o Low the judgement is based on intuition and not on knowledge or

information

o Medium common sense and general knowledge informs the decision

o High Scientific and or proven information has been used to give such a

judgment

Significance Based on the above criteria the significance of issues will be

determined This is the importance of the impact in terms of physical extent and

time scale and is rated as

o Low the impacts are less important

o Medium the impacts are important and require attention mitigation is

required to reduce the negative impacts

o High the impacts are of great importance Mitigation is therefore crucial

Cumulative Impacts The possible cumulative impacts will also be considered

Mitigation Mitigation for significant issues is incorporated into the EMP for

construction

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 7-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS

71 IMPACTS DURING CONSTRUCTION

711 Air quality

Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris

handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine

particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural

operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks

and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)

Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Fugitive particulate emissions (dust)

related to construction activities Regional

Short

term Medium High High Medium Regional

Short

term Low High High Low

Construction vehicle gas emissions Regional Short

term Medium High High Medium Regional

Short

term Low High High Low

712 Heritage and archaeological resources

Naturedescription of impact excavation activities may impact on unidentified heritage resources

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-2

Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based

on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments

Heritage and archaeological

resources Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on unidentified heritage

resources Local

Short

term

Medium -

high Low High Low

713 Biodiversity and conservation

Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation

importance and cause soil contamination

Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species

Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan

and has compiled a list of protected species to be rescued (see draft EMP)

Biodiversity and conservation Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Loss of fauna and flora Local Perma

nent

Medium -

high High High High Local

Permanen

t Medium High High Medium

Soil contamination Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-3

714 Water related impacts

Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater

runoff spills and leaks Soil erosion

Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of

spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste

disposal Stormwater quality monitoring (see draft EMP)

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Soil erosion Local Short

term Medium Medium High Medium Local

Short

term Medium Low High Low

715 Waste management

Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed

Commentmitigation see draft EMP and waste management plan

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-4

Waste management Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Local

Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

716 Health and safety

Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Short

term

Medium -

high

Medium -

high High High Local

Short

term

Medium -

high Low High Low

717 Traffic

Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and

construction workers from surrounding areas and transport of equipment from the port

Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low

Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and

accurate estimates of quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-5

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Increased traffic on N2 and within the

IDZ Regional

Short

term Low High High Low

718 Noise

Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Short

term

Medium-

high High High Medium Local

Short

term Medium High High Medium

719 Socio-economic

Naturedescription of impact temporary employment will be created during the construction phase

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-6

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Temporary employment Regional Short

term Medium High High Medium

72 IMPACTS DURING OPERATION

721 Air quality

NatureDescription of impact gas and particulate emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning

Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local

sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and

veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute

to background fine particulate concentrations (von Gruenewaldt 2011b)

Assumptions and limitations Potential release of CR6+

As no emission factors are available for trivalent chromium processing the

potential impacts due to these activities could not be quantified

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Dust emitted from traffic on paved roads Regional Long Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-7

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

term

Hydrogen chloride emissions from

pickling process Local

Long

term Low High High Low

Particulate emissions (smoke) from

galvanizing process (due to the

volatilization of flux)

Local Long

term Low High High Low

Particulate oxides of nitrogen carbon

monoxide and sulphur dioxide emissions

from LNG burner

Local Long

term Low High High Low

Nuisance related to odour Local Long

term Low Low High Low

Abnormally high hydrogen chloride and

particulate emissions due to scrubber

malfunction

Local Short

term Medium Low High Medium

Gases (eg SOx NOx CO etc) and

smoke emitted in case of a fire Local

Short

term High Low High Medium

722 Water quality

NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks

Commentmitigation see draft EMP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-8

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Stormwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

723 Waste management and hazardous substances

NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous

waste both can affect environmental quality and human health

Commentmitigation see draft EMP and waste management plan

Waste management and hazardous

substances Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Regional

Long

term High

Medium -

high High High Regional Long term High Low High Low

Soilwaterair pollution due to improper

transport storage and handling of

hazardous substances

Regional Long

term High

Medium -

high High High Regional Long term High Low High Low

Health hazard Local Long

term High

Medium -

high High High Local Long term High Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-9

724 Health and safety

Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Long

term

Medium-

high

Medium-

high High High Local Long term

Medium-

high Low High Low

725 Traffic

Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on

the road network

Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak

hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road

network within Zone 6 of the IDZ (Iliso 2011)

Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)

Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of

quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-10

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on traffic and capacity of the N2 Regional Long

term Low High High Low

Impact on traffic and capacity of ring

road 1 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR435 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR450 Local

Long

term Low High High Low

Impact on traffic and capacity of

Neptune road Local

Long

term Low High High Low

726 Noise

Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Long

term Medium High High Medium Local Long term Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-11

727 Socio-economic

Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate

revenue for the municipality and the region as a whole

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Employment and economic growth Regional Short

term Medium High High Medium

73 COMPARATIVE ASSESSMENT OF IMPACTS

During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as

low during operation after mitigation

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 8-1

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

As a tenant operating in the IDZ Casa Steel will be required to comply with all

current and future CDC requirements as well as with the relevant conditions of

permits licences issued to CDC (eg Integrated Stormwater Masterplan for the

eastern side of the Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)

In particular the CDC has its own requirements regarding the monitoring of certain

aspects of the project such as the quality of the effluent and the noise levels These

have been incorporated into the EMP

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 9-1

9 ENVIRONMENTAL IMPACT STATEMENT

All predicted negative impacts can be mitigated to a low significance The only

exceptions are biodiversity as the construction of the plant will result in the

destruction of habitat and loss of fauna and flora and noise impacts inherent to

construction activities Mitigation measures have been included in the EMP for these

impacts and they have a medium significance post-mitigation

Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium to

long term similar impacts are likely to occur due to ongoing developments in the IDZ

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 10-1

10 CONCLUSION AND RECOMMENDATIONS

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as

other infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified

and assessed No fatal flaws have been identified

It is recommended that the project be approved subject to the conditions listed in

chapter 9 and adherence to the EMP requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 11-1

11 REFERENCES

Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ

Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants

Bennie JS (2010) The historical component (built environment) of the Heritage

Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port

Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report

compiled for Eastern Cape Heritage Consultants

Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater

Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay

Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage

Consultants

BKS (2006) Coega Industrial Development Zone Transport Study Volume 3

Demand Modelling Report Final Draft

Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I

Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6

Report compiled for SRK Consulting

Coastal amp Environmental Services (2010) Environmental Impact Assessment for the

Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone

Volume 3 Environmental Impact Assessment Report CES Grahamstown

Coega Development Corporation (2008) Industry Waste Management Plan -

Strategic Master Plan Report

Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants

Report No CDCSHE 03 8122

Department of Water Affairs and Forestry (1998) Waste Management Series

ldquoMinimum Requirements For The Handling Classification And Disposal Of

Hazardous Wasterdquo Second Edition

Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising

Plant in the Coega Industrial Development Zone

Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the

Coega Industrial Development Zone (IDZ) Specialist Water Study

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 11-2

Jacobs E (2008) Final Environmental Impact Report and Draft Environmental

Management Plan Proposed Steel Recycling and Processing Facility within the

Coega IDZ Report compiled for SRK Consulting

Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY

Galvanising Plant in the Coega Industrial Development Zone Waste Management

and Hazardous Substances Report compiled for ILISO Consulting

RSA National air quality standard for thoracic particulates (PM10) SA standards

(Government Gazette No 32816)

von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed

Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape

Report compiled for ILISO Consulting

von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel

Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report

compiled for ILISO Consulting

Additional sources

Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed

Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared

for Coastal Environmental Services

Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed

Kalagadi Manganese smelter in the Coega Industrial Development Zone Port

Elizabeth Eastern Cape Province Report prepared for Coastal Environmental

Services

Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia

steel recycling facility at the Coega Industrial Development Area Port Elizabeth

Prepared for SRK Consulting Port Elizabeth

APPENDIX A

LIST OF INTERESTED AND

AFFECTED PARTIES

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

DEDEARegional Manager

and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza

DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza

DEA Ocean and

CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza

DEA Ocean and

Coast

Oceanographer land-

based sources of

marine pollution

Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza

DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza

CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza

CDCEnvironmental

Project

Manager

Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza

TNPAPort of Ngqura

Environmental

Manager

Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet

NMBMEnvironmental

ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza

NMBMEnvironmental

ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza

DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza

DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza

WESSASenior Conservation

Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza

Zwartkops

ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700

hughlauegmailcom

zwartkopstrustiafricacom

SANParksNational Marine

CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza

Department Of

LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza

NMBM Air Quality

Division

Assistant

DirectorAir

Pollution and Noise

Templeton Titima 079 490 0574 Ttitimamandelametrogovza

NMBM Air Quality

DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza

NUMSARegional

RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

Department of

HealthNadiema

van der

Bergh083 378 2103

nadiemavanderberghimpiloecprovgov

za

DWA Chief Services

Officer

Joseph Jacobs 041 586 4884 jjacobsdwafgovza

EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza

NUMSecretary of union

officesZandile Xhentsa 043 743 6597 zxhentsanumorgza

DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza

Dynamic

CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom

EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza

Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza

UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom

lprincezago2uticom

Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza

Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza

Absa Mr Johann Steyn 082 3775820 johannstabsacoza

Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza

PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza

Universal

EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza

Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza

GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom

Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza

NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom

DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza

DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza

TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet

DWA Mr Landile Jack JackLdwagovza

DWA Ms Lizna Fourie FourieL4dwagovza

APPENDIX B

NOTICE OF ATMOSPHERIC

EMISSIONS LICENCE APPLICATION

AND ADVERTISEMENT

APPENDIX C

NOTICE OF COMMENT PERIOD FOR

DRAFT SCOPING REPORT

APPENDIX D

SUMMARY OF ISSUES RAISED AND

RESPONSES THERETO

April 2012

1

PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL

DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))

IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt

AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt

This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses

provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process

conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the

Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

2

IssueCommentQuestion Date

received Origin Response

1 Please provide more information with respect to the potential

dangers including the toxicity of the proposed project

07032011

By email

Wayne Poulton

(Bosun Brick

tenant at the

IDZ)

An Environmental Impact Assessment (EIA) was undertaken

which assessed the potential toxicity of the emissions and

effluent Mitigation measures were also recommended in the draft

Environmental Management Programme (EMP) to avoid

minimise or compensate any significant impacts The Draft

Environmental Impact Report and draft EMP were made available

to stakeholders for comment in March 2012

2 Do you have a Background Information Document (BID) or

similar that provides more information on the project

27032011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The BID was sent to all registered IampAPs on 4 May 2011

3 The RoD issued to the CDC on 632007 for the change in

land use for the remaining area of the Coega IDZ includes a

number of requirements with respect to

atmospheric emissions that should be considered in the

Atmospheric Emissions Licence (AEL) application such as

prohibiting and monitoring where possible visible emission

plumes to the atmosphere In particular the

recommendations on pp87-91 of the final revised Scoping

Report dated Nov 2006 must be implemented (clause 421)

04042011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

We have obtained copies of the documents referred to and ensure

that these requirements were taken into account in the

environmental assessment and AEL application

4 If the Port of Ngqura is used for import and export the scope

of the traffic impact assessment (TIA) should also include the

port

10052011

By email

Elliot

Motsoahole

(TNPA Port of

Ngqura)

The scope of the TIA was extended to include port related traffic

The TNPA at the Port of Ngqura was consulted and does not

have any objection to the project TNPA has indicated that the

development would require a minimum number of vessels per

year which would have minimal impact on the Port operations

However due notice would have to be given to the Port of Ngqura

before a vessel is scheduled to arrive so that the vessel can be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

3

IssueCommentQuestion Date

received Origin Response

accommodated at an available berth

5 Concerns with respect to potential stormwater pollution

draining into the Coega catchment and the port of Ngqura

The port needs to be dredged and heavy metals present a

risk in that regard

16052011

By

telephone

Andrew Lucas

(Department of

Water Affairs)

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination by effluent waste or

hazardousdangerous substances is very low

Thus no metals oils or other contaminants are expected to be

present in the stormwater

However stormwater pollution can occur in exceptional

circumstances such as accidents and emergencies The

emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

6 All steel sheets bathing unit must be under roof

7 The sludge out of the decreasing bath will be high in Na and

pH Therefore handling and disposal must be clarified up front

in this project

8 Per se the wastewater from decreasing bath will have high

ph and the component from the pickling unit will have low ph

Then it may be assumed that both streams will neutralize

each other Please then clarify proposed sewer discharge

with Nelson Mandela Bay Municipality up-front for acceptance

of influent as per the documented proposal

9 Pickling may result in dissolved metals How does your team

expect to deal with this As it is planned for discharge into

24052011

By email

Landile Jack

(Department of

Water Affairs)

All bathing units will be under roof

Effluent from the degreasing and pickling baths will be discharged

to the wastewater treatment plant The respectively alkaline and

acidic effluents will mix and neutralise each other in the

wastewater treatment plant Calcium or gypsum will be added if

required to complete the neutralisation process Effluent from the

treatment plant will be discharged to sewer Contact has been

made with the relevant officials and the Municipalityrsquos

requirements have been obtained The effluent discharged to

sewer will notably comply with the applicable discharge standards

Traces of metals (eg iron) may be present but will not exceed

prescribed thresholds The necessary authorisation will be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

4

IssueCommentQuestion Date

received Origin Response

sewer Clarity and acceptance needs to be agreed with

Nelson Mandela Bay Municipality Who owns the sewer

10 Quenching unit will results to Zinc particles How will this

affect sewer discharge This again must be dealt with within

the negotiations with the Municipality

11 Once all has been agreed with the Municipality and at the

same time due negotiations must be done with hazardous

waste courier and disposal facility to accept the hazardous

waste identified in all production lines

12 Of note is the low volume of the proposed WWTW facility ie

250 cubmweek And the no discharge of the quenching

water ie over-flow and cooling only Hence Zinc particles

generation

obtained from the municipality

The sludge from the treatment plant will be collected by a licensed

service provider and disposed of at a permitted site

The quenching bath will be periodically emptied (every 6 months)

and the water discharged will go to the water treatment plant Zinc

particles will settle in the sludge which will be disposed of at a

permitted site

Contact has been made with EnviroServ who manages the

Aloes II HH waste site regarding collection and disposal of

hazardous waste (See waste management report)

13 Investigate the potential effects of toxicity andor influence of

emissions waste and hazardous substances both in

terrestrial and marine fauna

14 With regards to water usage where is the plant going to

extract its waters used in galvanization andor waste

management process ie rainfall rivers or even from the

sea) and which avenues would be more environmental

friendly and effective

31052011

By email

A Bewana

(SANPARKS)

Emissions waste and hazardous substances are not expected to

affect terrestrial or marine ecosystems The air quality study

concluded that atmospheric emissions would not be harmful to

human health and by extension terrestrial fauna There are no

standards for air quality for defining faunal impacts therefore by

ensuring that standards for humans are complied with the impact

on fauna is deemed to be acceptable In this case the impact of

emissions on terrestrial and marine fauna are thus not significant

Solid and liquid wastes both general and hazardous as well as

hazardous substances will be stored handled and disposed of

appropriately to as not to cause harm to terrestrial or marine

fauna

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

5

IssueCommentQuestion Date

received Origin Response

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination and hence land-based

marine pollution by effluent waste or hazardousdangerous

substances is very low

The risk of emissions waste and hazardous substances to

terrestrial and marine fauna is thus very low

However pollution of terrestrial and marine ecosystems can occur

in exceptional circumstances such as accidents and emergencies

The emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

The CDC has an agreement with the NMBM to supply potable

water to the Coega IDZ Currently the infrastructure to supply

return effluent (RE) to the IDZ is not in place therefore Casa Steel

will be supplied with potable water up until such time as the

following 2 options of RE are available

1) Upgrading of the existing Fishwater Flats waste water

treatment works (between IDZ amp PE) including RE plant

and infrastructure to pipe RE to the IDZ (EIA for the

upgrade is underway)

2) Construction of a new waste water treatment works

including RE plant in Zone 9 of the Coega IDZ

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option should be investigated further between Agni and Casa The

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

6

IssueCommentQuestion Date

received Origin Response

CDC can facilitate discussions between the 2 investors

Compliance with CDC Permits amp Requirements

15 It should be made clear that tenants will be required to

comply with CDC requirements and the relevant conditions of

permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water

Licence for its Storm Water Systems on the

East Side of the Coega River that tenants will

need to take cognizance of The contents of the

ldquoIntegrated Stormwater Masterplan for the

eastern side of the Coega IDZ Oct 2010rdquo

especially the Table of best practice p53

onwards may need to be taken cognizance of

o CDC is developing an Operations

Environmental Management Plan that will place

certain obligations on tenants

16 Environmental audits and data collected during monitoring

(eg stack emissions stormwater) will need to be shared with

CDC

Air Emissions

17 Presumably permanent in stack monitoring will be required in

terms of AEL permit requirements

18 Abnormal operating conditions resulting in air emissions ndash I

could find nothing in the EIR to indicate under what

circumstances these could occur (eg start-up) potential

frequency and duration and the impact on ambient air quality

ndash these events usually result in the most problems wrt air

emissions

09042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

15 Compliance with the CDCrsquos Permits amp Requirements has

been included explicitly as a requirement in the EIR (p8-1) and

EMP (pp18 and 25) in the following terms

ldquoAs a tenant operating in the IDZ Casa Steel will be required to

comply with all current and future CDC requirements as well as

with the relevant conditions of permits licences issued to CDC

(eg Integrated Stormwater Masterplan for the eastern side of the

Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)rdquo

16 The need to communicate with the CDC on monitoring and

auditing activities was emphasised in Chapter 8 of the EMP The

following paragraphs were added

ldquoDuring construction the environmental officer will be responsible

for monitoring compliance with the EMP and authorisation

conditions and keeping records as required in the EMP andor

authorisation conditions

The ECO will conduct site inspections every two weeks audit the

records kept by the environmental officer and submit an

environmental compliance report every two months to the

authorities and the CDC (via the Environmental Monitoring

Committeersquos ECO)

During operation the health and safety officer will monitor

compliance with the EMP and the conditions of the Environmental

Authorisation Data collected during monitoring activities and any

environmental audits conducted will be shared with authorities

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

7

IssueCommentQuestion Date

received Origin Response

Water

19 Large volumes of (2000 m3mth) of water are required of

which only 400m3 needs to be potable The NMBM return

effluent system will provide non-potable water once it is

constructed What other water recycling initiatives can be

utilized to reduce potable water requirements (the ISWMP for

the eastern side of the Coega IDZ has some best practice

guidelines collecting rainwater from the roof etc)

General

20 There is no mention of how the CDC Architectural Guidelines

will be incorporated into the development (eg to prevent a

stark uniform warehouse type development)

21 Does NMBM have adequate fire services to cover this

development Apart from the large petroleum store are there

any other large fire hazards

22 Reports from the tenantrsquos ECO during construction and from

the SHE Officer during operations should be channeled to the

Coega Environmental Monitoring Committee This can be

directly or preferably via the EMCrsquos ECO (this will be while

the EMC and ECO are in place) A precedent has been set

for this in the Environmental Authorisations for Agni-Steel and

Kalagadi Manganese Smelter

23 All mitigation actions emanating from the EIR should be

summarized (preferably in a table) If compliance with them is

to be part of the Environmental Authorization from DEDEAT

then they (or the ones that DEDEAT deems to be applicable)

and the CDC (via the Environmental Monitoring Committeersquos

ECO)

The ECO (during construction) and the health and safety officer

(during operation) will report to the Coega Environmental

Monitoring Committee (EMC) via the EMCrsquos ECO (this will be

while the EMC and ECO are in place)rdquo

17 The draft EMP recommends regular monitoring of emissions

from the scrubbers and from the chromating process Additional

emissions monitoring requirements will be confirmed once the

AEL is issued Mention has been made in the EMP (pp11 and 19)

that all AEL conditions including monitoring and reporting

requirements should be adhered to

18 Abnormal emissions can occur in exceptional circumstances

Start-up will not cause abnormal emissions as the scrubbers

will be commissioned first and will be functioning once the plant

starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions

would be emitted as a building fugitive

The hourly hydrogen chloride ground level concentrations

(directly offsite) were predicted to be 239 microgmsup3 (based on the

emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits

as stipulated for listed activities for galvanising processes) using a

screen model which assumes worst case meteorological

conditions The health effect screening level for hourly HCl

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

8

IssueCommentQuestion Date

received Origin Response

should be attached to the EA as an Appendix (otherwise no

one knows about them or takes cognizance of them)

concentrations is 2100 microgmsup3 Assuming abnormal emissions

emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset

conditions will still be well within the health effect screening

levels

Similarly the hourly particulate emissions from the building

fugitives during upset conditions would amount to 293 microgmsup3

(based on the emission limits as stipulated for listed activities for

galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1

January 2015) directly off-site

Therefore if emissions are 5 times higher normal they will still be

within health effect screening levels and the daily PM10 NAAQS

levels

In the case of a fire a cocktail of gases and particulates could be

emitted and could be over the recommended levels This

situation will however be dealt with as an emergency and

normalised as quickly as is possible

The above has been added to the impact identificationdescription

and assessment sections of the EIR

19 The CDC has an agreement with the NMBM to supply

potable water to the Coega IDZ Currently the infrastructure to

supply return effluent to the IDZ is not in place therefore Casa

Steel will be supplied with potable water up until such time as the

infrastructure is in place

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

9

IssueCommentQuestion Date

received Origin Response

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option will be investigated further between Agni and Casa The

CDC has come forward to facilitate discussions between the two

investors

Other water recycling initiatives such as rainwater harvesting

have been considered but are not practical

20 The CDCrsquos Architectural and Landscape Design guidelines

contain requirements pertaining to such aspects as the height

orientation and mass and form of buildings as well as guidelines

for landscaping and signage in order to ensure an attractive

development and achieve an architectural integrity within the

Coega IDZ The plans for the proposed galvanizing plant will be

submitted to the Design Review Committee for approval as

required by the CDC

21 Casa Steel will be required to install fire hydrants according

to the NMBMrsquos standardsrequirements The CDC will provide

potable water (up until such time as return effluent is available)

and a connection to the boundary of the site which will be

connected to the fire hydrants The installation of the fire hydrants

will require approval by the Metrorsquos Fire Chief as was done for

Agni-Steel one of the investors in Zone 6

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

10

IssueCommentQuestion Date

received Origin Response

The Coega IDZ falls within the NMBM and therefore the rates and

taxes paid by the CDC covers the fire services for which the Metro

is responsible Currently the Metro has sufficient capacity to

provide fire services to the tenants within the IDZ This was

confirmed in discussion with the CDCrsquos Infrastructure

Development Unit It is however unknown at which point the

Metrorsquos Disaster Management Plan would not be able to

accommodate servicing tenants in the IDZ

The LNG burner is the only major fire hazard on the plant

22 See response to item 16 above

23 Key mitigation and management measures emanating from

the EIR were recapitulated in Chapter 9 of the EIR to form part of

the conditions attached to the Environmental Authorization from

DEDEAT All mitigation measures recommended as a result of the

impact assessment are presented in a table in the draft EMP

which is appended to the EIR (Appendix J)

24 Hydrogen chloride is one of the main emissions There are no

ambient air quality guidelines for HCl and the EIR says

concentrations will be well within health parameters

However the main problem with HCl is its corrosive effect -

there is absolutely no mention of this in the draft EIR nor air

specialist report

There needs to be some sort of comment assessment as to

whether HCl emissions are likely to impact on for example

the adjacent Agni-Steel Plant wrt corrosion - their factory

structure will be made of steel

11042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The atmospheric corrosion of metals is a complex process with

both the extent of deterioration and the mechanisms varying

considerably depending on the metal Depending on the way

pollutants are transported from the atmosphere to the corroding

surface two types of deposition processes are recognized in

atmospheric corrosion ndash dry deposition and wet deposition Wet

deposition refers to precipitation whereas dry deposition refers to

the remaining processes including gas phase deposition and

particle deposition The most important pollutants acting as

corrosive agents are sulphur and nitrogen compounds including

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

11

IssueCommentQuestion Date

received Origin Response

The EIR specialist rpt suggests monitoring HCl at ground

level on the property boundary and this is supported in case

there are complaints from neighbours

secondary pollutants and particulates Pollutants can contribute to

corrosivity individually however there may be a synergistic effect

when more than one of these pollutants is present in the

environment being affected In the field of atmospheric corrosion

sulphur dioxide is the single most investigated gaseous pollutant

and the quantification of the direct contribution of sulphur dioxide

to the corrosion process of metallic materials is comparatively well

understood (Tidblad amp Kucera 1998)

Very little work has reported on the effect of HCl on the

degradation of materials in the environment with no local dose-

response thresholds developed for corrosion occurring due to HCl

exposures This is probably because HCl which is present

outdoors in markedly reduced concentrations when compared

with SO2 has not been considered to contribute to significant

degradation of materials (Syed 2006) For this reason the

incremental corrosion due to HCl from the Coega Galvanising

Plant cannot be quantified

25 It is unacceptable for ILISO to be using CDC maps (see

figure 9 ndash pg5-6) without these maps being referenced

accordingly particularly when it appears that a CDC map has

been used and then overlaid with features by an unknown

author (ie CASA steel site Port (where the boundaries

depicted are incorrect) and a North legend which is out of

keeping with the overall cartographic intent of the original

work

26 Figure 10 is not referenced appropriately and I believe that I

commented previously in respect to references to roads not

12042012

By email

Graham Taylor

(Spatial

Development

Manager -

Infrastructure

Development

CDC)

This has been rectified in the final version of the report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

12

IssueCommentQuestion Date

received Origin Response

yet built As a result Figure 10 is confusing and clarity needs

to be provided in terms of referencing In addition the Port

shape is irregular and similar to the comment above

27 I acknowledge the emergency preparedness and response

plan but please confirm that this includes pro-active routine

monitoring of storm water leaving your premises to verify that

your assumptions of clean storm water are correct

13042012

By post

Andrew Lucas

(Director

WRampU

Department of

Water Affairs)

Pro-active routine monitoring of stormwater leaving the premises

will be undertaken This has been explicitly emphasised in

chapter 8 of the draft EMP

28 Will portablechemical toilets be used during construction

29 What provisions have been made for storm water drainage

during construction

18042012

By

telephone

Department of

Water Affairs

Port Elizabeth

Chemical toilets will be used during construction

The Casa Steel site will be located at the corner of two roads

drainage of stormwater from the site will take place through the

roadsrsquo drainage system

From Lea September [mailtoleailisocom]

Sent 11 March 2011 0935 AM

To Wayne Poulton

Cc Terry Baker

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Wayne

An Environmental Impact Assessment (EIA) will be undertaken for this project during the

next 10 to 12 months

We foresee that some of the key environmental impacts of the project will be in terms of air

quality water quality waste and hazardous substances

At this stage I am not able to give you any details regarding the potential toxicity of the

emissions andor effluent However specialist studies will be conducted as part of the EIA

that will determine the key impacts of the project Mitigation measures will also be identified

to avoid minimise or compensate any significant impacts

You are registered on the stakeholder database and you will be kept informed of progress in

the EIA process you will notably get the opportunity to access the reports produced and

provide any feedback on them

Please feel free to contact me should you need any further information

Best regards

Lea September

From Wayne Poulton [mailtowaynepbosuncoza]

Sent 07 March 2011 1257 PM

To Lea September

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

Please can you provide me with some more information as to the potential dangers including

the toxicity of this

Kind regards

Wayne

From Lea September [mailtoleailisocom]

Sent 04 March 2011 1123

To Lea September

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 March 2011 0745 AM

To Paul Martin

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 05 April 2011 0847 AM

To Paul Martin

Cc Terry Baker Renee von Gruenewaldt

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Thank you Paul for this information

I have downloaded a copy of the RoD and Scoping report you referred to and will make sure

these requirements are taken into account in the environmental assessment

Best regards

Lea September

From Paul Martin [mailtopmartinaxxesscoza]

Sent 04 April 2011 0955 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Further to my comments on 27311

Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in

the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega

IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised

scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions

including prohibiting and monitoring where possible visible emission plumes to the atmosphere

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Paul Martin

Sent Monday March 28 2011 745 AM

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 10 May 2011 0327 PM

To ElliotMotsoaholetransnetnet

Cc Terry Baker

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Mr Motsoahole

Thank you for your input on this issue

The Port of Ngqura will indeed be used for import and export At the moment the scope of

the traffic impact assessment only covers road traffic I have however relayed the matter to

our traffic specialist and we will consider this issue in the finalization of the Scoping Report I

will keep you informed of any developments in that regard

I trust this is acceptable to you

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]

Sent 10 May 2011 0855 AM

To Lea September

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

It has been noted that Casa Steel will source steel coils from various markets internationally and

in South Africa and the bulk of the plantrsquos production output will be exported to African countries

However there is no mention of logistic requirements

Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will

be used the scope of traffic impact assessment should also include the port

Regards

From Lea September [mailtoleailisocom]

Sent 04 May 2011 0747 AM

To Lea September

Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

Please find attached a letter announcing the EIA process underway for the proposed 80 000

tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as

a Background Information Document (BID) outlining the details of the project

Please contact me should you require any further information on this project

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

Elliot Motsoahole

Manager - Environment

Transnet National Ports Authority

Port of Nqqura

Port Control Building Klub Road Port Elizabeth 6212

PO Box 612054 Bluewater Bay 6212

+27 41 507 8450

+27 86 674 7729

Cell +27 83 542 5619

E-mail Elliotmotsoaholetransnetnet

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

DISCLAIMER The information contained in this communication is subject to copyright and

intended only for the use of leailisocom Unauthorised use disclosure or copying is

strictly prohibited Should a virus infection occur as a result of this communication the sender

will not be liable If you have received this communication in error please notify

elliotmotsoaholetransnetnet

From Lea September [mailtoleailisocom]

Sent 25 May 2011 1147 AM

To Jack Landile (ELS)

Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi

Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Landile

Thank you for your input

Contact has been made with the relevant Municipal Directorate and we will follow up with

them to obtain clarifications on all these issues

I have added both Lizna and yourself on the database and will keep you updated on

progress on this project

Best regards

Lea September

From Jack Landile (ELS) [mailtoJackLdwagovza]

Sent 24 May 2011 0524 PM

To Fourie Lizna (ELS)

Cc Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Hi Lizna

I missed you on this sorry

I linked Pieter twice Instead

Regards

Landile

From Jack Landile (ELS)

Sent 24 May 2011 0445 PM

To leailisocom

Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Lea

The e-mail you sent to Mr Kooverji dated 19 May 2011 refer

Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are

All steel sheets bathing unit must be under roof

The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project

Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal

Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer

Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality

Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines

Of note is the low volume of the proposed WWTW facility ie 250 cubmweek

And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles

generation

Regards

Landile

From Lea September [mailtoleailisocom]

Sent 19 May 2011 0947 AM

To Lea September

Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Stakeholder

Please find attached the remaining appendices to the draft Scoping report for the proposed

80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 June 2011 0411 PM

To Aphiwe Bewana

Subject RE Proposed 80 000 TPY Galvanizing plant in Coega

Dear Mr Bewana

Thank you for your input and apologies for the late reply

We have taken note of your comments and are will be taking them forward in the EIA phase

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Aphiwe Bewana [mailtoaphiwebewanagmailcom]

Sent 31 May 2011 1205 PM

To Lea September

Subject Re Proposed 80 000 TPY Galvanizing plant in Coega

Comment

Re Proposed 80 000 TPY Galvanizing plant in Coega

As SANParks we would like the EIA phase to investigate the potential effects of toxicity

andor influence of emissions waste and hazardous substances both in terrestrial and

marine fauna In the draft scoping report reference has been made with regards to the

terrestrial fauna but there is no attention to potential effects to marine fauna

Equally with regards to water usage where is the plant going to extract its waters used in

galvanization andor waste management process ie rainfall rivers or even from the sea)

and which avenues would be more environmental friendly and effective

Regards

Aphiwe Bewana

Marine Planner

South African National Parks

POBox 76693

NMMU

Port Elizabeth

6031

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 06 July 2011 1031 AM

To Lea September

Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Hi Lea

Irsquove reviewed the Final Scoping Report Herewith a few comments

1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the

Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a

revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the

NMBLP Please include only those in the IDZ as part of your IAP list

Regards

Andrea

From Lea September [mailtoleailisocom]

Sent Wednesday July 06 2011 859 AM

To Lea Septemberrsquo

Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Dear Stakeholder

The final scoping report for the above-mentioned project (attached) is available for comment

until 27 July 2011

The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic

commentaryrdquo tab

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 09 April 2012 1159 AM

To Lea September

Subject Comments on Galvanising Plant EIR Coega IDZ

Lea

Attached are my comments on the Draft EIR for the Coega IDZ galvanising

plant

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

Email attachment

COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ

Dr Paul Martin PO Box 61029

Bluewater Bay 6212 Tel 041 4665698

Email pmartinaxxesscoza

Compliance with CDC Permits amp Requirements

It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of

o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants

Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC

Air Emissions

Presumably permanent in stack monitoring will be required in terms of AEL permit requirements

Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions

Water

Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)

General

There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)

Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards

Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter

All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 11 April 2012 1245 PM

To Lea September

Subject Fw Comments on Galvanising Plant EIR Coega IDZ

Lea

One other comment on that I have on the Galvanising Plant Draft EIR

Hydrogen chloride is one of the main emissions There are no ambient air

quality guidelines for HCl and the EIR says concentrations will be well

within health parameters

However the main problem with HCl is its corrosive effect - there is

absolutely no mention of this in the draft EIR nor air specialist report

There needs to be some sort of comment assessment as to whether HCl

emissions are likely to impact on for example the adjacent Agni-Steel

Plant wrt corrosion - their factory structure will be made of steel

The EIR specialist rpt suggests monitoring HCl at ground level on the

property boundary and this is supported in case there are complaints from

neighbours

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Paul Martin ltpmartinaxxesscozagt

To Lea September ltleailisocomgt

Sent Monday April 09 2012 1158 AM

Subject Comments on Galvanising Plant EIR Coega IDZ

gt Lea

gt

gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising

gt plant

gt

gt

gt Dr Paul Martin

gt PO Box 61029

gt Bluewater Bay 6212

gt Tel 041 4665698

gt Cell 0732524111

gt email pmartinaxxesscoza

gt

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 12 April 2012 1139 AM

To Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Hi Lea

Hope yoursquore keeping well

I have requested comments from my colleagues and the CDC Casa team on the Draft EIR

Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report

Regards

Andrea

From Graham Taylor

Sent Thursday April 12 2012 838 AM

To Andrea Von Holdt Firhana Sam

Cc Johan Fourie Maria van Zyl Melikhaya Sihawu

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Andrea Firhana

Firhana if you could please ensure that the co-ordinates provided in the EIR correspond

with our records (pages 4-1 amp 4-2)

My comments are as follows

It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work

Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above

Regards

Graham Taylor

Spatial Development Manager - Infrastructure Development

Mobile 0832283055

Office 0414030454

Facsimile 0865185033

Email GrahamTaylorcoegacoza

Website wwwcoegacom

right PLACE | right TIME | right CHOICE

This email and all contents are subject to the following disclaimer

httpwwwcoegacomemaildisclaimerhtml

From Lea September [mailtoleailisocom]

Sent 04 May 2012 0411 PM

To Andrea Von Holdt

Cc Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Dear Andrea

We have taken note of the comments from the GIS Unit These issues have been rectified in

the final version of the EIR

Please can you forward to the relevant persons at the GIS Unit

Thank you

Best regards

Lea September

APPENDIX E

BACKGROUND INFORMATION

DOCUMENT

APPENDIX F

AIR QUALITY IMPACT ASSESSMENT

APPENDIX G

TRAFFIC IMPACT ASSESSMENT

APPENDIX H

WASTE MANAGEMENT AND HAZARDOUS

SUBSTANCES SPECIALIST STUDY

APPENDIX I

WATER QUALITY SPECIALIST STUDY

APPENDIX J

ENVIRONMENTAL MANAGEMENT

PROGRAMME

Page 6: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 iv

ACRONYMS

AEL Atmospheric Emissions Licence

BID Background Information Document

CCA Custom Controlled Area

CDC Coega Development Corporation

DEA Department of Environmental Affairs

DEDEAT Department of Economic Development Environmental Affairs and Tourism

DWA Department of Water Affairs

EAP Environmental Assessment Practitioner

EIA Environmental Impact Assessment

ELC Environmental Liaison Committee

EMP Environmental Management Programme

GN Government Notice

IampAPs Interested and Affected Parties

IDZ Industrial Development Zone

LNG Liquid natural gas

masl Meters above sea level

MSDS Material Safety Data sheet

NEMA National Environmental Management Act

NEMBA National Environment Management Biodiversity Act (No10 of 2004)

NMBM Nelson Mandela Bay Municipality

OSMP Open Space Management Plan

PoS Plan of Study

SAHRA South African Heritage Resources Agency

TNPA Transnet National Ports Authority

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 v

EXECUTIVE SUMMARY

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone

(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province

Galvanizing consists of coating steel with zinc in order to protect it from corrosion An

Environmental Impact Assessment (EIA) is required as the proposed project involves several

activities listed in terms of Section 24 of the National Environmental Management Act

(NEMA) 107 of 1998 as amended and requires an environmental authorisation The

project also involves activities listed in terms of the National Environmental Management Air

Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008

which respectively require an Atmospheric Emissions Licence and a Waste Management

Licence

The Scoping and Environmental Impact Assessment process underway covers all aspects of

the project and informs all three applications

Scoping was the first phase of investigations and aimed to inter alia identify potential key

environmental issues and impacts to be addressed in the EIA phase

The following environmental issues and potential impacts identified in the Scoping Phase

were investigated in the EIA

Air quality

The galvanizing process generates atmospheric emissions which are regulated in terms

of the National Environmental Management Air Quality Act and appropriate measures

are required in order to adhere to the applicable standards Other sources of impact on

air quality include emissions from the LNG burner emissions and dust from the transport

of steel and other materials in trucks as well as dust and gas emissions related to

construction activities Mitigation measures recommended in the EMP will ensure that air

quality impacts are kept to a minimum and compliance with emissions standards is

maintained

Biodiversity and conservation

Certain types of vegetation in the IDZ are of high conservation importance Protected

species will be rescued as per the CDCrsquos requirements

Water quality

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through spills

or leaks This risk can however be minimized if not avoided altogether through design

choices (bunded areas) and the adherence to best practice guidelines for the handling or

the transport of hazardous substances and waste

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vi

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

Waste management and hazardous substances

The plant will generate a relatively small amount of solid waste which will be re-used

recycled or disposed of in accordance with the EMP recommendations

There will be a wastewater treatment plant on site which will neutralise process water

(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer

Hazardous waste from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site

at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and

removed on a monthly basis is limited to 10 m3

A number of substances classified as hazardous are used in the galvanizing process and

the transport and handling of these is subject to certain rules and guidelines

In addition the permanent storage of a high quantity of liquid petroleum on site (20 000

litres at any one time) is subject to certain specifications and requires approval from the

municipality

Health and safety

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling of the various substances used will be done in

accordance with applicable instructions (cf material safety data sheets)

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as provide

site supervision including executing tests (individual test cold run and hot run) during 3

months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the EMP

Traffic

In the operational phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and from

the Port of Ngqura

The traffic expected to be generated during construction as well as operation is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low and

the total traffic generated by Casa Steel is also relatively low

The impact on port traffic is also negligible and well within the portrsquos capacity

Socio-economic aspects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vii

The proposed galvanizing plant will make a positive contribution by creating jobs during

construction and operation and generating business for the various service providers

Fatal flaws

No fatal flaws have been identified

The significance of these potential key environmental impacts were assessed in the EIA

phase and the findings of this phase of investigations are presented in this report

The main findings of the EIA are as follows

During construction impacts post-mitigation are low with the exception of noise and

biodiversity as the construction of the plant will result in the destruction of habitat

and loss of fauna and flora and noise impacts inherent to construction activities

Mitigation measures have been included in the EMP for these impacts and they have

a medium significance post-mitigation

All impacts were assessed as low during operation after mitigation

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium

to long term similar impacts are likely to occur due to ongoing developments in the

IDZ

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

The CDC has its own requirements regarding the monitoring of certain aspects of the

project such as the quality of the effluent and the noise levels These have been

incorporated into the EMP Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as other

infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified and

assessed No fatal flaws have been identified

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 viii

It is recommended that the project be approved subject to the conditions listed above

and adherence to the EMP recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-1

1 INTRODUCTION

11 BACKGROUND

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)

Nelson Mandela Bay Municipality Eastern Cape Province

The demand for galvanised steel products is high in South Africa and Africa and is

expected to increase in the foreseeable future From an economic point of view the

proposed project has therefore been found to be viable

Casa Steel will source the steel coils from various markets internationally and in

South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is

destined to be exported mainly to African countries

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

An Environmental Impact Assessment (EIA) is required as the proposed project

involves several activities listed in terms of Section 24 of the National Environmental

Management Act (NEMA) No 107 of 1998 as amended and requires an

environmental authorisation

The following listed activities requiring environmental authorisation have been

identified

Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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 metres

Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped

land to industrial use greater than 1 ha but less than 20 ha in size outside an

urban area

Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any

process or activity requiring a license in terms of national or provincial legislation

governing the generation or release of emissions

Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5

hectares or more of vegetation where 75 or more of the vegetative cover

constitutes indigenous vegetation except where such removal of vegetation is

required for

(i) purposes of agriculture or afforestation inside areas identified in

spatial instruments adopted by the competent authority for

agriculture or afforestation purposes

(ii) the undertaking of a process or activity included in the list of waste

management activities published in terms of section 19 of the

National Environmental Management Waste Act 2008 (Act No 59

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-2

of 2008) in which case the activity is regarded to be excluded from

this list

(iii) the undertaking of a linear activity falling below the thresholds in

Notice 544 of 2010

Hot dip galvanizing is a listed activity in terms of section 21 of the National

Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires

an Atmospheric Emissions Licence (AEL)

In addition the treatment of wastewater with an annual throughput capacity of more

than 2000 m3 is a listed activity in terms of the National Environmental Management

Waste Act 59 of 2008 and requires a waste management licence

ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental

Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact

Assessment process in terms of section 24 of NEMA for the construction and

operation of the proposed galvanizing plant The EIA process covers all aspects of

the project and informs all three applications (for environmental authorisation waste

management licence and AEL)

13 PURPOSE OF THIS REPORT

This report builds on the scoping report submitted to the Eastern Cape Department of

Economic Development and Environmental Affairs (DEDEA) and the Nelson

Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It

describes the proposed project and presents the findings of the second phase of

investigations (EIA phase)

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT

PRACTITIONER (EAP)

The EIA was managed by Ms Terry Baker a certified Environmental Assessment

Practitioner with 20 years of working experience She has a MA in Environmental

Management and specialises in Environmental Impact Assessments and Project

Management She has been involved in a variety of different types of EIAs including

for water supply projects dams transmission lines roads and airports in South

Africa Botswana Uganda Lesotho and Mozambique She has been involved in

water resource management and public participation programmes on a number of

projects Terry has also been involved in the use of Geographic Information Systems

environmental status quo reports water quality assessments socio-economic and

institutional development projects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-3

15 PROJECT TEAM

In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen

(water quality specialist) and Lea September (EAP) with specialist input from Renee

von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous

substances) and Seniel Pillay (Traffic Impact Assessor)

The Business Unit Head of the ILISO Environmental Management Discipline Group

Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is

a Fellow of the South African Institution of Civil Engineers a member of the South

African Society of Aquatic Scientists of the Environmental Scientific Association of

the International Water Association of the Water Institute of South Africa and of the

Vaal River Catchment Association He is a certified Environmental Assessment

Practitioner with 30 years experience who specialises in project management

environmental impact assessments and water resource planning He specifically has

extensive experience in water quality especially water quality management water

quality monitoring and water quality assessment Martin has experience in managing

projects that involve multi-disciplinary teams and public consultation and

participation in South Africa and abroad

Lea September is an Environmental Assessment Practitioner with a Masters degree

in Environmental Management She has experience in impact assessment and

environmental management and has been responsible for drafting impact

assessment reports and Environmental Management Programmes and conducting

public participation processes as well as high level environmental screenings for a

variety of projects in the energy water transport and industrial sectors

Renee von Gruenewaldt has nine-years experience in the field of air pollution

impact assessment and air quality management Prior to becoming involved in air

quality consultation she was part of the Highveld Boundary Layer Wind Research

Group based at the University of Pretoria Since joining Environmental Management

Services (the company now Airshed Planning Professionals) she has undertaken

numerous air pollution impact studies and has provided extensive guidance to both

industry and government on air quality management practices

Pieter Smuts graduated as a Civil Engineer and became involved in the field of

municipal engineering and infrastructure construction He has specialized during the

last twelve years in solid waste management He has completed waste management

plans feasibility studies and final designs of waste management facilities in South

Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and

the review of the Mavoco hazardous waste landfill design in Maputo Mozambique

and completed a study on hazardous waste (textile factory sludge) management in

Maseru Lesotho

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-4

Seniel Pillay is a transportation engineer with over 16 years experience in

transportation planning and traffic engineering He has been involved in a wide

range of projects ranging from developing the Transport Operations Plan for the

FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System

for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller

traffic impact assessments for inter alia road improvement schemes Of particular

relevance to this project his experience includes Heavy Goods Vehicle Study for

eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact

Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash

Preliminary Transportation Assessment

16 STRUCTURE OF THIS REPORT

The proposed project and the alternatives considered are described in Chapter 2

Chapter 3 details the approach adopted for the EIA phase

The biophysical and socio-economic environment affected by the activity is described

in Chapter 4

The environmental impacts identified are discussed in Chapter 5

The EIA methodology is described in Chapter 6 and Chapter 7 presents the results

of the impact assessment

The environmental impact statement is presented in Chapter 8

Finally Chapter 9 spell out the conclusions and recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-1

2 DESCRIPTION OF THE PROPOSED PROJECT

21 TECHNICAL ASPECTS

211 The galvanizing process

Galvanizing consists of coating steel with zinc in order to protect it from corrosion

Before steel strips can be galvanized they undergo a pre-treatment in order to

ensure that the steel sheets are free from any surface oxides as they enter the

molten zinc coating Bath This is done by removing the oil from the steel sheets (in

the degreasing unit) and then removing the rust from the surface of the sheet (in the

pickling unit)

The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The

melting zinc on the strip surface will be cooled and solidified through air cooling in the

cooling tower

Finally the galvanised steel sheets are dipped into a water quenching tank in order to

further cool the sheets from about 150degC to 40degC

It is possible to make galvanised steel more durable by chromating it Approximately

50 of the galvanised steel production output will receive chromate passivation

treatment after quenching the galvanised steel sheets will be sprayed with a chrome

solution (3 kgcm2)

After galvanizing and chromating the steel sheets are cut to achieve the desired coil

size and weight and transported to the storage yard

The process flow diagram below (Figure 1) illustrates the main stages of the

galvanizing process and indicates the major inputs and outputs as well as the

resulting effluent and atmospheric emissions

Draft Environmenal Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-2

Figure 1 Process flow diagram for proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-3

212 Main inputs and outputs in operational phase

In view of the above the main inputs will be as follows

Steel coils 85 000 tonsyear

Zinc 870 tonsyear

Electricity 2500 kVA

Water 2000 m3month (of which 400 m3 will be potable water)

Liquid Natural Gas (LNG) 270 NM3hour

Sodium hydroxide (NaOH) 1000 m3year

Hydrochloric acid (HCl) 800 m3year

Chrome (Cr+3) 10 m3year

The main outputs will be

Galvanized steel 80 000 tonsyear

Scrap metal 20 tonsyear

General waste 65 tonsyear

Hazardous waste 2 m3month

Wastewater 012 Mlweek

Atmospheric emissions lt 5 ppm

213 Installations on site

The bulk of the operations involved in the galvanizing process occur along a

continuous galvanizing line (See Figure 2 below) which is the main piece of

machinery required for the proposed galvanising plant

Figure 2 Continuous Galvanizing Line

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-4

Water is one of the major inputs and is used throughout the galvanizing process notably

for rinsing and cooling purposes and as a mixing agent for the various chemical

solutions The plant will have a water treatment plant on site to treat the water used in

the various processes (approx 250 m3

of wastewater per week) The wastewater

treatment facility will be operated by a professional water treatment company as Casa

Steel does not have the required expertise in house to treat its process water Sulphuric

acid (H2SO4) is used as part of the treatment process to reduce caustic soda The

neutralised water is discharged to the sewer while any sludge is disposed of as

hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)

will be disposed of

Some critical areas of the galvanizing process such as the zinc pot require uninterrupted

power It is therefore proposed to install an LNG burner to maintain the zinc bath at a

temperature of between 450 and 460degC

22 LOCATION OF THE PROPOSED GALVANIZING PLANT

The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast

of Port Elizabeth in the Eastern Cape (Figure 3)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-5

Figure 3 Location of the proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-6

23 NEED AND DESIRABILITY

The profitability of the proposed project has been established by Casa Steel and a

pre-feasibility study has confirmed that the proposed project was feasible from a

technical and financial point of view The Coega IDZ is specifically designed to host

facilities such as a galvanizing plant and can provide the necessary infrastructure

and services to its investors It therefore constitutes a very suitable location for the

project

24 ALTERNATIVES IDENTIFIED

Zone 6 has been specifically earmarked for heavy ferrous metal industries and is

therefore a suitable location for the proposed galvanizing plant as such no site

alternatives have been provided for and assessed in this EIA However prior to the

commencement of the EIA process Casa Steel was presented with a number of

different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the

selection of the site were

(a) The dimensions of the land the site should be at least 200 m long and

50 m wide in order to accommodate the galvanizing line and adjacent lay

down area and additional land should be available next to the site for future

expansion

(b) The fiscal arrangements applying to the site the site should be located

within the future Custom Controlled Area (CCA) as the bulk of the

production output of the plant will be exported

The no-go alternative is assessed in this report

25 CONSTRUCTION ASPECTS

The construction phase of the project will take about 12 months and will essentially

consist of erecting a building to house the galvanizing line and other equipment and

preparing a concrete laydown area adjacent to the building

The CDC will provide an access point from the existing tarred road that will lead to

the site

Approximately 100 workers from the surrounding areas will be contracted for the

construction work

The requirements in terms of services during construction are listed below

Water 1000 m3month

Electricity 2500 kVA

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-7

The CDC will provide temporary services for the construction phase including a

conservancy tank for flush toilets Sewage infrastructure will only be provided for the

operational phase

26 OPERATION ASPECTS

Before the plant can become fully operational the equipment and machinery will be

tested for approximately 3 months The supplier will supervise these tests as part of

the transfer of know-how and training of staff on the plant

Casa Steel will start operating the plant at a reduced capacity (about 50 000

tonsyear) for a period of time (mostly determined by market aspects) before bringing

production to full capacity (80 000 tonsyear) This is done by operating the line for

longer hours

Approximately 50 to 60 people will be working on the plant Approximately 6-10 of

these will be unskilled 40-45 skilled and about 5 people in managerial positions

The requirements in terms of services during operation are as follows

Water 2000 m3month

Electricity 2500 kVA

Effluent discharge 24 m3day

The CDC has entered into agreements with the municipality to secure the provision

of services such as water and electricity to its tenants Tenants in the IDZ have their

own agreements with the NMBM for electricity while the agreements for water and

sewage are with the Facilities Unit of the CDC

Regarding discharge of wastewater to the sewer the municipality indicated that the

only requirement is that the water discharged complies with applicable municipal

discharge standards

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 3-1

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT

31 OBJECTIVES

The main objectives of the EIA phase are to

Assess the significance of the environmental issues and impacts identified in the

scoping phase focusing on key impacts

Recommend appropriate measures to mitigate negative impacts and enhance the

benefits and include them in the draft EMP

Undertake a public participation process that provides opportunities for all

interested and affected parties (IampAPs) to be involved

32 AUTHORITY CONSULTATION

The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental

Liaison Committeersquo (ELC) which comprises representatives of various authorities

including DEDEAT the Department of Environmental Affairs (DEA) and Department

of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the

Coega Development Corporation (CDC) and Transnet National Ports Authority

(TNPA) The ELC has been specifically formed to facilitate EIA applications in the

IDZ

Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to

the clearance of vegetation should be included in the application A formal request

was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the

application and all registered stakeholders were informed of the request in writing on

19 October 2011

33 PUBLIC PARTICIPATION PROCESS CONDUCTED

On-site notices were replaced by a notification displayed on the CDCrsquos digital notice

board at the business centre in Zone 1 of the IDZ The eNotice was placed on

13 April 2011 and will remain for the full duration of the EIA process

Registered stakeholders will be notified in writing of the availability of the draft EIA

report and EMP which will also be advertised in a local newspaper Stakeholders

including state departments and the public will have forty (40) days to comment on

the draft EIA report and EMP The draft EIA report and EMP will be sent by email

where possible and made available for download on the ILISO website

(wwwilisocom)

A summary of all issues and comments received during the stakeholder consultation

process as well as of correspondence in that regard will be captured in an Issues

and Responses Report that will form an Appendix to the EIA Report

The list of registered IampAPs is included in Appendix A

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 3-2

34 LEGISLATION AND GUIDELINES CONSIDERED

The following legislation and guidelines were considered in the preparation of this

report

National Environmental Management Act Act No 107 of 1998

NEMA EIA Regulations 2010

National Environmental Management Air Quality Act Act No 39 of 2004

National Environmental Management Waste Act Act No 59 of 2008

Hazardous Substances Act Act 15 of 1993

Occupational Health and Safety Act Act 85 of 1993

Hazardous Chemical Substances Regulations 1995 (GNR 1179)

Major Hazard Installation Regulations 2001 (GNR 692)

National Water Act Act 36 of 1998

National Heritage Resources Act Act 25 of 1999

DEAT Integrated Environmental Management Information Series 1-5 and 12-15

NEMA draft Implementation Guideline

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Public Participation (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Alternatives (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Draft Guideline for Determining the Scope of Specialist

Involvement in EIA Processes (2005)

IAIA guidelines

National air quality standard for thoracic particulates Government Gazette

No 32816

Listed activities and associated minimum standards identified in terms of section

21 of the National Environmental Management Air Quality Act Act No 39 of

2004 Government Notice 248 of 2009

Minimum Requirements for the Handling Classification and Disposal of

Hazardous Waste DWAF Waste Management Series (1998)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-1

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION

The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega

IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay

to the north of the N2 highway between Port Elizabeth and Grahamstown east of the

Coega River

The co-ordinates of the corners of the site are shown in Table 1

Table 1 Coordinates of site corners for the proposed galvanizing plant

Point Longitude Latitude

A 25deg411126E 33deg45587S

B 25deg411156E 33deg45499S

C 25deg411938E 33deg45131S

D 25deg412174E 33deg45481S

E 25deg412508E 33deg45979S

F 25deg412634E 33deg451160S

G 25deg411782E 33deg451560S

H 25deg411692E 33deg451428S

J 25deg411314E 33deg45868S

Figure 4 Zone layout in the Coega IDZ

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-2

Figure 5 Site location

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-3

42 SOCIO-ECONOMIC CHARACTERISTICS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the

NMBM There are no residents within the IDZ

As far as the broader NMBM and Eastern Cape Province are concerned the

following can be noted The NMBM is located within the Eastern Cape Province the

2nd largest Province in South Africa (3rd in terms of population) characterised by a

predominantly black population with low incomes and high levels of unemployment

(CES 2010)

The NMBM has a population of just above 11 million and covers an area of

1 950 km2 It is the main urban and industrial centre of the province and Port

Elizabeth in particular which forms part of the NMBM is the commercial capital of

the Eastern Cape 52 of the NMBM population is female and 37 is below the

age of 20 these two groups are particularly affected by unemployment

43 BIOPHYSICAL CHARACTERISTICS

431 Surface and ground water

No rivers occur in Zone 6 There is however a natural attenuation pond on the

southern most part of the site which will have to be avoided

The IDZ is underlain by calcrete sand and gravel deposits that overlie low

permeability clays These clays limit the vertical infiltration of rainwater and induce a

horizontal groundwater flow towards the Coega River channel which is the most

significant surface water feature in the Coega IDZ Consequently rapid run-off takes

place following precipitation (Jacobs 2008)

Groundwater levels at Coega are generally about 3 to 5 m below surface ie just

above the contact between the permeable sands and the underlying impermeable

clays The groundwater flow direction is to the southeast following the surface water

drainage direction (Jacobs 2008)

432 Climate and atmospheric conditions

Port Elizabeth has a warm temperate climate and the temperature ranges are not

extreme Exceptionally high temperatures may be experienced during berg wind

conditions which occur frequently during autumn and winter Extreme temperatures

also occur during summer with little accompanying wind

The wind regime for the area largely reflects the synoptic scale circulation with

dominant westerly and northwesterly flow fields representing the pre-frontal

conditions and south-westerly flow fields representing the frontal conditions The

south-easterly and south-westerly wind flow (land breeze) increases during daytime

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-4

conditions with westerly and north-westerly wind flow increasing during the night (sea

breeze)

The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of

Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15

km southwest) and Port Elizabeth (~23 km southwest)

An ambient air monitoring network has been established in the Coega IDZ which

consists of three monitors Saltworks Motherwell and Amsterdamplein Although

NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative

impacts due to the proposed Galvanising Plant is PM10 A maximum daily average

PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed

SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3

was exceeded on 17 days in 2007 and 26 days in 2008

Existing sources of emissions in the vicinity of the proposed galvanizing plant include

industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other

fugitive dust sources (von Gruenewaldt 2011b)

433 Geology and soils

Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel

and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly

limestone and conglomerate

434 Terrestrial ecology

This section draws from the EIA report compiled for the Agni Steel (formerly Afro-

Asia) steel processing facility which is adjacent to the proposed site for the

galvanizing plant (Jacobs 2008)

The area consists largely of grasses succulents and scrubby bush with alien

species making up the greater part of the more dense vegetation

Zone 6 falls within the inland vegetation and is characterised by a vegetation type

referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the

Coega IDZ and has been found to have three times the level of endemism of other

vegetation communities in the Coega IDZ Bontveld therefore has a high

conservation status Two Bontveld conservation areas have been identified within the

IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)

Bontveld that will be destroyed as a result of development in the IDZ will be given

conservation status in these two areas

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-5

Figure 6 Coega IDZ Open Space Management Plan (OSMP)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-6

Certain areas in the IDZ are invaded by alien plant species The most common

invader species is rooikrans (Acacia cyclops) which presently forms large

monospecific stands in areas throughout the Coega IDZ There are several other

aliens present that pose a threat to the flora of this area including the prickly pear

(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)

Loss of vegetation and alien plant invasion due to human activity has resulted in a

reduction in the diversity of terrestrial fauna

The majority of mammals present in the Coega IDZ are small or medium-sized Of

the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed

gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of

Algoa Bay however it is not considered threatened The gerbil is common in

foredune and dune thicket habitat in the Coega region and is therefore unlikely to

occur on the proposed site

A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird

species are resident or common to the area Most diversity occurs in the thicket

although the coastal area also supports specialised avifauna Two species of tern

the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well

as the Cape gannet (Morus capensis) and the African penguin (Spheniscus

demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne

caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant

(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser

flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns

are two of the most endangered coastal species in South Africa Other bird species

of conservation concern include the Whitefronted plover (Charadrius marginatus)

African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus

bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus

ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides

paradisea) Breeding pairs of Damara terns and African black oyster catchers have

been observed in the coastal dunes of the IDZ but should not be affected by

developments that fall outside the dune areas

The Eastern Cape supports nearly a third (approximately 133 species) of the reptile

species recorded in South Africa More than half of the Eastern Capersquos endemic

reptile species occur in the Algoa Bay area giving the region a high conservation

value A total of 63 reptile species are believed to occur within the Coega IDZ The

majority of these are found in Succulent Thicket and riverine habitats Only a few

reptile species occur in the coastal dunes and estuarine habitats More than a third of

the species are described as relatively tolerant of disturbed environments provided

that migration corridors of suitable habitat are maintained to link pristine habitats

Twenty two reptiles are of special concern including five endemic species (two of

which may also be endangered) four endangered sea turtles eight species listed

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-7

with CITES one rare species and four species at the periphery of their range

Fourteen of these species of special concern are confirmed as occurring on or within

2 km of the Coega IDZ

A total of 32 amphibian species and sub-species occur in the Eastern Cape

representing almost a third of the species recorded in South Africa However none of

the species are endemic or Red Data Book species Based on previous studies in the

area it is estimated that approximately 17 amphibian species occur within the Coega

IDZ Four species are listed as peripheral but none are threatened internationally

These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog

(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and

the bubbling kassina (Kassina senegalensis)

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated

vegetation has not been extensively studied One grasshopper species Acrotylos

hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue

(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis

pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in

four localities in the Eastern Cape one of which is within the Coega IDZ The Coega

copper Aloeides clarki is endemic to this particular region of the Eastern Cape and

is currently known to occur in three localities two of which are in the Coega IDZ The

localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the

Coega IDZ and their distributions were taken into account when defining Coegarsquos

open space system and Development Framework Plan

435 Land use and topography

The land is currently undeveloped and earmarked for industrial development The

site is relatively flat ranging from an elevation of 66 masl on the northern-most

corner to 59 masl at the southern-most corner

436 Heritage and archaeological survey

Extensive studies have been undertaken in Zone 6 with respect to heritage aspects

Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a

2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond

2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is

currently being finalised

Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing

Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha

in extent and was located next to the R102 road to Motherwell Kaplan conducted

HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi

Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will

now be located in Zone 5)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-8

The various archaeological investigations reached similar observations and

conclusions Stone tools of various densities and types were found throughout the

zone The majority of the stone tools were mainly of Earlier and Middle Stone Age

and occasional Later Stone Age origins (Figure 4)

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble

gravels exposed by tracks in Zone 6 (Source Binneman 2010)

The stone tools which comprised of quartzite flakes chunks flaked pebblecobble

and cores were randomly distributed across the landscape and are in secondary

context There were no lsquoconcentrationsrsquo of tools observed which suggested any

spatial patterning or activity areas although these may be present or covered by soil

and vegetation

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 5-1

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED

The following environmental issues and potential impacts were identified in the

Scoping phase

51 AIR QUALITY

The galvanizing process generates atmospheric emissions with particulates and

hydrogen chloride representing the main pollutants of concern The plant is fitted with

air extraction as well as scrubber systems which are designed to retain the bulk of

pollutants and particles for each of the processes in such a way that less than 5 ppm

of gases and particles will be released into the atmosphere after the fume scrubber

Other sources of impact on air quality include emissions from the LNG burner as well

as emissions and dust from the transport of steel and other materials in trucks

Construction activities will also create dust and gas emissions due to the clearing of

groundcover tipping of material to storage pile levelling of area wind erosion from

storage piles vehicle and construction equipment activity and tailpipe emissions

from vehicles and construction equipment such as graders scrapers and dozers

Overall the air quality impact assessment (Gruenewaldt 2011b) found that

The predicted particulate oxides of nitrogen carbon monoxide and sulphur

dioxide concentrations are all below the National Ambient Air Quality Standards

for all averaging periods

The predicted off-site concentrations of hydrogen chloride are well below the

most stringent effect screening levels

No odour threshold exceedances for hydrogen chloride were predicted to occur

due to routine operations at the Steel Galvanising Plant The South Wales

Environmental Protection Authority stipulates that an odour unit of 20 is

acceptable for urban areas The odour unit would be lt10 directly off-site for

hydrogen chloride

Abnormal emissions can occur in exceptional circumstances Start-up will not

cause abnormal emissions as the scrubbers will be commissioned first and will be

functioning once the plant starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions would be emitted as a

building fugitive

The hourly hydrogen chloride ground level concentrations (directly offsite) were

predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based

on the emission limits as stipulated for listed activities for galvanising processes)

using a screen model which assumes worst case meteorological conditions The

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-2

health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming

abnormal emissions emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset conditions will still

be well within the health effect screening levels

Similarly the hourly particulate emissions from the building fugitives during upset

conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for

listed activities for galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly

off-site

Therefore if emissions are 5 times higher normal they will still be within health effect

screening levels and the daily PM10 NAAQS levels

In the case of a fire a cocktail of gases and particulates could be emitted and could

be over the recommended levels This situation will however be dealt with as an

emergency and normalised as quickly as is possible

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS

The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of

its heritage potential and there are no proposed protected geosites in Zone 6

Should any artefacts be discovered during construction procedures stipulated in the

draft EMP will apply

53 BIODIVERSITY AND CONSERVATION

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

In terms of terrestrial fauna the CDCrsquos open space management plan provides for

the preservation of certain corridors The destruction of certain habitats as a result of

the development will therefore not automatically result in the loss of certain species

54 WATER QUALITY

There is a natural attenuation pond on the southern most part of the site which will be

avoided

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through

spills or leaks

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-3

This risk can however be minimized if not avoided altogether The floor of the factory

will be designed as a bunded area to contain any spills and the entire process will be

contained Potential spills or leaks will therefore be contained and will not impact on

water resources Storm water is therefore considered clean water under normal

operational conditions An oil trap will be placed at the exit of the site to ensure that

no grease from the laydown area enters the stormwater system

Spills and leaks can occur during the handling or the transport of hazardous

substances Best practice guidelines will be followed to ensure that this risk is

adequately managed

Wastewater discharged to sewer will be treated to comply with municipal discharge

standards and is not expected to have an impact on the chemical characteristics of

the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be

discharged from the plant is small in relation to the total volume received at the

Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works

(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently

operated at 61 of its capacity which is approximately 80 Mℓday Thus the

0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore

not have any significant impact on the WWTW

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES

The plant will generate a relatively small amount of solid waste in the form of scrap

metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)

The scrap metal may be sold to other steel processing facilities such as Agni Steel

which will be located next to the plant or collected and disposed of with the rest of

the solid waste by a licensed service provider

As mentioned previously there will be a wastewater treatment plant on site which will

neutralise process water (012 Mlweek) in order to ensure it is of a standard

acceptable for discharge to sewer Waste in the form of sludge from the

neutralization or spent acid must be disposed of as a hazardous waste Solid waste

from the filters used for air quality control is also in this category These wastes can

usually be tested and then delisted which means that it can be placed in a general

purpose landfill

Hazardous effluent from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-

site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored

and removed on a monthly basis is limited to 10 m3

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-4

A number of substances classified as hazardous are used in the galvanizing process

(Table 2) and the transport and handling of these is subject to certain rules and

guidelines In particular the material safety data sheets (cf Appendix H) should be

referred to for inter alia hazards identification accidental release measures

handling and storage precautions exposure controlpersonal protection ecological

information and transport information The Hazardous Chemical Substances

Regulations 1995 should also be adhered to in respect of the transport and storage

of hazardous chemical substances

Table 2 Hazardous materials to be used on site

Major Input Materials

Substance

listed in the

SABS 0228

Group II

hazardous

substances

Volumes to be

stored on site at

any one time

Diesel radic 2000 litres

Liquid petroleum radic 20 000 liters

Sodium hydroxide (NaOH)

(used for degreasing) 8 radic 1000m

3

Hydrochloric acid (HCI)

(used for pickling) 8 radic 800m

3

Zinc (used for galvanising) - TBD

Trivalent chromium (CR+3

)

(used for chromating) 8 radic 10m

3

Sulphuric acid (H2SO4) (used for

treatment of waste water on site) 8 radic TBD

Ammonium Hydroxide (NH4OH) 8 radic TBD

TBD ndash To be determined

Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one

time) and is classified as a flammable substance Specification for flammable storage

facilities in accordance with the requirements of the Nelson Mandela Bay

Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for

quantities between 5000 and 20 000 liters the substance must be kept in a

flammable liquid store which complies with the requirements of a specification

obtainable from the Department Some of the requirements are

Flammable liquid and solid storage facilities are only permitted on the ground

floor

Decanting of flammable liquids and solids are not permitted within any building

Due to the fact that there are flammable materials on site a certificate may be

required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and

Emergency Services Department to confirm that facilities for flammable storage

are in accordance with their requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-5

Because of the permanent installation and high quantity of liquid petroleum on site

the Major Hazard Installation Regulations 2001 promulgated under the Occupational

Health and Safety Act No 85 of 1993 applies A written application for approval of

the installation is required to be submitted to the chief inspector Department of

Labour provincial director Department of Labour and NMBM prior to construction

In addition a risk assessment should be formulated covering all hazardous materials

together with an emergency preparedness and response plan

56 HEALTH AND SAFETY

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling instructions as well as occupational exposure limits

are indicated in the material safety data sheets of the various substances used

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as

provide site supervision including executing tests (individual test cold run and hot

run) during 3 months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the

EMP

In addition the emergency preparedness and response plan will cover the health and

safety aspects related to emergency situations

57 TRAFFIC

The volumes of traffic at the IDZ are currently relatively low and variable depending

on the different zones in the IDZ however these volumes will increase as more

developments are implemented

The construction phase of the Casa Steel development will take about 12 months

and will essentially consist of erecting a building to house the galvanizing line and

other equipment and preparing a concrete laydown area adjacent to the building

The traffic that would be generated during the construction phase can be expected to

be less than the traffic that would be generated by the Casa Steel development when

it is fully operational

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-6

In the operation phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and

from the Port of Ngqura

The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the

Casa Steel development would be off Ring Road 1 The other roads of significance

for the Casa Steel development are the N2 Neptune Road MR435 and MR450

Access to the port is given by Neptune Road Road Link NEP-03 has not yet been

built

Figure 8 Coega IDZ road network identification

(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-7

Figure 9 Coega IDZ road network

Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No

01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-8

The distribution of freight trips is fixed as the majority of trips will be made between

the Port of Ngqura and the Casa Steel site With regard to personnel trips there are

various points of origins (the surrounding residential areas) that could be used by

staff going to the Casa Steel site The distribution of personnel trips is based on

existing traffic count information and is shown in Figure 10

Figure 10 Trip distribution for freight and personnel trips

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The resultant expected Casa Steel traffic assignment is shown in Figure 11

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-9

Figure 11 Morning peak hour Casa Steel development traffic

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The traffic that is expected to be generated by the Casa Steel development is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low

and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)

Consultation has taken place with Transnet Port Authority (TPA) to establish the

impact of the galvanizing plant operations on traffic inside the port The additional

ships entering and exiting the port of Ngqura as a result of the proposed development

will have a negligible impact on port traffic and TPA indicated that it would be well

within the portrsquos capacity

58 NOISE

Noise is not foreseen to be a significant issue insofar as the noise levels inside the

plant and at the boundary of the site will not exceed the limits prescribed by the CDC

Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels

during the day and 60 decibels at night

Mitigation of noise impacts will be addressed in the design of the noise-emitting

components of the plant and their enclosures

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-10

59 SOCIO-ECONOMIC ASPECTS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of

NMBM There are no residents within the IDZ

The direct socio-economic impacts of the proposed project are thus limited to the

employment generated by the project during construction and operation Job creation

remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)

and the IDZ and Port of Ngqura are expected to become a significant catalyst to the

economic growth of the Municipality and the region with current investments at

Coega creating more jobs and stimulating the economy

In this context the proposed galvanizing plant will make a positive contribution

towards the achievement of these goals

There will be 50 to 60 employees during operation phase distributed as follows

Figure 12 Casa Steel organisation chart

Even though a large part of the inputs will be imported and the bulk of the production

output will be exported there will be some positive impacts for the economy of the

region and of South Africa in general Notably the requirements of the plant for

water electricity waste collection and disposal waste water treatment and transport

for example will create business for the various service providers and have an

indirect impact on employment and fiscal revenues as a result

From a visual impact point of view it can be anticipated that the landscape in the IDZ

will be significantly affected over time by developments related to the establishment

of the port and various industries

HEAD ( WORKS )

MGR ( COMM) MGR ( ADMNHR ) Manager marketing

MANAGER OPERATION MANAGER MANAGER MANAGER Q C

AC FIN PUR ampSTORE

PPC SH-GALV SH-tech

SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF

1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO

JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF

2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO

WORKERS WORKERS 7NOS

15 7

RAW MAT amp

DESP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 6-1

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY

A description of the nature of the impact any specific legal requirements and the

stage (constructiondecommissioning or operation) will be given Impacts are

considered to be the same during construction and decommissioning The

significance of the potential impacts will be considered before and after identified

mitigation is implemented

The following criteria will be used to evaluate significance

Nature The nature of the impact will be classified as positive or negative and

direct or indirect

Extent and location Magnitude of the impact and is classified as

Local the impacted area is only at the site ndash the actual extent of the activity

Regional the impacted area extends to the surrounding immediate and

neighbouring properties

National the impact can be considered to be of national importance

Duration This measures the lifetime of the impact and is classified as

o Short term the impact will be for 0 ndash 3 years or only last for the period of

construction

o Medium term three to ten years

o Long term longer than 10 years or the impact will continue for the entire

operational lifetime of the project

o Permanent this applies to the impact that will remain after the operational

lifetime of the project

Intensity This is the degree to which the project affects or changes the

environment and is classified as

o Low the change is slight and often not noticeable and the natural functioning

of the environment is not affected

o Medium The environment is remarkably altered but still functions in a

modified way

o High Functioning of the affected environment is disturbed and can cease

Probability This is the likelihood or the chances that the impact will occur and

is classified as

o Low during the normal operation of the project no impacts are expected

o Medium the impact is likely to occur if extra care is not taken to mitigate

them

o High the environment will be affected irrespectively in some cases such

impact can be reduced

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 6-2

Confidence This is the level knowledgeinformation the environmental impact

practitioner or a specialist had in hisher judgement and is rated as

o Low the judgement is based on intuition and not on knowledge or

information

o Medium common sense and general knowledge informs the decision

o High Scientific and or proven information has been used to give such a

judgment

Significance Based on the above criteria the significance of issues will be

determined This is the importance of the impact in terms of physical extent and

time scale and is rated as

o Low the impacts are less important

o Medium the impacts are important and require attention mitigation is

required to reduce the negative impacts

o High the impacts are of great importance Mitigation is therefore crucial

Cumulative Impacts The possible cumulative impacts will also be considered

Mitigation Mitigation for significant issues is incorporated into the EMP for

construction

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 7-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS

71 IMPACTS DURING CONSTRUCTION

711 Air quality

Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris

handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine

particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural

operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks

and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)

Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Fugitive particulate emissions (dust)

related to construction activities Regional

Short

term Medium High High Medium Regional

Short

term Low High High Low

Construction vehicle gas emissions Regional Short

term Medium High High Medium Regional

Short

term Low High High Low

712 Heritage and archaeological resources

Naturedescription of impact excavation activities may impact on unidentified heritage resources

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-2

Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based

on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments

Heritage and archaeological

resources Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on unidentified heritage

resources Local

Short

term

Medium -

high Low High Low

713 Biodiversity and conservation

Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation

importance and cause soil contamination

Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species

Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan

and has compiled a list of protected species to be rescued (see draft EMP)

Biodiversity and conservation Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Loss of fauna and flora Local Perma

nent

Medium -

high High High High Local

Permanen

t Medium High High Medium

Soil contamination Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-3

714 Water related impacts

Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater

runoff spills and leaks Soil erosion

Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of

spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste

disposal Stormwater quality monitoring (see draft EMP)

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Soil erosion Local Short

term Medium Medium High Medium Local

Short

term Medium Low High Low

715 Waste management

Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed

Commentmitigation see draft EMP and waste management plan

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-4

Waste management Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Local

Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

716 Health and safety

Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Short

term

Medium -

high

Medium -

high High High Local

Short

term

Medium -

high Low High Low

717 Traffic

Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and

construction workers from surrounding areas and transport of equipment from the port

Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low

Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and

accurate estimates of quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-5

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Increased traffic on N2 and within the

IDZ Regional

Short

term Low High High Low

718 Noise

Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Short

term

Medium-

high High High Medium Local

Short

term Medium High High Medium

719 Socio-economic

Naturedescription of impact temporary employment will be created during the construction phase

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-6

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Temporary employment Regional Short

term Medium High High Medium

72 IMPACTS DURING OPERATION

721 Air quality

NatureDescription of impact gas and particulate emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning

Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local

sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and

veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute

to background fine particulate concentrations (von Gruenewaldt 2011b)

Assumptions and limitations Potential release of CR6+

As no emission factors are available for trivalent chromium processing the

potential impacts due to these activities could not be quantified

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Dust emitted from traffic on paved roads Regional Long Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-7

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

term

Hydrogen chloride emissions from

pickling process Local

Long

term Low High High Low

Particulate emissions (smoke) from

galvanizing process (due to the

volatilization of flux)

Local Long

term Low High High Low

Particulate oxides of nitrogen carbon

monoxide and sulphur dioxide emissions

from LNG burner

Local Long

term Low High High Low

Nuisance related to odour Local Long

term Low Low High Low

Abnormally high hydrogen chloride and

particulate emissions due to scrubber

malfunction

Local Short

term Medium Low High Medium

Gases (eg SOx NOx CO etc) and

smoke emitted in case of a fire Local

Short

term High Low High Medium

722 Water quality

NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks

Commentmitigation see draft EMP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-8

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Stormwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

723 Waste management and hazardous substances

NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous

waste both can affect environmental quality and human health

Commentmitigation see draft EMP and waste management plan

Waste management and hazardous

substances Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Regional

Long

term High

Medium -

high High High Regional Long term High Low High Low

Soilwaterair pollution due to improper

transport storage and handling of

hazardous substances

Regional Long

term High

Medium -

high High High Regional Long term High Low High Low

Health hazard Local Long

term High

Medium -

high High High Local Long term High Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-9

724 Health and safety

Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Long

term

Medium-

high

Medium-

high High High Local Long term

Medium-

high Low High Low

725 Traffic

Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on

the road network

Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak

hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road

network within Zone 6 of the IDZ (Iliso 2011)

Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)

Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of

quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-10

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on traffic and capacity of the N2 Regional Long

term Low High High Low

Impact on traffic and capacity of ring

road 1 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR435 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR450 Local

Long

term Low High High Low

Impact on traffic and capacity of

Neptune road Local

Long

term Low High High Low

726 Noise

Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Long

term Medium High High Medium Local Long term Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-11

727 Socio-economic

Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate

revenue for the municipality and the region as a whole

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Employment and economic growth Regional Short

term Medium High High Medium

73 COMPARATIVE ASSESSMENT OF IMPACTS

During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as

low during operation after mitigation

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 8-1

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

As a tenant operating in the IDZ Casa Steel will be required to comply with all

current and future CDC requirements as well as with the relevant conditions of

permits licences issued to CDC (eg Integrated Stormwater Masterplan for the

eastern side of the Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)

In particular the CDC has its own requirements regarding the monitoring of certain

aspects of the project such as the quality of the effluent and the noise levels These

have been incorporated into the EMP

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 9-1

9 ENVIRONMENTAL IMPACT STATEMENT

All predicted negative impacts can be mitigated to a low significance The only

exceptions are biodiversity as the construction of the plant will result in the

destruction of habitat and loss of fauna and flora and noise impacts inherent to

construction activities Mitigation measures have been included in the EMP for these

impacts and they have a medium significance post-mitigation

Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium to

long term similar impacts are likely to occur due to ongoing developments in the IDZ

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 10-1

10 CONCLUSION AND RECOMMENDATIONS

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as

other infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified

and assessed No fatal flaws have been identified

It is recommended that the project be approved subject to the conditions listed in

chapter 9 and adherence to the EMP requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 11-1

11 REFERENCES

Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ

Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants

Bennie JS (2010) The historical component (built environment) of the Heritage

Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port

Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report

compiled for Eastern Cape Heritage Consultants

Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater

Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay

Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage

Consultants

BKS (2006) Coega Industrial Development Zone Transport Study Volume 3

Demand Modelling Report Final Draft

Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I

Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6

Report compiled for SRK Consulting

Coastal amp Environmental Services (2010) Environmental Impact Assessment for the

Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone

Volume 3 Environmental Impact Assessment Report CES Grahamstown

Coega Development Corporation (2008) Industry Waste Management Plan -

Strategic Master Plan Report

Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants

Report No CDCSHE 03 8122

Department of Water Affairs and Forestry (1998) Waste Management Series

ldquoMinimum Requirements For The Handling Classification And Disposal Of

Hazardous Wasterdquo Second Edition

Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising

Plant in the Coega Industrial Development Zone

Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the

Coega Industrial Development Zone (IDZ) Specialist Water Study

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 11-2

Jacobs E (2008) Final Environmental Impact Report and Draft Environmental

Management Plan Proposed Steel Recycling and Processing Facility within the

Coega IDZ Report compiled for SRK Consulting

Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY

Galvanising Plant in the Coega Industrial Development Zone Waste Management

and Hazardous Substances Report compiled for ILISO Consulting

RSA National air quality standard for thoracic particulates (PM10) SA standards

(Government Gazette No 32816)

von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed

Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape

Report compiled for ILISO Consulting

von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel

Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report

compiled for ILISO Consulting

Additional sources

Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed

Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared

for Coastal Environmental Services

Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed

Kalagadi Manganese smelter in the Coega Industrial Development Zone Port

Elizabeth Eastern Cape Province Report prepared for Coastal Environmental

Services

Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia

steel recycling facility at the Coega Industrial Development Area Port Elizabeth

Prepared for SRK Consulting Port Elizabeth

APPENDIX A

LIST OF INTERESTED AND

AFFECTED PARTIES

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

DEDEARegional Manager

and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza

DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza

DEA Ocean and

CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza

DEA Ocean and

Coast

Oceanographer land-

based sources of

marine pollution

Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza

DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza

CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza

CDCEnvironmental

Project

Manager

Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza

TNPAPort of Ngqura

Environmental

Manager

Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet

NMBMEnvironmental

ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza

NMBMEnvironmental

ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza

DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza

DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza

WESSASenior Conservation

Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza

Zwartkops

ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700

hughlauegmailcom

zwartkopstrustiafricacom

SANParksNational Marine

CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza

Department Of

LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza

NMBM Air Quality

Division

Assistant

DirectorAir

Pollution and Noise

Templeton Titima 079 490 0574 Ttitimamandelametrogovza

NMBM Air Quality

DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza

NUMSARegional

RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

Department of

HealthNadiema

van der

Bergh083 378 2103

nadiemavanderberghimpiloecprovgov

za

DWA Chief Services

Officer

Joseph Jacobs 041 586 4884 jjacobsdwafgovza

EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza

NUMSecretary of union

officesZandile Xhentsa 043 743 6597 zxhentsanumorgza

DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza

Dynamic

CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom

EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza

Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza

UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom

lprincezago2uticom

Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza

Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza

Absa Mr Johann Steyn 082 3775820 johannstabsacoza

Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza

PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza

Universal

EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza

Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza

GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom

Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza

NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom

DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza

DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza

TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet

DWA Mr Landile Jack JackLdwagovza

DWA Ms Lizna Fourie FourieL4dwagovza

APPENDIX B

NOTICE OF ATMOSPHERIC

EMISSIONS LICENCE APPLICATION

AND ADVERTISEMENT

APPENDIX C

NOTICE OF COMMENT PERIOD FOR

DRAFT SCOPING REPORT

APPENDIX D

SUMMARY OF ISSUES RAISED AND

RESPONSES THERETO

April 2012

1

PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL

DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))

IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt

AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt

This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses

provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process

conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the

Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

2

IssueCommentQuestion Date

received Origin Response

1 Please provide more information with respect to the potential

dangers including the toxicity of the proposed project

07032011

By email

Wayne Poulton

(Bosun Brick

tenant at the

IDZ)

An Environmental Impact Assessment (EIA) was undertaken

which assessed the potential toxicity of the emissions and

effluent Mitigation measures were also recommended in the draft

Environmental Management Programme (EMP) to avoid

minimise or compensate any significant impacts The Draft

Environmental Impact Report and draft EMP were made available

to stakeholders for comment in March 2012

2 Do you have a Background Information Document (BID) or

similar that provides more information on the project

27032011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The BID was sent to all registered IampAPs on 4 May 2011

3 The RoD issued to the CDC on 632007 for the change in

land use for the remaining area of the Coega IDZ includes a

number of requirements with respect to

atmospheric emissions that should be considered in the

Atmospheric Emissions Licence (AEL) application such as

prohibiting and monitoring where possible visible emission

plumes to the atmosphere In particular the

recommendations on pp87-91 of the final revised Scoping

Report dated Nov 2006 must be implemented (clause 421)

04042011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

We have obtained copies of the documents referred to and ensure

that these requirements were taken into account in the

environmental assessment and AEL application

4 If the Port of Ngqura is used for import and export the scope

of the traffic impact assessment (TIA) should also include the

port

10052011

By email

Elliot

Motsoahole

(TNPA Port of

Ngqura)

The scope of the TIA was extended to include port related traffic

The TNPA at the Port of Ngqura was consulted and does not

have any objection to the project TNPA has indicated that the

development would require a minimum number of vessels per

year which would have minimal impact on the Port operations

However due notice would have to be given to the Port of Ngqura

before a vessel is scheduled to arrive so that the vessel can be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

3

IssueCommentQuestion Date

received Origin Response

accommodated at an available berth

5 Concerns with respect to potential stormwater pollution

draining into the Coega catchment and the port of Ngqura

The port needs to be dredged and heavy metals present a

risk in that regard

16052011

By

telephone

Andrew Lucas

(Department of

Water Affairs)

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination by effluent waste or

hazardousdangerous substances is very low

Thus no metals oils or other contaminants are expected to be

present in the stormwater

However stormwater pollution can occur in exceptional

circumstances such as accidents and emergencies The

emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

6 All steel sheets bathing unit must be under roof

7 The sludge out of the decreasing bath will be high in Na and

pH Therefore handling and disposal must be clarified up front

in this project

8 Per se the wastewater from decreasing bath will have high

ph and the component from the pickling unit will have low ph

Then it may be assumed that both streams will neutralize

each other Please then clarify proposed sewer discharge

with Nelson Mandela Bay Municipality up-front for acceptance

of influent as per the documented proposal

9 Pickling may result in dissolved metals How does your team

expect to deal with this As it is planned for discharge into

24052011

By email

Landile Jack

(Department of

Water Affairs)

All bathing units will be under roof

Effluent from the degreasing and pickling baths will be discharged

to the wastewater treatment plant The respectively alkaline and

acidic effluents will mix and neutralise each other in the

wastewater treatment plant Calcium or gypsum will be added if

required to complete the neutralisation process Effluent from the

treatment plant will be discharged to sewer Contact has been

made with the relevant officials and the Municipalityrsquos

requirements have been obtained The effluent discharged to

sewer will notably comply with the applicable discharge standards

Traces of metals (eg iron) may be present but will not exceed

prescribed thresholds The necessary authorisation will be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

4

IssueCommentQuestion Date

received Origin Response

sewer Clarity and acceptance needs to be agreed with

Nelson Mandela Bay Municipality Who owns the sewer

10 Quenching unit will results to Zinc particles How will this

affect sewer discharge This again must be dealt with within

the negotiations with the Municipality

11 Once all has been agreed with the Municipality and at the

same time due negotiations must be done with hazardous

waste courier and disposal facility to accept the hazardous

waste identified in all production lines

12 Of note is the low volume of the proposed WWTW facility ie

250 cubmweek And the no discharge of the quenching

water ie over-flow and cooling only Hence Zinc particles

generation

obtained from the municipality

The sludge from the treatment plant will be collected by a licensed

service provider and disposed of at a permitted site

The quenching bath will be periodically emptied (every 6 months)

and the water discharged will go to the water treatment plant Zinc

particles will settle in the sludge which will be disposed of at a

permitted site

Contact has been made with EnviroServ who manages the

Aloes II HH waste site regarding collection and disposal of

hazardous waste (See waste management report)

13 Investigate the potential effects of toxicity andor influence of

emissions waste and hazardous substances both in

terrestrial and marine fauna

14 With regards to water usage where is the plant going to

extract its waters used in galvanization andor waste

management process ie rainfall rivers or even from the

sea) and which avenues would be more environmental

friendly and effective

31052011

By email

A Bewana

(SANPARKS)

Emissions waste and hazardous substances are not expected to

affect terrestrial or marine ecosystems The air quality study

concluded that atmospheric emissions would not be harmful to

human health and by extension terrestrial fauna There are no

standards for air quality for defining faunal impacts therefore by

ensuring that standards for humans are complied with the impact

on fauna is deemed to be acceptable In this case the impact of

emissions on terrestrial and marine fauna are thus not significant

Solid and liquid wastes both general and hazardous as well as

hazardous substances will be stored handled and disposed of

appropriately to as not to cause harm to terrestrial or marine

fauna

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

5

IssueCommentQuestion Date

received Origin Response

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination and hence land-based

marine pollution by effluent waste or hazardousdangerous

substances is very low

The risk of emissions waste and hazardous substances to

terrestrial and marine fauna is thus very low

However pollution of terrestrial and marine ecosystems can occur

in exceptional circumstances such as accidents and emergencies

The emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

The CDC has an agreement with the NMBM to supply potable

water to the Coega IDZ Currently the infrastructure to supply

return effluent (RE) to the IDZ is not in place therefore Casa Steel

will be supplied with potable water up until such time as the

following 2 options of RE are available

1) Upgrading of the existing Fishwater Flats waste water

treatment works (between IDZ amp PE) including RE plant

and infrastructure to pipe RE to the IDZ (EIA for the

upgrade is underway)

2) Construction of a new waste water treatment works

including RE plant in Zone 9 of the Coega IDZ

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option should be investigated further between Agni and Casa The

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

6

IssueCommentQuestion Date

received Origin Response

CDC can facilitate discussions between the 2 investors

Compliance with CDC Permits amp Requirements

15 It should be made clear that tenants will be required to

comply with CDC requirements and the relevant conditions of

permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water

Licence for its Storm Water Systems on the

East Side of the Coega River that tenants will

need to take cognizance of The contents of the

ldquoIntegrated Stormwater Masterplan for the

eastern side of the Coega IDZ Oct 2010rdquo

especially the Table of best practice p53

onwards may need to be taken cognizance of

o CDC is developing an Operations

Environmental Management Plan that will place

certain obligations on tenants

16 Environmental audits and data collected during monitoring

(eg stack emissions stormwater) will need to be shared with

CDC

Air Emissions

17 Presumably permanent in stack monitoring will be required in

terms of AEL permit requirements

18 Abnormal operating conditions resulting in air emissions ndash I

could find nothing in the EIR to indicate under what

circumstances these could occur (eg start-up) potential

frequency and duration and the impact on ambient air quality

ndash these events usually result in the most problems wrt air

emissions

09042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

15 Compliance with the CDCrsquos Permits amp Requirements has

been included explicitly as a requirement in the EIR (p8-1) and

EMP (pp18 and 25) in the following terms

ldquoAs a tenant operating in the IDZ Casa Steel will be required to

comply with all current and future CDC requirements as well as

with the relevant conditions of permits licences issued to CDC

(eg Integrated Stormwater Masterplan for the eastern side of the

Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)rdquo

16 The need to communicate with the CDC on monitoring and

auditing activities was emphasised in Chapter 8 of the EMP The

following paragraphs were added

ldquoDuring construction the environmental officer will be responsible

for monitoring compliance with the EMP and authorisation

conditions and keeping records as required in the EMP andor

authorisation conditions

The ECO will conduct site inspections every two weeks audit the

records kept by the environmental officer and submit an

environmental compliance report every two months to the

authorities and the CDC (via the Environmental Monitoring

Committeersquos ECO)

During operation the health and safety officer will monitor

compliance with the EMP and the conditions of the Environmental

Authorisation Data collected during monitoring activities and any

environmental audits conducted will be shared with authorities

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

7

IssueCommentQuestion Date

received Origin Response

Water

19 Large volumes of (2000 m3mth) of water are required of

which only 400m3 needs to be potable The NMBM return

effluent system will provide non-potable water once it is

constructed What other water recycling initiatives can be

utilized to reduce potable water requirements (the ISWMP for

the eastern side of the Coega IDZ has some best practice

guidelines collecting rainwater from the roof etc)

General

20 There is no mention of how the CDC Architectural Guidelines

will be incorporated into the development (eg to prevent a

stark uniform warehouse type development)

21 Does NMBM have adequate fire services to cover this

development Apart from the large petroleum store are there

any other large fire hazards

22 Reports from the tenantrsquos ECO during construction and from

the SHE Officer during operations should be channeled to the

Coega Environmental Monitoring Committee This can be

directly or preferably via the EMCrsquos ECO (this will be while

the EMC and ECO are in place) A precedent has been set

for this in the Environmental Authorisations for Agni-Steel and

Kalagadi Manganese Smelter

23 All mitigation actions emanating from the EIR should be

summarized (preferably in a table) If compliance with them is

to be part of the Environmental Authorization from DEDEAT

then they (or the ones that DEDEAT deems to be applicable)

and the CDC (via the Environmental Monitoring Committeersquos

ECO)

The ECO (during construction) and the health and safety officer

(during operation) will report to the Coega Environmental

Monitoring Committee (EMC) via the EMCrsquos ECO (this will be

while the EMC and ECO are in place)rdquo

17 The draft EMP recommends regular monitoring of emissions

from the scrubbers and from the chromating process Additional

emissions monitoring requirements will be confirmed once the

AEL is issued Mention has been made in the EMP (pp11 and 19)

that all AEL conditions including monitoring and reporting

requirements should be adhered to

18 Abnormal emissions can occur in exceptional circumstances

Start-up will not cause abnormal emissions as the scrubbers

will be commissioned first and will be functioning once the plant

starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions

would be emitted as a building fugitive

The hourly hydrogen chloride ground level concentrations

(directly offsite) were predicted to be 239 microgmsup3 (based on the

emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits

as stipulated for listed activities for galvanising processes) using a

screen model which assumes worst case meteorological

conditions The health effect screening level for hourly HCl

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

8

IssueCommentQuestion Date

received Origin Response

should be attached to the EA as an Appendix (otherwise no

one knows about them or takes cognizance of them)

concentrations is 2100 microgmsup3 Assuming abnormal emissions

emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset

conditions will still be well within the health effect screening

levels

Similarly the hourly particulate emissions from the building

fugitives during upset conditions would amount to 293 microgmsup3

(based on the emission limits as stipulated for listed activities for

galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1

January 2015) directly off-site

Therefore if emissions are 5 times higher normal they will still be

within health effect screening levels and the daily PM10 NAAQS

levels

In the case of a fire a cocktail of gases and particulates could be

emitted and could be over the recommended levels This

situation will however be dealt with as an emergency and

normalised as quickly as is possible

The above has been added to the impact identificationdescription

and assessment sections of the EIR

19 The CDC has an agreement with the NMBM to supply

potable water to the Coega IDZ Currently the infrastructure to

supply return effluent to the IDZ is not in place therefore Casa

Steel will be supplied with potable water up until such time as the

infrastructure is in place

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

9

IssueCommentQuestion Date

received Origin Response

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option will be investigated further between Agni and Casa The

CDC has come forward to facilitate discussions between the two

investors

Other water recycling initiatives such as rainwater harvesting

have been considered but are not practical

20 The CDCrsquos Architectural and Landscape Design guidelines

contain requirements pertaining to such aspects as the height

orientation and mass and form of buildings as well as guidelines

for landscaping and signage in order to ensure an attractive

development and achieve an architectural integrity within the

Coega IDZ The plans for the proposed galvanizing plant will be

submitted to the Design Review Committee for approval as

required by the CDC

21 Casa Steel will be required to install fire hydrants according

to the NMBMrsquos standardsrequirements The CDC will provide

potable water (up until such time as return effluent is available)

and a connection to the boundary of the site which will be

connected to the fire hydrants The installation of the fire hydrants

will require approval by the Metrorsquos Fire Chief as was done for

Agni-Steel one of the investors in Zone 6

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

10

IssueCommentQuestion Date

received Origin Response

The Coega IDZ falls within the NMBM and therefore the rates and

taxes paid by the CDC covers the fire services for which the Metro

is responsible Currently the Metro has sufficient capacity to

provide fire services to the tenants within the IDZ This was

confirmed in discussion with the CDCrsquos Infrastructure

Development Unit It is however unknown at which point the

Metrorsquos Disaster Management Plan would not be able to

accommodate servicing tenants in the IDZ

The LNG burner is the only major fire hazard on the plant

22 See response to item 16 above

23 Key mitigation and management measures emanating from

the EIR were recapitulated in Chapter 9 of the EIR to form part of

the conditions attached to the Environmental Authorization from

DEDEAT All mitigation measures recommended as a result of the

impact assessment are presented in a table in the draft EMP

which is appended to the EIR (Appendix J)

24 Hydrogen chloride is one of the main emissions There are no

ambient air quality guidelines for HCl and the EIR says

concentrations will be well within health parameters

However the main problem with HCl is its corrosive effect -

there is absolutely no mention of this in the draft EIR nor air

specialist report

There needs to be some sort of comment assessment as to

whether HCl emissions are likely to impact on for example

the adjacent Agni-Steel Plant wrt corrosion - their factory

structure will be made of steel

11042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The atmospheric corrosion of metals is a complex process with

both the extent of deterioration and the mechanisms varying

considerably depending on the metal Depending on the way

pollutants are transported from the atmosphere to the corroding

surface two types of deposition processes are recognized in

atmospheric corrosion ndash dry deposition and wet deposition Wet

deposition refers to precipitation whereas dry deposition refers to

the remaining processes including gas phase deposition and

particle deposition The most important pollutants acting as

corrosive agents are sulphur and nitrogen compounds including

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

11

IssueCommentQuestion Date

received Origin Response

The EIR specialist rpt suggests monitoring HCl at ground

level on the property boundary and this is supported in case

there are complaints from neighbours

secondary pollutants and particulates Pollutants can contribute to

corrosivity individually however there may be a synergistic effect

when more than one of these pollutants is present in the

environment being affected In the field of atmospheric corrosion

sulphur dioxide is the single most investigated gaseous pollutant

and the quantification of the direct contribution of sulphur dioxide

to the corrosion process of metallic materials is comparatively well

understood (Tidblad amp Kucera 1998)

Very little work has reported on the effect of HCl on the

degradation of materials in the environment with no local dose-

response thresholds developed for corrosion occurring due to HCl

exposures This is probably because HCl which is present

outdoors in markedly reduced concentrations when compared

with SO2 has not been considered to contribute to significant

degradation of materials (Syed 2006) For this reason the

incremental corrosion due to HCl from the Coega Galvanising

Plant cannot be quantified

25 It is unacceptable for ILISO to be using CDC maps (see

figure 9 ndash pg5-6) without these maps being referenced

accordingly particularly when it appears that a CDC map has

been used and then overlaid with features by an unknown

author (ie CASA steel site Port (where the boundaries

depicted are incorrect) and a North legend which is out of

keeping with the overall cartographic intent of the original

work

26 Figure 10 is not referenced appropriately and I believe that I

commented previously in respect to references to roads not

12042012

By email

Graham Taylor

(Spatial

Development

Manager -

Infrastructure

Development

CDC)

This has been rectified in the final version of the report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

12

IssueCommentQuestion Date

received Origin Response

yet built As a result Figure 10 is confusing and clarity needs

to be provided in terms of referencing In addition the Port

shape is irregular and similar to the comment above

27 I acknowledge the emergency preparedness and response

plan but please confirm that this includes pro-active routine

monitoring of storm water leaving your premises to verify that

your assumptions of clean storm water are correct

13042012

By post

Andrew Lucas

(Director

WRampU

Department of

Water Affairs)

Pro-active routine monitoring of stormwater leaving the premises

will be undertaken This has been explicitly emphasised in

chapter 8 of the draft EMP

28 Will portablechemical toilets be used during construction

29 What provisions have been made for storm water drainage

during construction

18042012

By

telephone

Department of

Water Affairs

Port Elizabeth

Chemical toilets will be used during construction

The Casa Steel site will be located at the corner of two roads

drainage of stormwater from the site will take place through the

roadsrsquo drainage system

From Lea September [mailtoleailisocom]

Sent 11 March 2011 0935 AM

To Wayne Poulton

Cc Terry Baker

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Wayne

An Environmental Impact Assessment (EIA) will be undertaken for this project during the

next 10 to 12 months

We foresee that some of the key environmental impacts of the project will be in terms of air

quality water quality waste and hazardous substances

At this stage I am not able to give you any details regarding the potential toxicity of the

emissions andor effluent However specialist studies will be conducted as part of the EIA

that will determine the key impacts of the project Mitigation measures will also be identified

to avoid minimise or compensate any significant impacts

You are registered on the stakeholder database and you will be kept informed of progress in

the EIA process you will notably get the opportunity to access the reports produced and

provide any feedback on them

Please feel free to contact me should you need any further information

Best regards

Lea September

From Wayne Poulton [mailtowaynepbosuncoza]

Sent 07 March 2011 1257 PM

To Lea September

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

Please can you provide me with some more information as to the potential dangers including

the toxicity of this

Kind regards

Wayne

From Lea September [mailtoleailisocom]

Sent 04 March 2011 1123

To Lea September

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 March 2011 0745 AM

To Paul Martin

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 05 April 2011 0847 AM

To Paul Martin

Cc Terry Baker Renee von Gruenewaldt

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Thank you Paul for this information

I have downloaded a copy of the RoD and Scoping report you referred to and will make sure

these requirements are taken into account in the environmental assessment

Best regards

Lea September

From Paul Martin [mailtopmartinaxxesscoza]

Sent 04 April 2011 0955 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Further to my comments on 27311

Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in

the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega

IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised

scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions

including prohibiting and monitoring where possible visible emission plumes to the atmosphere

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Paul Martin

Sent Monday March 28 2011 745 AM

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 10 May 2011 0327 PM

To ElliotMotsoaholetransnetnet

Cc Terry Baker

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Mr Motsoahole

Thank you for your input on this issue

The Port of Ngqura will indeed be used for import and export At the moment the scope of

the traffic impact assessment only covers road traffic I have however relayed the matter to

our traffic specialist and we will consider this issue in the finalization of the Scoping Report I

will keep you informed of any developments in that regard

I trust this is acceptable to you

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]

Sent 10 May 2011 0855 AM

To Lea September

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

It has been noted that Casa Steel will source steel coils from various markets internationally and

in South Africa and the bulk of the plantrsquos production output will be exported to African countries

However there is no mention of logistic requirements

Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will

be used the scope of traffic impact assessment should also include the port

Regards

From Lea September [mailtoleailisocom]

Sent 04 May 2011 0747 AM

To Lea September

Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

Please find attached a letter announcing the EIA process underway for the proposed 80 000

tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as

a Background Information Document (BID) outlining the details of the project

Please contact me should you require any further information on this project

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

Elliot Motsoahole

Manager - Environment

Transnet National Ports Authority

Port of Nqqura

Port Control Building Klub Road Port Elizabeth 6212

PO Box 612054 Bluewater Bay 6212

+27 41 507 8450

+27 86 674 7729

Cell +27 83 542 5619

E-mail Elliotmotsoaholetransnetnet

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

DISCLAIMER The information contained in this communication is subject to copyright and

intended only for the use of leailisocom Unauthorised use disclosure or copying is

strictly prohibited Should a virus infection occur as a result of this communication the sender

will not be liable If you have received this communication in error please notify

elliotmotsoaholetransnetnet

From Lea September [mailtoleailisocom]

Sent 25 May 2011 1147 AM

To Jack Landile (ELS)

Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi

Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Landile

Thank you for your input

Contact has been made with the relevant Municipal Directorate and we will follow up with

them to obtain clarifications on all these issues

I have added both Lizna and yourself on the database and will keep you updated on

progress on this project

Best regards

Lea September

From Jack Landile (ELS) [mailtoJackLdwagovza]

Sent 24 May 2011 0524 PM

To Fourie Lizna (ELS)

Cc Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Hi Lizna

I missed you on this sorry

I linked Pieter twice Instead

Regards

Landile

From Jack Landile (ELS)

Sent 24 May 2011 0445 PM

To leailisocom

Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Lea

The e-mail you sent to Mr Kooverji dated 19 May 2011 refer

Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are

All steel sheets bathing unit must be under roof

The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project

Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal

Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer

Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality

Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines

Of note is the low volume of the proposed WWTW facility ie 250 cubmweek

And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles

generation

Regards

Landile

From Lea September [mailtoleailisocom]

Sent 19 May 2011 0947 AM

To Lea September

Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Stakeholder

Please find attached the remaining appendices to the draft Scoping report for the proposed

80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 June 2011 0411 PM

To Aphiwe Bewana

Subject RE Proposed 80 000 TPY Galvanizing plant in Coega

Dear Mr Bewana

Thank you for your input and apologies for the late reply

We have taken note of your comments and are will be taking them forward in the EIA phase

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Aphiwe Bewana [mailtoaphiwebewanagmailcom]

Sent 31 May 2011 1205 PM

To Lea September

Subject Re Proposed 80 000 TPY Galvanizing plant in Coega

Comment

Re Proposed 80 000 TPY Galvanizing plant in Coega

As SANParks we would like the EIA phase to investigate the potential effects of toxicity

andor influence of emissions waste and hazardous substances both in terrestrial and

marine fauna In the draft scoping report reference has been made with regards to the

terrestrial fauna but there is no attention to potential effects to marine fauna

Equally with regards to water usage where is the plant going to extract its waters used in

galvanization andor waste management process ie rainfall rivers or even from the sea)

and which avenues would be more environmental friendly and effective

Regards

Aphiwe Bewana

Marine Planner

South African National Parks

POBox 76693

NMMU

Port Elizabeth

6031

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 06 July 2011 1031 AM

To Lea September

Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Hi Lea

Irsquove reviewed the Final Scoping Report Herewith a few comments

1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the

Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a

revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the

NMBLP Please include only those in the IDZ as part of your IAP list

Regards

Andrea

From Lea September [mailtoleailisocom]

Sent Wednesday July 06 2011 859 AM

To Lea Septemberrsquo

Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Dear Stakeholder

The final scoping report for the above-mentioned project (attached) is available for comment

until 27 July 2011

The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic

commentaryrdquo tab

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 09 April 2012 1159 AM

To Lea September

Subject Comments on Galvanising Plant EIR Coega IDZ

Lea

Attached are my comments on the Draft EIR for the Coega IDZ galvanising

plant

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

Email attachment

COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ

Dr Paul Martin PO Box 61029

Bluewater Bay 6212 Tel 041 4665698

Email pmartinaxxesscoza

Compliance with CDC Permits amp Requirements

It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of

o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants

Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC

Air Emissions

Presumably permanent in stack monitoring will be required in terms of AEL permit requirements

Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions

Water

Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)

General

There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)

Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards

Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter

All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 11 April 2012 1245 PM

To Lea September

Subject Fw Comments on Galvanising Plant EIR Coega IDZ

Lea

One other comment on that I have on the Galvanising Plant Draft EIR

Hydrogen chloride is one of the main emissions There are no ambient air

quality guidelines for HCl and the EIR says concentrations will be well

within health parameters

However the main problem with HCl is its corrosive effect - there is

absolutely no mention of this in the draft EIR nor air specialist report

There needs to be some sort of comment assessment as to whether HCl

emissions are likely to impact on for example the adjacent Agni-Steel

Plant wrt corrosion - their factory structure will be made of steel

The EIR specialist rpt suggests monitoring HCl at ground level on the

property boundary and this is supported in case there are complaints from

neighbours

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Paul Martin ltpmartinaxxesscozagt

To Lea September ltleailisocomgt

Sent Monday April 09 2012 1158 AM

Subject Comments on Galvanising Plant EIR Coega IDZ

gt Lea

gt

gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising

gt plant

gt

gt

gt Dr Paul Martin

gt PO Box 61029

gt Bluewater Bay 6212

gt Tel 041 4665698

gt Cell 0732524111

gt email pmartinaxxesscoza

gt

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 12 April 2012 1139 AM

To Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Hi Lea

Hope yoursquore keeping well

I have requested comments from my colleagues and the CDC Casa team on the Draft EIR

Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report

Regards

Andrea

From Graham Taylor

Sent Thursday April 12 2012 838 AM

To Andrea Von Holdt Firhana Sam

Cc Johan Fourie Maria van Zyl Melikhaya Sihawu

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Andrea Firhana

Firhana if you could please ensure that the co-ordinates provided in the EIR correspond

with our records (pages 4-1 amp 4-2)

My comments are as follows

It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work

Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above

Regards

Graham Taylor

Spatial Development Manager - Infrastructure Development

Mobile 0832283055

Office 0414030454

Facsimile 0865185033

Email GrahamTaylorcoegacoza

Website wwwcoegacom

right PLACE | right TIME | right CHOICE

This email and all contents are subject to the following disclaimer

httpwwwcoegacomemaildisclaimerhtml

From Lea September [mailtoleailisocom]

Sent 04 May 2012 0411 PM

To Andrea Von Holdt

Cc Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Dear Andrea

We have taken note of the comments from the GIS Unit These issues have been rectified in

the final version of the EIR

Please can you forward to the relevant persons at the GIS Unit

Thank you

Best regards

Lea September

APPENDIX E

BACKGROUND INFORMATION

DOCUMENT

APPENDIX F

AIR QUALITY IMPACT ASSESSMENT

APPENDIX G

TRAFFIC IMPACT ASSESSMENT

APPENDIX H

WASTE MANAGEMENT AND HAZARDOUS

SUBSTANCES SPECIALIST STUDY

APPENDIX I

WATER QUALITY SPECIALIST STUDY

APPENDIX J

ENVIRONMENTAL MANAGEMENT

PROGRAMME

Page 7: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 v

EXECUTIVE SUMMARY

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone

(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province

Galvanizing consists of coating steel with zinc in order to protect it from corrosion An

Environmental Impact Assessment (EIA) is required as the proposed project involves several

activities listed in terms of Section 24 of the National Environmental Management Act

(NEMA) 107 of 1998 as amended and requires an environmental authorisation The

project also involves activities listed in terms of the National Environmental Management Air

Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008

which respectively require an Atmospheric Emissions Licence and a Waste Management

Licence

The Scoping and Environmental Impact Assessment process underway covers all aspects of

the project and informs all three applications

Scoping was the first phase of investigations and aimed to inter alia identify potential key

environmental issues and impacts to be addressed in the EIA phase

The following environmental issues and potential impacts identified in the Scoping Phase

were investigated in the EIA

Air quality

The galvanizing process generates atmospheric emissions which are regulated in terms

of the National Environmental Management Air Quality Act and appropriate measures

are required in order to adhere to the applicable standards Other sources of impact on

air quality include emissions from the LNG burner emissions and dust from the transport

of steel and other materials in trucks as well as dust and gas emissions related to

construction activities Mitigation measures recommended in the EMP will ensure that air

quality impacts are kept to a minimum and compliance with emissions standards is

maintained

Biodiversity and conservation

Certain types of vegetation in the IDZ are of high conservation importance Protected

species will be rescued as per the CDCrsquos requirements

Water quality

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through spills

or leaks This risk can however be minimized if not avoided altogether through design

choices (bunded areas) and the adherence to best practice guidelines for the handling or

the transport of hazardous substances and waste

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vi

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

Waste management and hazardous substances

The plant will generate a relatively small amount of solid waste which will be re-used

recycled or disposed of in accordance with the EMP recommendations

There will be a wastewater treatment plant on site which will neutralise process water

(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer

Hazardous waste from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site

at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and

removed on a monthly basis is limited to 10 m3

A number of substances classified as hazardous are used in the galvanizing process and

the transport and handling of these is subject to certain rules and guidelines

In addition the permanent storage of a high quantity of liquid petroleum on site (20 000

litres at any one time) is subject to certain specifications and requires approval from the

municipality

Health and safety

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling of the various substances used will be done in

accordance with applicable instructions (cf material safety data sheets)

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as provide

site supervision including executing tests (individual test cold run and hot run) during 3

months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the EMP

Traffic

In the operational phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and from

the Port of Ngqura

The traffic expected to be generated during construction as well as operation is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low and

the total traffic generated by Casa Steel is also relatively low

The impact on port traffic is also negligible and well within the portrsquos capacity

Socio-economic aspects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vii

The proposed galvanizing plant will make a positive contribution by creating jobs during

construction and operation and generating business for the various service providers

Fatal flaws

No fatal flaws have been identified

The significance of these potential key environmental impacts were assessed in the EIA

phase and the findings of this phase of investigations are presented in this report

The main findings of the EIA are as follows

During construction impacts post-mitigation are low with the exception of noise and

biodiversity as the construction of the plant will result in the destruction of habitat

and loss of fauna and flora and noise impacts inherent to construction activities

Mitigation measures have been included in the EMP for these impacts and they have

a medium significance post-mitigation

All impacts were assessed as low during operation after mitigation

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium

to long term similar impacts are likely to occur due to ongoing developments in the

IDZ

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

The CDC has its own requirements regarding the monitoring of certain aspects of the

project such as the quality of the effluent and the noise levels These have been

incorporated into the EMP Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as other

infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified and

assessed No fatal flaws have been identified

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 viii

It is recommended that the project be approved subject to the conditions listed above

and adherence to the EMP recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-1

1 INTRODUCTION

11 BACKGROUND

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)

Nelson Mandela Bay Municipality Eastern Cape Province

The demand for galvanised steel products is high in South Africa and Africa and is

expected to increase in the foreseeable future From an economic point of view the

proposed project has therefore been found to be viable

Casa Steel will source the steel coils from various markets internationally and in

South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is

destined to be exported mainly to African countries

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

An Environmental Impact Assessment (EIA) is required as the proposed project

involves several activities listed in terms of Section 24 of the National Environmental

Management Act (NEMA) No 107 of 1998 as amended and requires an

environmental authorisation

The following listed activities requiring environmental authorisation have been

identified

Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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 metres

Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped

land to industrial use greater than 1 ha but less than 20 ha in size outside an

urban area

Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any

process or activity requiring a license in terms of national or provincial legislation

governing the generation or release of emissions

Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5

hectares or more of vegetation where 75 or more of the vegetative cover

constitutes indigenous vegetation except where such removal of vegetation is

required for

(i) purposes of agriculture or afforestation inside areas identified in

spatial instruments adopted by the competent authority for

agriculture or afforestation purposes

(ii) the undertaking of a process or activity included in the list of waste

management activities published in terms of section 19 of the

National Environmental Management Waste Act 2008 (Act No 59

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-2

of 2008) in which case the activity is regarded to be excluded from

this list

(iii) the undertaking of a linear activity falling below the thresholds in

Notice 544 of 2010

Hot dip galvanizing is a listed activity in terms of section 21 of the National

Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires

an Atmospheric Emissions Licence (AEL)

In addition the treatment of wastewater with an annual throughput capacity of more

than 2000 m3 is a listed activity in terms of the National Environmental Management

Waste Act 59 of 2008 and requires a waste management licence

ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental

Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact

Assessment process in terms of section 24 of NEMA for the construction and

operation of the proposed galvanizing plant The EIA process covers all aspects of

the project and informs all three applications (for environmental authorisation waste

management licence and AEL)

13 PURPOSE OF THIS REPORT

This report builds on the scoping report submitted to the Eastern Cape Department of

Economic Development and Environmental Affairs (DEDEA) and the Nelson

Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It

describes the proposed project and presents the findings of the second phase of

investigations (EIA phase)

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT

PRACTITIONER (EAP)

The EIA was managed by Ms Terry Baker a certified Environmental Assessment

Practitioner with 20 years of working experience She has a MA in Environmental

Management and specialises in Environmental Impact Assessments and Project

Management She has been involved in a variety of different types of EIAs including

for water supply projects dams transmission lines roads and airports in South

Africa Botswana Uganda Lesotho and Mozambique She has been involved in

water resource management and public participation programmes on a number of

projects Terry has also been involved in the use of Geographic Information Systems

environmental status quo reports water quality assessments socio-economic and

institutional development projects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-3

15 PROJECT TEAM

In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen

(water quality specialist) and Lea September (EAP) with specialist input from Renee

von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous

substances) and Seniel Pillay (Traffic Impact Assessor)

The Business Unit Head of the ILISO Environmental Management Discipline Group

Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is

a Fellow of the South African Institution of Civil Engineers a member of the South

African Society of Aquatic Scientists of the Environmental Scientific Association of

the International Water Association of the Water Institute of South Africa and of the

Vaal River Catchment Association He is a certified Environmental Assessment

Practitioner with 30 years experience who specialises in project management

environmental impact assessments and water resource planning He specifically has

extensive experience in water quality especially water quality management water

quality monitoring and water quality assessment Martin has experience in managing

projects that involve multi-disciplinary teams and public consultation and

participation in South Africa and abroad

Lea September is an Environmental Assessment Practitioner with a Masters degree

in Environmental Management She has experience in impact assessment and

environmental management and has been responsible for drafting impact

assessment reports and Environmental Management Programmes and conducting

public participation processes as well as high level environmental screenings for a

variety of projects in the energy water transport and industrial sectors

Renee von Gruenewaldt has nine-years experience in the field of air pollution

impact assessment and air quality management Prior to becoming involved in air

quality consultation she was part of the Highveld Boundary Layer Wind Research

Group based at the University of Pretoria Since joining Environmental Management

Services (the company now Airshed Planning Professionals) she has undertaken

numerous air pollution impact studies and has provided extensive guidance to both

industry and government on air quality management practices

Pieter Smuts graduated as a Civil Engineer and became involved in the field of

municipal engineering and infrastructure construction He has specialized during the

last twelve years in solid waste management He has completed waste management

plans feasibility studies and final designs of waste management facilities in South

Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and

the review of the Mavoco hazardous waste landfill design in Maputo Mozambique

and completed a study on hazardous waste (textile factory sludge) management in

Maseru Lesotho

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-4

Seniel Pillay is a transportation engineer with over 16 years experience in

transportation planning and traffic engineering He has been involved in a wide

range of projects ranging from developing the Transport Operations Plan for the

FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System

for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller

traffic impact assessments for inter alia road improvement schemes Of particular

relevance to this project his experience includes Heavy Goods Vehicle Study for

eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact

Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash

Preliminary Transportation Assessment

16 STRUCTURE OF THIS REPORT

The proposed project and the alternatives considered are described in Chapter 2

Chapter 3 details the approach adopted for the EIA phase

The biophysical and socio-economic environment affected by the activity is described

in Chapter 4

The environmental impacts identified are discussed in Chapter 5

The EIA methodology is described in Chapter 6 and Chapter 7 presents the results

of the impact assessment

The environmental impact statement is presented in Chapter 8

Finally Chapter 9 spell out the conclusions and recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-1

2 DESCRIPTION OF THE PROPOSED PROJECT

21 TECHNICAL ASPECTS

211 The galvanizing process

Galvanizing consists of coating steel with zinc in order to protect it from corrosion

Before steel strips can be galvanized they undergo a pre-treatment in order to

ensure that the steel sheets are free from any surface oxides as they enter the

molten zinc coating Bath This is done by removing the oil from the steel sheets (in

the degreasing unit) and then removing the rust from the surface of the sheet (in the

pickling unit)

The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The

melting zinc on the strip surface will be cooled and solidified through air cooling in the

cooling tower

Finally the galvanised steel sheets are dipped into a water quenching tank in order to

further cool the sheets from about 150degC to 40degC

It is possible to make galvanised steel more durable by chromating it Approximately

50 of the galvanised steel production output will receive chromate passivation

treatment after quenching the galvanised steel sheets will be sprayed with a chrome

solution (3 kgcm2)

After galvanizing and chromating the steel sheets are cut to achieve the desired coil

size and weight and transported to the storage yard

The process flow diagram below (Figure 1) illustrates the main stages of the

galvanizing process and indicates the major inputs and outputs as well as the

resulting effluent and atmospheric emissions

Draft Environmenal Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-2

Figure 1 Process flow diagram for proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-3

212 Main inputs and outputs in operational phase

In view of the above the main inputs will be as follows

Steel coils 85 000 tonsyear

Zinc 870 tonsyear

Electricity 2500 kVA

Water 2000 m3month (of which 400 m3 will be potable water)

Liquid Natural Gas (LNG) 270 NM3hour

Sodium hydroxide (NaOH) 1000 m3year

Hydrochloric acid (HCl) 800 m3year

Chrome (Cr+3) 10 m3year

The main outputs will be

Galvanized steel 80 000 tonsyear

Scrap metal 20 tonsyear

General waste 65 tonsyear

Hazardous waste 2 m3month

Wastewater 012 Mlweek

Atmospheric emissions lt 5 ppm

213 Installations on site

The bulk of the operations involved in the galvanizing process occur along a

continuous galvanizing line (See Figure 2 below) which is the main piece of

machinery required for the proposed galvanising plant

Figure 2 Continuous Galvanizing Line

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-4

Water is one of the major inputs and is used throughout the galvanizing process notably

for rinsing and cooling purposes and as a mixing agent for the various chemical

solutions The plant will have a water treatment plant on site to treat the water used in

the various processes (approx 250 m3

of wastewater per week) The wastewater

treatment facility will be operated by a professional water treatment company as Casa

Steel does not have the required expertise in house to treat its process water Sulphuric

acid (H2SO4) is used as part of the treatment process to reduce caustic soda The

neutralised water is discharged to the sewer while any sludge is disposed of as

hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)

will be disposed of

Some critical areas of the galvanizing process such as the zinc pot require uninterrupted

power It is therefore proposed to install an LNG burner to maintain the zinc bath at a

temperature of between 450 and 460degC

22 LOCATION OF THE PROPOSED GALVANIZING PLANT

The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast

of Port Elizabeth in the Eastern Cape (Figure 3)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-5

Figure 3 Location of the proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-6

23 NEED AND DESIRABILITY

The profitability of the proposed project has been established by Casa Steel and a

pre-feasibility study has confirmed that the proposed project was feasible from a

technical and financial point of view The Coega IDZ is specifically designed to host

facilities such as a galvanizing plant and can provide the necessary infrastructure

and services to its investors It therefore constitutes a very suitable location for the

project

24 ALTERNATIVES IDENTIFIED

Zone 6 has been specifically earmarked for heavy ferrous metal industries and is

therefore a suitable location for the proposed galvanizing plant as such no site

alternatives have been provided for and assessed in this EIA However prior to the

commencement of the EIA process Casa Steel was presented with a number of

different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the

selection of the site were

(a) The dimensions of the land the site should be at least 200 m long and

50 m wide in order to accommodate the galvanizing line and adjacent lay

down area and additional land should be available next to the site for future

expansion

(b) The fiscal arrangements applying to the site the site should be located

within the future Custom Controlled Area (CCA) as the bulk of the

production output of the plant will be exported

The no-go alternative is assessed in this report

25 CONSTRUCTION ASPECTS

The construction phase of the project will take about 12 months and will essentially

consist of erecting a building to house the galvanizing line and other equipment and

preparing a concrete laydown area adjacent to the building

The CDC will provide an access point from the existing tarred road that will lead to

the site

Approximately 100 workers from the surrounding areas will be contracted for the

construction work

The requirements in terms of services during construction are listed below

Water 1000 m3month

Electricity 2500 kVA

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-7

The CDC will provide temporary services for the construction phase including a

conservancy tank for flush toilets Sewage infrastructure will only be provided for the

operational phase

26 OPERATION ASPECTS

Before the plant can become fully operational the equipment and machinery will be

tested for approximately 3 months The supplier will supervise these tests as part of

the transfer of know-how and training of staff on the plant

Casa Steel will start operating the plant at a reduced capacity (about 50 000

tonsyear) for a period of time (mostly determined by market aspects) before bringing

production to full capacity (80 000 tonsyear) This is done by operating the line for

longer hours

Approximately 50 to 60 people will be working on the plant Approximately 6-10 of

these will be unskilled 40-45 skilled and about 5 people in managerial positions

The requirements in terms of services during operation are as follows

Water 2000 m3month

Electricity 2500 kVA

Effluent discharge 24 m3day

The CDC has entered into agreements with the municipality to secure the provision

of services such as water and electricity to its tenants Tenants in the IDZ have their

own agreements with the NMBM for electricity while the agreements for water and

sewage are with the Facilities Unit of the CDC

Regarding discharge of wastewater to the sewer the municipality indicated that the

only requirement is that the water discharged complies with applicable municipal

discharge standards

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 3-1

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT

31 OBJECTIVES

The main objectives of the EIA phase are to

Assess the significance of the environmental issues and impacts identified in the

scoping phase focusing on key impacts

Recommend appropriate measures to mitigate negative impacts and enhance the

benefits and include them in the draft EMP

Undertake a public participation process that provides opportunities for all

interested and affected parties (IampAPs) to be involved

32 AUTHORITY CONSULTATION

The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental

Liaison Committeersquo (ELC) which comprises representatives of various authorities

including DEDEAT the Department of Environmental Affairs (DEA) and Department

of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the

Coega Development Corporation (CDC) and Transnet National Ports Authority

(TNPA) The ELC has been specifically formed to facilitate EIA applications in the

IDZ

Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to

the clearance of vegetation should be included in the application A formal request

was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the

application and all registered stakeholders were informed of the request in writing on

19 October 2011

33 PUBLIC PARTICIPATION PROCESS CONDUCTED

On-site notices were replaced by a notification displayed on the CDCrsquos digital notice

board at the business centre in Zone 1 of the IDZ The eNotice was placed on

13 April 2011 and will remain for the full duration of the EIA process

Registered stakeholders will be notified in writing of the availability of the draft EIA

report and EMP which will also be advertised in a local newspaper Stakeholders

including state departments and the public will have forty (40) days to comment on

the draft EIA report and EMP The draft EIA report and EMP will be sent by email

where possible and made available for download on the ILISO website

(wwwilisocom)

A summary of all issues and comments received during the stakeholder consultation

process as well as of correspondence in that regard will be captured in an Issues

and Responses Report that will form an Appendix to the EIA Report

The list of registered IampAPs is included in Appendix A

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 3-2

34 LEGISLATION AND GUIDELINES CONSIDERED

The following legislation and guidelines were considered in the preparation of this

report

National Environmental Management Act Act No 107 of 1998

NEMA EIA Regulations 2010

National Environmental Management Air Quality Act Act No 39 of 2004

National Environmental Management Waste Act Act No 59 of 2008

Hazardous Substances Act Act 15 of 1993

Occupational Health and Safety Act Act 85 of 1993

Hazardous Chemical Substances Regulations 1995 (GNR 1179)

Major Hazard Installation Regulations 2001 (GNR 692)

National Water Act Act 36 of 1998

National Heritage Resources Act Act 25 of 1999

DEAT Integrated Environmental Management Information Series 1-5 and 12-15

NEMA draft Implementation Guideline

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Public Participation (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Alternatives (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Draft Guideline for Determining the Scope of Specialist

Involvement in EIA Processes (2005)

IAIA guidelines

National air quality standard for thoracic particulates Government Gazette

No 32816

Listed activities and associated minimum standards identified in terms of section

21 of the National Environmental Management Air Quality Act Act No 39 of

2004 Government Notice 248 of 2009

Minimum Requirements for the Handling Classification and Disposal of

Hazardous Waste DWAF Waste Management Series (1998)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-1

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION

The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega

IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay

to the north of the N2 highway between Port Elizabeth and Grahamstown east of the

Coega River

The co-ordinates of the corners of the site are shown in Table 1

Table 1 Coordinates of site corners for the proposed galvanizing plant

Point Longitude Latitude

A 25deg411126E 33deg45587S

B 25deg411156E 33deg45499S

C 25deg411938E 33deg45131S

D 25deg412174E 33deg45481S

E 25deg412508E 33deg45979S

F 25deg412634E 33deg451160S

G 25deg411782E 33deg451560S

H 25deg411692E 33deg451428S

J 25deg411314E 33deg45868S

Figure 4 Zone layout in the Coega IDZ

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-2

Figure 5 Site location

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-3

42 SOCIO-ECONOMIC CHARACTERISTICS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the

NMBM There are no residents within the IDZ

As far as the broader NMBM and Eastern Cape Province are concerned the

following can be noted The NMBM is located within the Eastern Cape Province the

2nd largest Province in South Africa (3rd in terms of population) characterised by a

predominantly black population with low incomes and high levels of unemployment

(CES 2010)

The NMBM has a population of just above 11 million and covers an area of

1 950 km2 It is the main urban and industrial centre of the province and Port

Elizabeth in particular which forms part of the NMBM is the commercial capital of

the Eastern Cape 52 of the NMBM population is female and 37 is below the

age of 20 these two groups are particularly affected by unemployment

43 BIOPHYSICAL CHARACTERISTICS

431 Surface and ground water

No rivers occur in Zone 6 There is however a natural attenuation pond on the

southern most part of the site which will have to be avoided

The IDZ is underlain by calcrete sand and gravel deposits that overlie low

permeability clays These clays limit the vertical infiltration of rainwater and induce a

horizontal groundwater flow towards the Coega River channel which is the most

significant surface water feature in the Coega IDZ Consequently rapid run-off takes

place following precipitation (Jacobs 2008)

Groundwater levels at Coega are generally about 3 to 5 m below surface ie just

above the contact between the permeable sands and the underlying impermeable

clays The groundwater flow direction is to the southeast following the surface water

drainage direction (Jacobs 2008)

432 Climate and atmospheric conditions

Port Elizabeth has a warm temperate climate and the temperature ranges are not

extreme Exceptionally high temperatures may be experienced during berg wind

conditions which occur frequently during autumn and winter Extreme temperatures

also occur during summer with little accompanying wind

The wind regime for the area largely reflects the synoptic scale circulation with

dominant westerly and northwesterly flow fields representing the pre-frontal

conditions and south-westerly flow fields representing the frontal conditions The

south-easterly and south-westerly wind flow (land breeze) increases during daytime

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-4

conditions with westerly and north-westerly wind flow increasing during the night (sea

breeze)

The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of

Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15

km southwest) and Port Elizabeth (~23 km southwest)

An ambient air monitoring network has been established in the Coega IDZ which

consists of three monitors Saltworks Motherwell and Amsterdamplein Although

NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative

impacts due to the proposed Galvanising Plant is PM10 A maximum daily average

PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed

SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3

was exceeded on 17 days in 2007 and 26 days in 2008

Existing sources of emissions in the vicinity of the proposed galvanizing plant include

industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other

fugitive dust sources (von Gruenewaldt 2011b)

433 Geology and soils

Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel

and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly

limestone and conglomerate

434 Terrestrial ecology

This section draws from the EIA report compiled for the Agni Steel (formerly Afro-

Asia) steel processing facility which is adjacent to the proposed site for the

galvanizing plant (Jacobs 2008)

The area consists largely of grasses succulents and scrubby bush with alien

species making up the greater part of the more dense vegetation

Zone 6 falls within the inland vegetation and is characterised by a vegetation type

referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the

Coega IDZ and has been found to have three times the level of endemism of other

vegetation communities in the Coega IDZ Bontveld therefore has a high

conservation status Two Bontveld conservation areas have been identified within the

IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)

Bontveld that will be destroyed as a result of development in the IDZ will be given

conservation status in these two areas

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-5

Figure 6 Coega IDZ Open Space Management Plan (OSMP)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-6

Certain areas in the IDZ are invaded by alien plant species The most common

invader species is rooikrans (Acacia cyclops) which presently forms large

monospecific stands in areas throughout the Coega IDZ There are several other

aliens present that pose a threat to the flora of this area including the prickly pear

(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)

Loss of vegetation and alien plant invasion due to human activity has resulted in a

reduction in the diversity of terrestrial fauna

The majority of mammals present in the Coega IDZ are small or medium-sized Of

the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed

gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of

Algoa Bay however it is not considered threatened The gerbil is common in

foredune and dune thicket habitat in the Coega region and is therefore unlikely to

occur on the proposed site

A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird

species are resident or common to the area Most diversity occurs in the thicket

although the coastal area also supports specialised avifauna Two species of tern

the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well

as the Cape gannet (Morus capensis) and the African penguin (Spheniscus

demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne

caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant

(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser

flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns

are two of the most endangered coastal species in South Africa Other bird species

of conservation concern include the Whitefronted plover (Charadrius marginatus)

African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus

bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus

ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides

paradisea) Breeding pairs of Damara terns and African black oyster catchers have

been observed in the coastal dunes of the IDZ but should not be affected by

developments that fall outside the dune areas

The Eastern Cape supports nearly a third (approximately 133 species) of the reptile

species recorded in South Africa More than half of the Eastern Capersquos endemic

reptile species occur in the Algoa Bay area giving the region a high conservation

value A total of 63 reptile species are believed to occur within the Coega IDZ The

majority of these are found in Succulent Thicket and riverine habitats Only a few

reptile species occur in the coastal dunes and estuarine habitats More than a third of

the species are described as relatively tolerant of disturbed environments provided

that migration corridors of suitable habitat are maintained to link pristine habitats

Twenty two reptiles are of special concern including five endemic species (two of

which may also be endangered) four endangered sea turtles eight species listed

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-7

with CITES one rare species and four species at the periphery of their range

Fourteen of these species of special concern are confirmed as occurring on or within

2 km of the Coega IDZ

A total of 32 amphibian species and sub-species occur in the Eastern Cape

representing almost a third of the species recorded in South Africa However none of

the species are endemic or Red Data Book species Based on previous studies in the

area it is estimated that approximately 17 amphibian species occur within the Coega

IDZ Four species are listed as peripheral but none are threatened internationally

These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog

(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and

the bubbling kassina (Kassina senegalensis)

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated

vegetation has not been extensively studied One grasshopper species Acrotylos

hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue

(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis

pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in

four localities in the Eastern Cape one of which is within the Coega IDZ The Coega

copper Aloeides clarki is endemic to this particular region of the Eastern Cape and

is currently known to occur in three localities two of which are in the Coega IDZ The

localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the

Coega IDZ and their distributions were taken into account when defining Coegarsquos

open space system and Development Framework Plan

435 Land use and topography

The land is currently undeveloped and earmarked for industrial development The

site is relatively flat ranging from an elevation of 66 masl on the northern-most

corner to 59 masl at the southern-most corner

436 Heritage and archaeological survey

Extensive studies have been undertaken in Zone 6 with respect to heritage aspects

Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a

2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond

2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is

currently being finalised

Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing

Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha

in extent and was located next to the R102 road to Motherwell Kaplan conducted

HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi

Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will

now be located in Zone 5)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-8

The various archaeological investigations reached similar observations and

conclusions Stone tools of various densities and types were found throughout the

zone The majority of the stone tools were mainly of Earlier and Middle Stone Age

and occasional Later Stone Age origins (Figure 4)

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble

gravels exposed by tracks in Zone 6 (Source Binneman 2010)

The stone tools which comprised of quartzite flakes chunks flaked pebblecobble

and cores were randomly distributed across the landscape and are in secondary

context There were no lsquoconcentrationsrsquo of tools observed which suggested any

spatial patterning or activity areas although these may be present or covered by soil

and vegetation

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 5-1

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED

The following environmental issues and potential impacts were identified in the

Scoping phase

51 AIR QUALITY

The galvanizing process generates atmospheric emissions with particulates and

hydrogen chloride representing the main pollutants of concern The plant is fitted with

air extraction as well as scrubber systems which are designed to retain the bulk of

pollutants and particles for each of the processes in such a way that less than 5 ppm

of gases and particles will be released into the atmosphere after the fume scrubber

Other sources of impact on air quality include emissions from the LNG burner as well

as emissions and dust from the transport of steel and other materials in trucks

Construction activities will also create dust and gas emissions due to the clearing of

groundcover tipping of material to storage pile levelling of area wind erosion from

storage piles vehicle and construction equipment activity and tailpipe emissions

from vehicles and construction equipment such as graders scrapers and dozers

Overall the air quality impact assessment (Gruenewaldt 2011b) found that

The predicted particulate oxides of nitrogen carbon monoxide and sulphur

dioxide concentrations are all below the National Ambient Air Quality Standards

for all averaging periods

The predicted off-site concentrations of hydrogen chloride are well below the

most stringent effect screening levels

No odour threshold exceedances for hydrogen chloride were predicted to occur

due to routine operations at the Steel Galvanising Plant The South Wales

Environmental Protection Authority stipulates that an odour unit of 20 is

acceptable for urban areas The odour unit would be lt10 directly off-site for

hydrogen chloride

Abnormal emissions can occur in exceptional circumstances Start-up will not

cause abnormal emissions as the scrubbers will be commissioned first and will be

functioning once the plant starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions would be emitted as a

building fugitive

The hourly hydrogen chloride ground level concentrations (directly offsite) were

predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based

on the emission limits as stipulated for listed activities for galvanising processes)

using a screen model which assumes worst case meteorological conditions The

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-2

health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming

abnormal emissions emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset conditions will still

be well within the health effect screening levels

Similarly the hourly particulate emissions from the building fugitives during upset

conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for

listed activities for galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly

off-site

Therefore if emissions are 5 times higher normal they will still be within health effect

screening levels and the daily PM10 NAAQS levels

In the case of a fire a cocktail of gases and particulates could be emitted and could

be over the recommended levels This situation will however be dealt with as an

emergency and normalised as quickly as is possible

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS

The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of

its heritage potential and there are no proposed protected geosites in Zone 6

Should any artefacts be discovered during construction procedures stipulated in the

draft EMP will apply

53 BIODIVERSITY AND CONSERVATION

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

In terms of terrestrial fauna the CDCrsquos open space management plan provides for

the preservation of certain corridors The destruction of certain habitats as a result of

the development will therefore not automatically result in the loss of certain species

54 WATER QUALITY

There is a natural attenuation pond on the southern most part of the site which will be

avoided

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through

spills or leaks

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-3

This risk can however be minimized if not avoided altogether The floor of the factory

will be designed as a bunded area to contain any spills and the entire process will be

contained Potential spills or leaks will therefore be contained and will not impact on

water resources Storm water is therefore considered clean water under normal

operational conditions An oil trap will be placed at the exit of the site to ensure that

no grease from the laydown area enters the stormwater system

Spills and leaks can occur during the handling or the transport of hazardous

substances Best practice guidelines will be followed to ensure that this risk is

adequately managed

Wastewater discharged to sewer will be treated to comply with municipal discharge

standards and is not expected to have an impact on the chemical characteristics of

the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be

discharged from the plant is small in relation to the total volume received at the

Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works

(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently

operated at 61 of its capacity which is approximately 80 Mℓday Thus the

0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore

not have any significant impact on the WWTW

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES

The plant will generate a relatively small amount of solid waste in the form of scrap

metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)

The scrap metal may be sold to other steel processing facilities such as Agni Steel

which will be located next to the plant or collected and disposed of with the rest of

the solid waste by a licensed service provider

As mentioned previously there will be a wastewater treatment plant on site which will

neutralise process water (012 Mlweek) in order to ensure it is of a standard

acceptable for discharge to sewer Waste in the form of sludge from the

neutralization or spent acid must be disposed of as a hazardous waste Solid waste

from the filters used for air quality control is also in this category These wastes can

usually be tested and then delisted which means that it can be placed in a general

purpose landfill

Hazardous effluent from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-

site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored

and removed on a monthly basis is limited to 10 m3

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-4

A number of substances classified as hazardous are used in the galvanizing process

(Table 2) and the transport and handling of these is subject to certain rules and

guidelines In particular the material safety data sheets (cf Appendix H) should be

referred to for inter alia hazards identification accidental release measures

handling and storage precautions exposure controlpersonal protection ecological

information and transport information The Hazardous Chemical Substances

Regulations 1995 should also be adhered to in respect of the transport and storage

of hazardous chemical substances

Table 2 Hazardous materials to be used on site

Major Input Materials

Substance

listed in the

SABS 0228

Group II

hazardous

substances

Volumes to be

stored on site at

any one time

Diesel radic 2000 litres

Liquid petroleum radic 20 000 liters

Sodium hydroxide (NaOH)

(used for degreasing) 8 radic 1000m

3

Hydrochloric acid (HCI)

(used for pickling) 8 radic 800m

3

Zinc (used for galvanising) - TBD

Trivalent chromium (CR+3

)

(used for chromating) 8 radic 10m

3

Sulphuric acid (H2SO4) (used for

treatment of waste water on site) 8 radic TBD

Ammonium Hydroxide (NH4OH) 8 radic TBD

TBD ndash To be determined

Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one

time) and is classified as a flammable substance Specification for flammable storage

facilities in accordance with the requirements of the Nelson Mandela Bay

Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for

quantities between 5000 and 20 000 liters the substance must be kept in a

flammable liquid store which complies with the requirements of a specification

obtainable from the Department Some of the requirements are

Flammable liquid and solid storage facilities are only permitted on the ground

floor

Decanting of flammable liquids and solids are not permitted within any building

Due to the fact that there are flammable materials on site a certificate may be

required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and

Emergency Services Department to confirm that facilities for flammable storage

are in accordance with their requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-5

Because of the permanent installation and high quantity of liquid petroleum on site

the Major Hazard Installation Regulations 2001 promulgated under the Occupational

Health and Safety Act No 85 of 1993 applies A written application for approval of

the installation is required to be submitted to the chief inspector Department of

Labour provincial director Department of Labour and NMBM prior to construction

In addition a risk assessment should be formulated covering all hazardous materials

together with an emergency preparedness and response plan

56 HEALTH AND SAFETY

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling instructions as well as occupational exposure limits

are indicated in the material safety data sheets of the various substances used

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as

provide site supervision including executing tests (individual test cold run and hot

run) during 3 months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the

EMP

In addition the emergency preparedness and response plan will cover the health and

safety aspects related to emergency situations

57 TRAFFIC

The volumes of traffic at the IDZ are currently relatively low and variable depending

on the different zones in the IDZ however these volumes will increase as more

developments are implemented

The construction phase of the Casa Steel development will take about 12 months

and will essentially consist of erecting a building to house the galvanizing line and

other equipment and preparing a concrete laydown area adjacent to the building

The traffic that would be generated during the construction phase can be expected to

be less than the traffic that would be generated by the Casa Steel development when

it is fully operational

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-6

In the operation phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and

from the Port of Ngqura

The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the

Casa Steel development would be off Ring Road 1 The other roads of significance

for the Casa Steel development are the N2 Neptune Road MR435 and MR450

Access to the port is given by Neptune Road Road Link NEP-03 has not yet been

built

Figure 8 Coega IDZ road network identification

(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-7

Figure 9 Coega IDZ road network

Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No

01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-8

The distribution of freight trips is fixed as the majority of trips will be made between

the Port of Ngqura and the Casa Steel site With regard to personnel trips there are

various points of origins (the surrounding residential areas) that could be used by

staff going to the Casa Steel site The distribution of personnel trips is based on

existing traffic count information and is shown in Figure 10

Figure 10 Trip distribution for freight and personnel trips

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The resultant expected Casa Steel traffic assignment is shown in Figure 11

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-9

Figure 11 Morning peak hour Casa Steel development traffic

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The traffic that is expected to be generated by the Casa Steel development is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low

and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)

Consultation has taken place with Transnet Port Authority (TPA) to establish the

impact of the galvanizing plant operations on traffic inside the port The additional

ships entering and exiting the port of Ngqura as a result of the proposed development

will have a negligible impact on port traffic and TPA indicated that it would be well

within the portrsquos capacity

58 NOISE

Noise is not foreseen to be a significant issue insofar as the noise levels inside the

plant and at the boundary of the site will not exceed the limits prescribed by the CDC

Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels

during the day and 60 decibels at night

Mitigation of noise impacts will be addressed in the design of the noise-emitting

components of the plant and their enclosures

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-10

59 SOCIO-ECONOMIC ASPECTS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of

NMBM There are no residents within the IDZ

The direct socio-economic impacts of the proposed project are thus limited to the

employment generated by the project during construction and operation Job creation

remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)

and the IDZ and Port of Ngqura are expected to become a significant catalyst to the

economic growth of the Municipality and the region with current investments at

Coega creating more jobs and stimulating the economy

In this context the proposed galvanizing plant will make a positive contribution

towards the achievement of these goals

There will be 50 to 60 employees during operation phase distributed as follows

Figure 12 Casa Steel organisation chart

Even though a large part of the inputs will be imported and the bulk of the production

output will be exported there will be some positive impacts for the economy of the

region and of South Africa in general Notably the requirements of the plant for

water electricity waste collection and disposal waste water treatment and transport

for example will create business for the various service providers and have an

indirect impact on employment and fiscal revenues as a result

From a visual impact point of view it can be anticipated that the landscape in the IDZ

will be significantly affected over time by developments related to the establishment

of the port and various industries

HEAD ( WORKS )

MGR ( COMM) MGR ( ADMNHR ) Manager marketing

MANAGER OPERATION MANAGER MANAGER MANAGER Q C

AC FIN PUR ampSTORE

PPC SH-GALV SH-tech

SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF

1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO

JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF

2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO

WORKERS WORKERS 7NOS

15 7

RAW MAT amp

DESP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 6-1

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY

A description of the nature of the impact any specific legal requirements and the

stage (constructiondecommissioning or operation) will be given Impacts are

considered to be the same during construction and decommissioning The

significance of the potential impacts will be considered before and after identified

mitigation is implemented

The following criteria will be used to evaluate significance

Nature The nature of the impact will be classified as positive or negative and

direct or indirect

Extent and location Magnitude of the impact and is classified as

Local the impacted area is only at the site ndash the actual extent of the activity

Regional the impacted area extends to the surrounding immediate and

neighbouring properties

National the impact can be considered to be of national importance

Duration This measures the lifetime of the impact and is classified as

o Short term the impact will be for 0 ndash 3 years or only last for the period of

construction

o Medium term three to ten years

o Long term longer than 10 years or the impact will continue for the entire

operational lifetime of the project

o Permanent this applies to the impact that will remain after the operational

lifetime of the project

Intensity This is the degree to which the project affects or changes the

environment and is classified as

o Low the change is slight and often not noticeable and the natural functioning

of the environment is not affected

o Medium The environment is remarkably altered but still functions in a

modified way

o High Functioning of the affected environment is disturbed and can cease

Probability This is the likelihood or the chances that the impact will occur and

is classified as

o Low during the normal operation of the project no impacts are expected

o Medium the impact is likely to occur if extra care is not taken to mitigate

them

o High the environment will be affected irrespectively in some cases such

impact can be reduced

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 6-2

Confidence This is the level knowledgeinformation the environmental impact

practitioner or a specialist had in hisher judgement and is rated as

o Low the judgement is based on intuition and not on knowledge or

information

o Medium common sense and general knowledge informs the decision

o High Scientific and or proven information has been used to give such a

judgment

Significance Based on the above criteria the significance of issues will be

determined This is the importance of the impact in terms of physical extent and

time scale and is rated as

o Low the impacts are less important

o Medium the impacts are important and require attention mitigation is

required to reduce the negative impacts

o High the impacts are of great importance Mitigation is therefore crucial

Cumulative Impacts The possible cumulative impacts will also be considered

Mitigation Mitigation for significant issues is incorporated into the EMP for

construction

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 7-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS

71 IMPACTS DURING CONSTRUCTION

711 Air quality

Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris

handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine

particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural

operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks

and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)

Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Fugitive particulate emissions (dust)

related to construction activities Regional

Short

term Medium High High Medium Regional

Short

term Low High High Low

Construction vehicle gas emissions Regional Short

term Medium High High Medium Regional

Short

term Low High High Low

712 Heritage and archaeological resources

Naturedescription of impact excavation activities may impact on unidentified heritage resources

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-2

Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based

on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments

Heritage and archaeological

resources Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on unidentified heritage

resources Local

Short

term

Medium -

high Low High Low

713 Biodiversity and conservation

Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation

importance and cause soil contamination

Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species

Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan

and has compiled a list of protected species to be rescued (see draft EMP)

Biodiversity and conservation Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Loss of fauna and flora Local Perma

nent

Medium -

high High High High Local

Permanen

t Medium High High Medium

Soil contamination Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-3

714 Water related impacts

Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater

runoff spills and leaks Soil erosion

Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of

spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste

disposal Stormwater quality monitoring (see draft EMP)

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Soil erosion Local Short

term Medium Medium High Medium Local

Short

term Medium Low High Low

715 Waste management

Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed

Commentmitigation see draft EMP and waste management plan

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-4

Waste management Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Local

Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

716 Health and safety

Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Short

term

Medium -

high

Medium -

high High High Local

Short

term

Medium -

high Low High Low

717 Traffic

Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and

construction workers from surrounding areas and transport of equipment from the port

Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low

Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and

accurate estimates of quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-5

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Increased traffic on N2 and within the

IDZ Regional

Short

term Low High High Low

718 Noise

Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Short

term

Medium-

high High High Medium Local

Short

term Medium High High Medium

719 Socio-economic

Naturedescription of impact temporary employment will be created during the construction phase

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-6

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Temporary employment Regional Short

term Medium High High Medium

72 IMPACTS DURING OPERATION

721 Air quality

NatureDescription of impact gas and particulate emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning

Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local

sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and

veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute

to background fine particulate concentrations (von Gruenewaldt 2011b)

Assumptions and limitations Potential release of CR6+

As no emission factors are available for trivalent chromium processing the

potential impacts due to these activities could not be quantified

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Dust emitted from traffic on paved roads Regional Long Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-7

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

term

Hydrogen chloride emissions from

pickling process Local

Long

term Low High High Low

Particulate emissions (smoke) from

galvanizing process (due to the

volatilization of flux)

Local Long

term Low High High Low

Particulate oxides of nitrogen carbon

monoxide and sulphur dioxide emissions

from LNG burner

Local Long

term Low High High Low

Nuisance related to odour Local Long

term Low Low High Low

Abnormally high hydrogen chloride and

particulate emissions due to scrubber

malfunction

Local Short

term Medium Low High Medium

Gases (eg SOx NOx CO etc) and

smoke emitted in case of a fire Local

Short

term High Low High Medium

722 Water quality

NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks

Commentmitigation see draft EMP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-8

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Stormwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

723 Waste management and hazardous substances

NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous

waste both can affect environmental quality and human health

Commentmitigation see draft EMP and waste management plan

Waste management and hazardous

substances Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Regional

Long

term High

Medium -

high High High Regional Long term High Low High Low

Soilwaterair pollution due to improper

transport storage and handling of

hazardous substances

Regional Long

term High

Medium -

high High High Regional Long term High Low High Low

Health hazard Local Long

term High

Medium -

high High High Local Long term High Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-9

724 Health and safety

Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Long

term

Medium-

high

Medium-

high High High Local Long term

Medium-

high Low High Low

725 Traffic

Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on

the road network

Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak

hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road

network within Zone 6 of the IDZ (Iliso 2011)

Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)

Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of

quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-10

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on traffic and capacity of the N2 Regional Long

term Low High High Low

Impact on traffic and capacity of ring

road 1 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR435 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR450 Local

Long

term Low High High Low

Impact on traffic and capacity of

Neptune road Local

Long

term Low High High Low

726 Noise

Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Long

term Medium High High Medium Local Long term Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-11

727 Socio-economic

Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate

revenue for the municipality and the region as a whole

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Employment and economic growth Regional Short

term Medium High High Medium

73 COMPARATIVE ASSESSMENT OF IMPACTS

During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as

low during operation after mitigation

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 8-1

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

As a tenant operating in the IDZ Casa Steel will be required to comply with all

current and future CDC requirements as well as with the relevant conditions of

permits licences issued to CDC (eg Integrated Stormwater Masterplan for the

eastern side of the Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)

In particular the CDC has its own requirements regarding the monitoring of certain

aspects of the project such as the quality of the effluent and the noise levels These

have been incorporated into the EMP

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 9-1

9 ENVIRONMENTAL IMPACT STATEMENT

All predicted negative impacts can be mitigated to a low significance The only

exceptions are biodiversity as the construction of the plant will result in the

destruction of habitat and loss of fauna and flora and noise impacts inherent to

construction activities Mitigation measures have been included in the EMP for these

impacts and they have a medium significance post-mitigation

Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium to

long term similar impacts are likely to occur due to ongoing developments in the IDZ

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 10-1

10 CONCLUSION AND RECOMMENDATIONS

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as

other infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified

and assessed No fatal flaws have been identified

It is recommended that the project be approved subject to the conditions listed in

chapter 9 and adherence to the EMP requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 11-1

11 REFERENCES

Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ

Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants

Bennie JS (2010) The historical component (built environment) of the Heritage

Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port

Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report

compiled for Eastern Cape Heritage Consultants

Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater

Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay

Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage

Consultants

BKS (2006) Coega Industrial Development Zone Transport Study Volume 3

Demand Modelling Report Final Draft

Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I

Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6

Report compiled for SRK Consulting

Coastal amp Environmental Services (2010) Environmental Impact Assessment for the

Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone

Volume 3 Environmental Impact Assessment Report CES Grahamstown

Coega Development Corporation (2008) Industry Waste Management Plan -

Strategic Master Plan Report

Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants

Report No CDCSHE 03 8122

Department of Water Affairs and Forestry (1998) Waste Management Series

ldquoMinimum Requirements For The Handling Classification And Disposal Of

Hazardous Wasterdquo Second Edition

Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising

Plant in the Coega Industrial Development Zone

Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the

Coega Industrial Development Zone (IDZ) Specialist Water Study

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 11-2

Jacobs E (2008) Final Environmental Impact Report and Draft Environmental

Management Plan Proposed Steel Recycling and Processing Facility within the

Coega IDZ Report compiled for SRK Consulting

Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY

Galvanising Plant in the Coega Industrial Development Zone Waste Management

and Hazardous Substances Report compiled for ILISO Consulting

RSA National air quality standard for thoracic particulates (PM10) SA standards

(Government Gazette No 32816)

von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed

Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape

Report compiled for ILISO Consulting

von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel

Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report

compiled for ILISO Consulting

Additional sources

Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed

Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared

for Coastal Environmental Services

Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed

Kalagadi Manganese smelter in the Coega Industrial Development Zone Port

Elizabeth Eastern Cape Province Report prepared for Coastal Environmental

Services

Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia

steel recycling facility at the Coega Industrial Development Area Port Elizabeth

Prepared for SRK Consulting Port Elizabeth

APPENDIX A

LIST OF INTERESTED AND

AFFECTED PARTIES

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

DEDEARegional Manager

and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza

DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza

DEA Ocean and

CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza

DEA Ocean and

Coast

Oceanographer land-

based sources of

marine pollution

Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza

DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza

CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza

CDCEnvironmental

Project

Manager

Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza

TNPAPort of Ngqura

Environmental

Manager

Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet

NMBMEnvironmental

ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza

NMBMEnvironmental

ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza

DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza

DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza

WESSASenior Conservation

Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza

Zwartkops

ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700

hughlauegmailcom

zwartkopstrustiafricacom

SANParksNational Marine

CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza

Department Of

LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza

NMBM Air Quality

Division

Assistant

DirectorAir

Pollution and Noise

Templeton Titima 079 490 0574 Ttitimamandelametrogovza

NMBM Air Quality

DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza

NUMSARegional

RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

Department of

HealthNadiema

van der

Bergh083 378 2103

nadiemavanderberghimpiloecprovgov

za

DWA Chief Services

Officer

Joseph Jacobs 041 586 4884 jjacobsdwafgovza

EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza

NUMSecretary of union

officesZandile Xhentsa 043 743 6597 zxhentsanumorgza

DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza

Dynamic

CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom

EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza

Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza

UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom

lprincezago2uticom

Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza

Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza

Absa Mr Johann Steyn 082 3775820 johannstabsacoza

Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza

PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza

Universal

EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza

Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza

GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom

Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza

NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom

DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza

DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza

TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet

DWA Mr Landile Jack JackLdwagovza

DWA Ms Lizna Fourie FourieL4dwagovza

APPENDIX B

NOTICE OF ATMOSPHERIC

EMISSIONS LICENCE APPLICATION

AND ADVERTISEMENT

APPENDIX C

NOTICE OF COMMENT PERIOD FOR

DRAFT SCOPING REPORT

APPENDIX D

SUMMARY OF ISSUES RAISED AND

RESPONSES THERETO

April 2012

1

PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL

DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))

IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt

AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt

This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses

provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process

conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the

Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

2

IssueCommentQuestion Date

received Origin Response

1 Please provide more information with respect to the potential

dangers including the toxicity of the proposed project

07032011

By email

Wayne Poulton

(Bosun Brick

tenant at the

IDZ)

An Environmental Impact Assessment (EIA) was undertaken

which assessed the potential toxicity of the emissions and

effluent Mitigation measures were also recommended in the draft

Environmental Management Programme (EMP) to avoid

minimise or compensate any significant impacts The Draft

Environmental Impact Report and draft EMP were made available

to stakeholders for comment in March 2012

2 Do you have a Background Information Document (BID) or

similar that provides more information on the project

27032011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The BID was sent to all registered IampAPs on 4 May 2011

3 The RoD issued to the CDC on 632007 for the change in

land use for the remaining area of the Coega IDZ includes a

number of requirements with respect to

atmospheric emissions that should be considered in the

Atmospheric Emissions Licence (AEL) application such as

prohibiting and monitoring where possible visible emission

plumes to the atmosphere In particular the

recommendations on pp87-91 of the final revised Scoping

Report dated Nov 2006 must be implemented (clause 421)

04042011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

We have obtained copies of the documents referred to and ensure

that these requirements were taken into account in the

environmental assessment and AEL application

4 If the Port of Ngqura is used for import and export the scope

of the traffic impact assessment (TIA) should also include the

port

10052011

By email

Elliot

Motsoahole

(TNPA Port of

Ngqura)

The scope of the TIA was extended to include port related traffic

The TNPA at the Port of Ngqura was consulted and does not

have any objection to the project TNPA has indicated that the

development would require a minimum number of vessels per

year which would have minimal impact on the Port operations

However due notice would have to be given to the Port of Ngqura

before a vessel is scheduled to arrive so that the vessel can be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

3

IssueCommentQuestion Date

received Origin Response

accommodated at an available berth

5 Concerns with respect to potential stormwater pollution

draining into the Coega catchment and the port of Ngqura

The port needs to be dredged and heavy metals present a

risk in that regard

16052011

By

telephone

Andrew Lucas

(Department of

Water Affairs)

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination by effluent waste or

hazardousdangerous substances is very low

Thus no metals oils or other contaminants are expected to be

present in the stormwater

However stormwater pollution can occur in exceptional

circumstances such as accidents and emergencies The

emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

6 All steel sheets bathing unit must be under roof

7 The sludge out of the decreasing bath will be high in Na and

pH Therefore handling and disposal must be clarified up front

in this project

8 Per se the wastewater from decreasing bath will have high

ph and the component from the pickling unit will have low ph

Then it may be assumed that both streams will neutralize

each other Please then clarify proposed sewer discharge

with Nelson Mandela Bay Municipality up-front for acceptance

of influent as per the documented proposal

9 Pickling may result in dissolved metals How does your team

expect to deal with this As it is planned for discharge into

24052011

By email

Landile Jack

(Department of

Water Affairs)

All bathing units will be under roof

Effluent from the degreasing and pickling baths will be discharged

to the wastewater treatment plant The respectively alkaline and

acidic effluents will mix and neutralise each other in the

wastewater treatment plant Calcium or gypsum will be added if

required to complete the neutralisation process Effluent from the

treatment plant will be discharged to sewer Contact has been

made with the relevant officials and the Municipalityrsquos

requirements have been obtained The effluent discharged to

sewer will notably comply with the applicable discharge standards

Traces of metals (eg iron) may be present but will not exceed

prescribed thresholds The necessary authorisation will be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

4

IssueCommentQuestion Date

received Origin Response

sewer Clarity and acceptance needs to be agreed with

Nelson Mandela Bay Municipality Who owns the sewer

10 Quenching unit will results to Zinc particles How will this

affect sewer discharge This again must be dealt with within

the negotiations with the Municipality

11 Once all has been agreed with the Municipality and at the

same time due negotiations must be done with hazardous

waste courier and disposal facility to accept the hazardous

waste identified in all production lines

12 Of note is the low volume of the proposed WWTW facility ie

250 cubmweek And the no discharge of the quenching

water ie over-flow and cooling only Hence Zinc particles

generation

obtained from the municipality

The sludge from the treatment plant will be collected by a licensed

service provider and disposed of at a permitted site

The quenching bath will be periodically emptied (every 6 months)

and the water discharged will go to the water treatment plant Zinc

particles will settle in the sludge which will be disposed of at a

permitted site

Contact has been made with EnviroServ who manages the

Aloes II HH waste site regarding collection and disposal of

hazardous waste (See waste management report)

13 Investigate the potential effects of toxicity andor influence of

emissions waste and hazardous substances both in

terrestrial and marine fauna

14 With regards to water usage where is the plant going to

extract its waters used in galvanization andor waste

management process ie rainfall rivers or even from the

sea) and which avenues would be more environmental

friendly and effective

31052011

By email

A Bewana

(SANPARKS)

Emissions waste and hazardous substances are not expected to

affect terrestrial or marine ecosystems The air quality study

concluded that atmospheric emissions would not be harmful to

human health and by extension terrestrial fauna There are no

standards for air quality for defining faunal impacts therefore by

ensuring that standards for humans are complied with the impact

on fauna is deemed to be acceptable In this case the impact of

emissions on terrestrial and marine fauna are thus not significant

Solid and liquid wastes both general and hazardous as well as

hazardous substances will be stored handled and disposed of

appropriately to as not to cause harm to terrestrial or marine

fauna

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

5

IssueCommentQuestion Date

received Origin Response

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination and hence land-based

marine pollution by effluent waste or hazardousdangerous

substances is very low

The risk of emissions waste and hazardous substances to

terrestrial and marine fauna is thus very low

However pollution of terrestrial and marine ecosystems can occur

in exceptional circumstances such as accidents and emergencies

The emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

The CDC has an agreement with the NMBM to supply potable

water to the Coega IDZ Currently the infrastructure to supply

return effluent (RE) to the IDZ is not in place therefore Casa Steel

will be supplied with potable water up until such time as the

following 2 options of RE are available

1) Upgrading of the existing Fishwater Flats waste water

treatment works (between IDZ amp PE) including RE plant

and infrastructure to pipe RE to the IDZ (EIA for the

upgrade is underway)

2) Construction of a new waste water treatment works

including RE plant in Zone 9 of the Coega IDZ

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option should be investigated further between Agni and Casa The

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

6

IssueCommentQuestion Date

received Origin Response

CDC can facilitate discussions between the 2 investors

Compliance with CDC Permits amp Requirements

15 It should be made clear that tenants will be required to

comply with CDC requirements and the relevant conditions of

permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water

Licence for its Storm Water Systems on the

East Side of the Coega River that tenants will

need to take cognizance of The contents of the

ldquoIntegrated Stormwater Masterplan for the

eastern side of the Coega IDZ Oct 2010rdquo

especially the Table of best practice p53

onwards may need to be taken cognizance of

o CDC is developing an Operations

Environmental Management Plan that will place

certain obligations on tenants

16 Environmental audits and data collected during monitoring

(eg stack emissions stormwater) will need to be shared with

CDC

Air Emissions

17 Presumably permanent in stack monitoring will be required in

terms of AEL permit requirements

18 Abnormal operating conditions resulting in air emissions ndash I

could find nothing in the EIR to indicate under what

circumstances these could occur (eg start-up) potential

frequency and duration and the impact on ambient air quality

ndash these events usually result in the most problems wrt air

emissions

09042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

15 Compliance with the CDCrsquos Permits amp Requirements has

been included explicitly as a requirement in the EIR (p8-1) and

EMP (pp18 and 25) in the following terms

ldquoAs a tenant operating in the IDZ Casa Steel will be required to

comply with all current and future CDC requirements as well as

with the relevant conditions of permits licences issued to CDC

(eg Integrated Stormwater Masterplan for the eastern side of the

Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)rdquo

16 The need to communicate with the CDC on monitoring and

auditing activities was emphasised in Chapter 8 of the EMP The

following paragraphs were added

ldquoDuring construction the environmental officer will be responsible

for monitoring compliance with the EMP and authorisation

conditions and keeping records as required in the EMP andor

authorisation conditions

The ECO will conduct site inspections every two weeks audit the

records kept by the environmental officer and submit an

environmental compliance report every two months to the

authorities and the CDC (via the Environmental Monitoring

Committeersquos ECO)

During operation the health and safety officer will monitor

compliance with the EMP and the conditions of the Environmental

Authorisation Data collected during monitoring activities and any

environmental audits conducted will be shared with authorities

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

7

IssueCommentQuestion Date

received Origin Response

Water

19 Large volumes of (2000 m3mth) of water are required of

which only 400m3 needs to be potable The NMBM return

effluent system will provide non-potable water once it is

constructed What other water recycling initiatives can be

utilized to reduce potable water requirements (the ISWMP for

the eastern side of the Coega IDZ has some best practice

guidelines collecting rainwater from the roof etc)

General

20 There is no mention of how the CDC Architectural Guidelines

will be incorporated into the development (eg to prevent a

stark uniform warehouse type development)

21 Does NMBM have adequate fire services to cover this

development Apart from the large petroleum store are there

any other large fire hazards

22 Reports from the tenantrsquos ECO during construction and from

the SHE Officer during operations should be channeled to the

Coega Environmental Monitoring Committee This can be

directly or preferably via the EMCrsquos ECO (this will be while

the EMC and ECO are in place) A precedent has been set

for this in the Environmental Authorisations for Agni-Steel and

Kalagadi Manganese Smelter

23 All mitigation actions emanating from the EIR should be

summarized (preferably in a table) If compliance with them is

to be part of the Environmental Authorization from DEDEAT

then they (or the ones that DEDEAT deems to be applicable)

and the CDC (via the Environmental Monitoring Committeersquos

ECO)

The ECO (during construction) and the health and safety officer

(during operation) will report to the Coega Environmental

Monitoring Committee (EMC) via the EMCrsquos ECO (this will be

while the EMC and ECO are in place)rdquo

17 The draft EMP recommends regular monitoring of emissions

from the scrubbers and from the chromating process Additional

emissions monitoring requirements will be confirmed once the

AEL is issued Mention has been made in the EMP (pp11 and 19)

that all AEL conditions including monitoring and reporting

requirements should be adhered to

18 Abnormal emissions can occur in exceptional circumstances

Start-up will not cause abnormal emissions as the scrubbers

will be commissioned first and will be functioning once the plant

starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions

would be emitted as a building fugitive

The hourly hydrogen chloride ground level concentrations

(directly offsite) were predicted to be 239 microgmsup3 (based on the

emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits

as stipulated for listed activities for galvanising processes) using a

screen model which assumes worst case meteorological

conditions The health effect screening level for hourly HCl

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

8

IssueCommentQuestion Date

received Origin Response

should be attached to the EA as an Appendix (otherwise no

one knows about them or takes cognizance of them)

concentrations is 2100 microgmsup3 Assuming abnormal emissions

emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset

conditions will still be well within the health effect screening

levels

Similarly the hourly particulate emissions from the building

fugitives during upset conditions would amount to 293 microgmsup3

(based on the emission limits as stipulated for listed activities for

galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1

January 2015) directly off-site

Therefore if emissions are 5 times higher normal they will still be

within health effect screening levels and the daily PM10 NAAQS

levels

In the case of a fire a cocktail of gases and particulates could be

emitted and could be over the recommended levels This

situation will however be dealt with as an emergency and

normalised as quickly as is possible

The above has been added to the impact identificationdescription

and assessment sections of the EIR

19 The CDC has an agreement with the NMBM to supply

potable water to the Coega IDZ Currently the infrastructure to

supply return effluent to the IDZ is not in place therefore Casa

Steel will be supplied with potable water up until such time as the

infrastructure is in place

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

9

IssueCommentQuestion Date

received Origin Response

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option will be investigated further between Agni and Casa The

CDC has come forward to facilitate discussions between the two

investors

Other water recycling initiatives such as rainwater harvesting

have been considered but are not practical

20 The CDCrsquos Architectural and Landscape Design guidelines

contain requirements pertaining to such aspects as the height

orientation and mass and form of buildings as well as guidelines

for landscaping and signage in order to ensure an attractive

development and achieve an architectural integrity within the

Coega IDZ The plans for the proposed galvanizing plant will be

submitted to the Design Review Committee for approval as

required by the CDC

21 Casa Steel will be required to install fire hydrants according

to the NMBMrsquos standardsrequirements The CDC will provide

potable water (up until such time as return effluent is available)

and a connection to the boundary of the site which will be

connected to the fire hydrants The installation of the fire hydrants

will require approval by the Metrorsquos Fire Chief as was done for

Agni-Steel one of the investors in Zone 6

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

10

IssueCommentQuestion Date

received Origin Response

The Coega IDZ falls within the NMBM and therefore the rates and

taxes paid by the CDC covers the fire services for which the Metro

is responsible Currently the Metro has sufficient capacity to

provide fire services to the tenants within the IDZ This was

confirmed in discussion with the CDCrsquos Infrastructure

Development Unit It is however unknown at which point the

Metrorsquos Disaster Management Plan would not be able to

accommodate servicing tenants in the IDZ

The LNG burner is the only major fire hazard on the plant

22 See response to item 16 above

23 Key mitigation and management measures emanating from

the EIR were recapitulated in Chapter 9 of the EIR to form part of

the conditions attached to the Environmental Authorization from

DEDEAT All mitigation measures recommended as a result of the

impact assessment are presented in a table in the draft EMP

which is appended to the EIR (Appendix J)

24 Hydrogen chloride is one of the main emissions There are no

ambient air quality guidelines for HCl and the EIR says

concentrations will be well within health parameters

However the main problem with HCl is its corrosive effect -

there is absolutely no mention of this in the draft EIR nor air

specialist report

There needs to be some sort of comment assessment as to

whether HCl emissions are likely to impact on for example

the adjacent Agni-Steel Plant wrt corrosion - their factory

structure will be made of steel

11042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The atmospheric corrosion of metals is a complex process with

both the extent of deterioration and the mechanisms varying

considerably depending on the metal Depending on the way

pollutants are transported from the atmosphere to the corroding

surface two types of deposition processes are recognized in

atmospheric corrosion ndash dry deposition and wet deposition Wet

deposition refers to precipitation whereas dry deposition refers to

the remaining processes including gas phase deposition and

particle deposition The most important pollutants acting as

corrosive agents are sulphur and nitrogen compounds including

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

11

IssueCommentQuestion Date

received Origin Response

The EIR specialist rpt suggests monitoring HCl at ground

level on the property boundary and this is supported in case

there are complaints from neighbours

secondary pollutants and particulates Pollutants can contribute to

corrosivity individually however there may be a synergistic effect

when more than one of these pollutants is present in the

environment being affected In the field of atmospheric corrosion

sulphur dioxide is the single most investigated gaseous pollutant

and the quantification of the direct contribution of sulphur dioxide

to the corrosion process of metallic materials is comparatively well

understood (Tidblad amp Kucera 1998)

Very little work has reported on the effect of HCl on the

degradation of materials in the environment with no local dose-

response thresholds developed for corrosion occurring due to HCl

exposures This is probably because HCl which is present

outdoors in markedly reduced concentrations when compared

with SO2 has not been considered to contribute to significant

degradation of materials (Syed 2006) For this reason the

incremental corrosion due to HCl from the Coega Galvanising

Plant cannot be quantified

25 It is unacceptable for ILISO to be using CDC maps (see

figure 9 ndash pg5-6) without these maps being referenced

accordingly particularly when it appears that a CDC map has

been used and then overlaid with features by an unknown

author (ie CASA steel site Port (where the boundaries

depicted are incorrect) and a North legend which is out of

keeping with the overall cartographic intent of the original

work

26 Figure 10 is not referenced appropriately and I believe that I

commented previously in respect to references to roads not

12042012

By email

Graham Taylor

(Spatial

Development

Manager -

Infrastructure

Development

CDC)

This has been rectified in the final version of the report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

12

IssueCommentQuestion Date

received Origin Response

yet built As a result Figure 10 is confusing and clarity needs

to be provided in terms of referencing In addition the Port

shape is irregular and similar to the comment above

27 I acknowledge the emergency preparedness and response

plan but please confirm that this includes pro-active routine

monitoring of storm water leaving your premises to verify that

your assumptions of clean storm water are correct

13042012

By post

Andrew Lucas

(Director

WRampU

Department of

Water Affairs)

Pro-active routine monitoring of stormwater leaving the premises

will be undertaken This has been explicitly emphasised in

chapter 8 of the draft EMP

28 Will portablechemical toilets be used during construction

29 What provisions have been made for storm water drainage

during construction

18042012

By

telephone

Department of

Water Affairs

Port Elizabeth

Chemical toilets will be used during construction

The Casa Steel site will be located at the corner of two roads

drainage of stormwater from the site will take place through the

roadsrsquo drainage system

From Lea September [mailtoleailisocom]

Sent 11 March 2011 0935 AM

To Wayne Poulton

Cc Terry Baker

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Wayne

An Environmental Impact Assessment (EIA) will be undertaken for this project during the

next 10 to 12 months

We foresee that some of the key environmental impacts of the project will be in terms of air

quality water quality waste and hazardous substances

At this stage I am not able to give you any details regarding the potential toxicity of the

emissions andor effluent However specialist studies will be conducted as part of the EIA

that will determine the key impacts of the project Mitigation measures will also be identified

to avoid minimise or compensate any significant impacts

You are registered on the stakeholder database and you will be kept informed of progress in

the EIA process you will notably get the opportunity to access the reports produced and

provide any feedback on them

Please feel free to contact me should you need any further information

Best regards

Lea September

From Wayne Poulton [mailtowaynepbosuncoza]

Sent 07 March 2011 1257 PM

To Lea September

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

Please can you provide me with some more information as to the potential dangers including

the toxicity of this

Kind regards

Wayne

From Lea September [mailtoleailisocom]

Sent 04 March 2011 1123

To Lea September

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 March 2011 0745 AM

To Paul Martin

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 05 April 2011 0847 AM

To Paul Martin

Cc Terry Baker Renee von Gruenewaldt

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Thank you Paul for this information

I have downloaded a copy of the RoD and Scoping report you referred to and will make sure

these requirements are taken into account in the environmental assessment

Best regards

Lea September

From Paul Martin [mailtopmartinaxxesscoza]

Sent 04 April 2011 0955 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Further to my comments on 27311

Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in

the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega

IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised

scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions

including prohibiting and monitoring where possible visible emission plumes to the atmosphere

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Paul Martin

Sent Monday March 28 2011 745 AM

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 10 May 2011 0327 PM

To ElliotMotsoaholetransnetnet

Cc Terry Baker

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Mr Motsoahole

Thank you for your input on this issue

The Port of Ngqura will indeed be used for import and export At the moment the scope of

the traffic impact assessment only covers road traffic I have however relayed the matter to

our traffic specialist and we will consider this issue in the finalization of the Scoping Report I

will keep you informed of any developments in that regard

I trust this is acceptable to you

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]

Sent 10 May 2011 0855 AM

To Lea September

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

It has been noted that Casa Steel will source steel coils from various markets internationally and

in South Africa and the bulk of the plantrsquos production output will be exported to African countries

However there is no mention of logistic requirements

Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will

be used the scope of traffic impact assessment should also include the port

Regards

From Lea September [mailtoleailisocom]

Sent 04 May 2011 0747 AM

To Lea September

Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

Please find attached a letter announcing the EIA process underway for the proposed 80 000

tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as

a Background Information Document (BID) outlining the details of the project

Please contact me should you require any further information on this project

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

Elliot Motsoahole

Manager - Environment

Transnet National Ports Authority

Port of Nqqura

Port Control Building Klub Road Port Elizabeth 6212

PO Box 612054 Bluewater Bay 6212

+27 41 507 8450

+27 86 674 7729

Cell +27 83 542 5619

E-mail Elliotmotsoaholetransnetnet

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

DISCLAIMER The information contained in this communication is subject to copyright and

intended only for the use of leailisocom Unauthorised use disclosure or copying is

strictly prohibited Should a virus infection occur as a result of this communication the sender

will not be liable If you have received this communication in error please notify

elliotmotsoaholetransnetnet

From Lea September [mailtoleailisocom]

Sent 25 May 2011 1147 AM

To Jack Landile (ELS)

Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi

Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Landile

Thank you for your input

Contact has been made with the relevant Municipal Directorate and we will follow up with

them to obtain clarifications on all these issues

I have added both Lizna and yourself on the database and will keep you updated on

progress on this project

Best regards

Lea September

From Jack Landile (ELS) [mailtoJackLdwagovza]

Sent 24 May 2011 0524 PM

To Fourie Lizna (ELS)

Cc Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Hi Lizna

I missed you on this sorry

I linked Pieter twice Instead

Regards

Landile

From Jack Landile (ELS)

Sent 24 May 2011 0445 PM

To leailisocom

Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Lea

The e-mail you sent to Mr Kooverji dated 19 May 2011 refer

Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are

All steel sheets bathing unit must be under roof

The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project

Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal

Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer

Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality

Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines

Of note is the low volume of the proposed WWTW facility ie 250 cubmweek

And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles

generation

Regards

Landile

From Lea September [mailtoleailisocom]

Sent 19 May 2011 0947 AM

To Lea September

Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Stakeholder

Please find attached the remaining appendices to the draft Scoping report for the proposed

80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 June 2011 0411 PM

To Aphiwe Bewana

Subject RE Proposed 80 000 TPY Galvanizing plant in Coega

Dear Mr Bewana

Thank you for your input and apologies for the late reply

We have taken note of your comments and are will be taking them forward in the EIA phase

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Aphiwe Bewana [mailtoaphiwebewanagmailcom]

Sent 31 May 2011 1205 PM

To Lea September

Subject Re Proposed 80 000 TPY Galvanizing plant in Coega

Comment

Re Proposed 80 000 TPY Galvanizing plant in Coega

As SANParks we would like the EIA phase to investigate the potential effects of toxicity

andor influence of emissions waste and hazardous substances both in terrestrial and

marine fauna In the draft scoping report reference has been made with regards to the

terrestrial fauna but there is no attention to potential effects to marine fauna

Equally with regards to water usage where is the plant going to extract its waters used in

galvanization andor waste management process ie rainfall rivers or even from the sea)

and which avenues would be more environmental friendly and effective

Regards

Aphiwe Bewana

Marine Planner

South African National Parks

POBox 76693

NMMU

Port Elizabeth

6031

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 06 July 2011 1031 AM

To Lea September

Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Hi Lea

Irsquove reviewed the Final Scoping Report Herewith a few comments

1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the

Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a

revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the

NMBLP Please include only those in the IDZ as part of your IAP list

Regards

Andrea

From Lea September [mailtoleailisocom]

Sent Wednesday July 06 2011 859 AM

To Lea Septemberrsquo

Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Dear Stakeholder

The final scoping report for the above-mentioned project (attached) is available for comment

until 27 July 2011

The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic

commentaryrdquo tab

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 09 April 2012 1159 AM

To Lea September

Subject Comments on Galvanising Plant EIR Coega IDZ

Lea

Attached are my comments on the Draft EIR for the Coega IDZ galvanising

plant

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

Email attachment

COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ

Dr Paul Martin PO Box 61029

Bluewater Bay 6212 Tel 041 4665698

Email pmartinaxxesscoza

Compliance with CDC Permits amp Requirements

It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of

o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants

Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC

Air Emissions

Presumably permanent in stack monitoring will be required in terms of AEL permit requirements

Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions

Water

Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)

General

There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)

Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards

Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter

All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 11 April 2012 1245 PM

To Lea September

Subject Fw Comments on Galvanising Plant EIR Coega IDZ

Lea

One other comment on that I have on the Galvanising Plant Draft EIR

Hydrogen chloride is one of the main emissions There are no ambient air

quality guidelines for HCl and the EIR says concentrations will be well

within health parameters

However the main problem with HCl is its corrosive effect - there is

absolutely no mention of this in the draft EIR nor air specialist report

There needs to be some sort of comment assessment as to whether HCl

emissions are likely to impact on for example the adjacent Agni-Steel

Plant wrt corrosion - their factory structure will be made of steel

The EIR specialist rpt suggests monitoring HCl at ground level on the

property boundary and this is supported in case there are complaints from

neighbours

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Paul Martin ltpmartinaxxesscozagt

To Lea September ltleailisocomgt

Sent Monday April 09 2012 1158 AM

Subject Comments on Galvanising Plant EIR Coega IDZ

gt Lea

gt

gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising

gt plant

gt

gt

gt Dr Paul Martin

gt PO Box 61029

gt Bluewater Bay 6212

gt Tel 041 4665698

gt Cell 0732524111

gt email pmartinaxxesscoza

gt

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 12 April 2012 1139 AM

To Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Hi Lea

Hope yoursquore keeping well

I have requested comments from my colleagues and the CDC Casa team on the Draft EIR

Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report

Regards

Andrea

From Graham Taylor

Sent Thursday April 12 2012 838 AM

To Andrea Von Holdt Firhana Sam

Cc Johan Fourie Maria van Zyl Melikhaya Sihawu

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Andrea Firhana

Firhana if you could please ensure that the co-ordinates provided in the EIR correspond

with our records (pages 4-1 amp 4-2)

My comments are as follows

It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work

Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above

Regards

Graham Taylor

Spatial Development Manager - Infrastructure Development

Mobile 0832283055

Office 0414030454

Facsimile 0865185033

Email GrahamTaylorcoegacoza

Website wwwcoegacom

right PLACE | right TIME | right CHOICE

This email and all contents are subject to the following disclaimer

httpwwwcoegacomemaildisclaimerhtml

From Lea September [mailtoleailisocom]

Sent 04 May 2012 0411 PM

To Andrea Von Holdt

Cc Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Dear Andrea

We have taken note of the comments from the GIS Unit These issues have been rectified in

the final version of the EIR

Please can you forward to the relevant persons at the GIS Unit

Thank you

Best regards

Lea September

APPENDIX E

BACKGROUND INFORMATION

DOCUMENT

APPENDIX F

AIR QUALITY IMPACT ASSESSMENT

APPENDIX G

TRAFFIC IMPACT ASSESSMENT

APPENDIX H

WASTE MANAGEMENT AND HAZARDOUS

SUBSTANCES SPECIALIST STUDY

APPENDIX I

WATER QUALITY SPECIALIST STUDY

APPENDIX J

ENVIRONMENTAL MANAGEMENT

PROGRAMME

Page 8: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vi

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

Waste management and hazardous substances

The plant will generate a relatively small amount of solid waste which will be re-used

recycled or disposed of in accordance with the EMP recommendations

There will be a wastewater treatment plant on site which will neutralise process water

(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer

Hazardous waste from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site

at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and

removed on a monthly basis is limited to 10 m3

A number of substances classified as hazardous are used in the galvanizing process and

the transport and handling of these is subject to certain rules and guidelines

In addition the permanent storage of a high quantity of liquid petroleum on site (20 000

litres at any one time) is subject to certain specifications and requires approval from the

municipality

Health and safety

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling of the various substances used will be done in

accordance with applicable instructions (cf material safety data sheets)

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as provide

site supervision including executing tests (individual test cold run and hot run) during 3

months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the EMP

Traffic

In the operational phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and from

the Port of Ngqura

The traffic expected to be generated during construction as well as operation is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low and

the total traffic generated by Casa Steel is also relatively low

The impact on port traffic is also negligible and well within the portrsquos capacity

Socio-economic aspects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vii

The proposed galvanizing plant will make a positive contribution by creating jobs during

construction and operation and generating business for the various service providers

Fatal flaws

No fatal flaws have been identified

The significance of these potential key environmental impacts were assessed in the EIA

phase and the findings of this phase of investigations are presented in this report

The main findings of the EIA are as follows

During construction impacts post-mitigation are low with the exception of noise and

biodiversity as the construction of the plant will result in the destruction of habitat

and loss of fauna and flora and noise impacts inherent to construction activities

Mitigation measures have been included in the EMP for these impacts and they have

a medium significance post-mitigation

All impacts were assessed as low during operation after mitigation

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium

to long term similar impacts are likely to occur due to ongoing developments in the

IDZ

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

The CDC has its own requirements regarding the monitoring of certain aspects of the

project such as the quality of the effluent and the noise levels These have been

incorporated into the EMP Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as other

infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified and

assessed No fatal flaws have been identified

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 viii

It is recommended that the project be approved subject to the conditions listed above

and adherence to the EMP recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-1

1 INTRODUCTION

11 BACKGROUND

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)

Nelson Mandela Bay Municipality Eastern Cape Province

The demand for galvanised steel products is high in South Africa and Africa and is

expected to increase in the foreseeable future From an economic point of view the

proposed project has therefore been found to be viable

Casa Steel will source the steel coils from various markets internationally and in

South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is

destined to be exported mainly to African countries

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

An Environmental Impact Assessment (EIA) is required as the proposed project

involves several activities listed in terms of Section 24 of the National Environmental

Management Act (NEMA) No 107 of 1998 as amended and requires an

environmental authorisation

The following listed activities requiring environmental authorisation have been

identified

Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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 metres

Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped

land to industrial use greater than 1 ha but less than 20 ha in size outside an

urban area

Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any

process or activity requiring a license in terms of national or provincial legislation

governing the generation or release of emissions

Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5

hectares or more of vegetation where 75 or more of the vegetative cover

constitutes indigenous vegetation except where such removal of vegetation is

required for

(i) purposes of agriculture or afforestation inside areas identified in

spatial instruments adopted by the competent authority for

agriculture or afforestation purposes

(ii) the undertaking of a process or activity included in the list of waste

management activities published in terms of section 19 of the

National Environmental Management Waste Act 2008 (Act No 59

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-2

of 2008) in which case the activity is regarded to be excluded from

this list

(iii) the undertaking of a linear activity falling below the thresholds in

Notice 544 of 2010

Hot dip galvanizing is a listed activity in terms of section 21 of the National

Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires

an Atmospheric Emissions Licence (AEL)

In addition the treatment of wastewater with an annual throughput capacity of more

than 2000 m3 is a listed activity in terms of the National Environmental Management

Waste Act 59 of 2008 and requires a waste management licence

ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental

Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact

Assessment process in terms of section 24 of NEMA for the construction and

operation of the proposed galvanizing plant The EIA process covers all aspects of

the project and informs all three applications (for environmental authorisation waste

management licence and AEL)

13 PURPOSE OF THIS REPORT

This report builds on the scoping report submitted to the Eastern Cape Department of

Economic Development and Environmental Affairs (DEDEA) and the Nelson

Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It

describes the proposed project and presents the findings of the second phase of

investigations (EIA phase)

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT

PRACTITIONER (EAP)

The EIA was managed by Ms Terry Baker a certified Environmental Assessment

Practitioner with 20 years of working experience She has a MA in Environmental

Management and specialises in Environmental Impact Assessments and Project

Management She has been involved in a variety of different types of EIAs including

for water supply projects dams transmission lines roads and airports in South

Africa Botswana Uganda Lesotho and Mozambique She has been involved in

water resource management and public participation programmes on a number of

projects Terry has also been involved in the use of Geographic Information Systems

environmental status quo reports water quality assessments socio-economic and

institutional development projects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-3

15 PROJECT TEAM

In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen

(water quality specialist) and Lea September (EAP) with specialist input from Renee

von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous

substances) and Seniel Pillay (Traffic Impact Assessor)

The Business Unit Head of the ILISO Environmental Management Discipline Group

Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is

a Fellow of the South African Institution of Civil Engineers a member of the South

African Society of Aquatic Scientists of the Environmental Scientific Association of

the International Water Association of the Water Institute of South Africa and of the

Vaal River Catchment Association He is a certified Environmental Assessment

Practitioner with 30 years experience who specialises in project management

environmental impact assessments and water resource planning He specifically has

extensive experience in water quality especially water quality management water

quality monitoring and water quality assessment Martin has experience in managing

projects that involve multi-disciplinary teams and public consultation and

participation in South Africa and abroad

Lea September is an Environmental Assessment Practitioner with a Masters degree

in Environmental Management She has experience in impact assessment and

environmental management and has been responsible for drafting impact

assessment reports and Environmental Management Programmes and conducting

public participation processes as well as high level environmental screenings for a

variety of projects in the energy water transport and industrial sectors

Renee von Gruenewaldt has nine-years experience in the field of air pollution

impact assessment and air quality management Prior to becoming involved in air

quality consultation she was part of the Highveld Boundary Layer Wind Research

Group based at the University of Pretoria Since joining Environmental Management

Services (the company now Airshed Planning Professionals) she has undertaken

numerous air pollution impact studies and has provided extensive guidance to both

industry and government on air quality management practices

Pieter Smuts graduated as a Civil Engineer and became involved in the field of

municipal engineering and infrastructure construction He has specialized during the

last twelve years in solid waste management He has completed waste management

plans feasibility studies and final designs of waste management facilities in South

Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and

the review of the Mavoco hazardous waste landfill design in Maputo Mozambique

and completed a study on hazardous waste (textile factory sludge) management in

Maseru Lesotho

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-4

Seniel Pillay is a transportation engineer with over 16 years experience in

transportation planning and traffic engineering He has been involved in a wide

range of projects ranging from developing the Transport Operations Plan for the

FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System

for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller

traffic impact assessments for inter alia road improvement schemes Of particular

relevance to this project his experience includes Heavy Goods Vehicle Study for

eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact

Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash

Preliminary Transportation Assessment

16 STRUCTURE OF THIS REPORT

The proposed project and the alternatives considered are described in Chapter 2

Chapter 3 details the approach adopted for the EIA phase

The biophysical and socio-economic environment affected by the activity is described

in Chapter 4

The environmental impacts identified are discussed in Chapter 5

The EIA methodology is described in Chapter 6 and Chapter 7 presents the results

of the impact assessment

The environmental impact statement is presented in Chapter 8

Finally Chapter 9 spell out the conclusions and recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-1

2 DESCRIPTION OF THE PROPOSED PROJECT

21 TECHNICAL ASPECTS

211 The galvanizing process

Galvanizing consists of coating steel with zinc in order to protect it from corrosion

Before steel strips can be galvanized they undergo a pre-treatment in order to

ensure that the steel sheets are free from any surface oxides as they enter the

molten zinc coating Bath This is done by removing the oil from the steel sheets (in

the degreasing unit) and then removing the rust from the surface of the sheet (in the

pickling unit)

The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The

melting zinc on the strip surface will be cooled and solidified through air cooling in the

cooling tower

Finally the galvanised steel sheets are dipped into a water quenching tank in order to

further cool the sheets from about 150degC to 40degC

It is possible to make galvanised steel more durable by chromating it Approximately

50 of the galvanised steel production output will receive chromate passivation

treatment after quenching the galvanised steel sheets will be sprayed with a chrome

solution (3 kgcm2)

After galvanizing and chromating the steel sheets are cut to achieve the desired coil

size and weight and transported to the storage yard

The process flow diagram below (Figure 1) illustrates the main stages of the

galvanizing process and indicates the major inputs and outputs as well as the

resulting effluent and atmospheric emissions

Draft Environmenal Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-2

Figure 1 Process flow diagram for proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-3

212 Main inputs and outputs in operational phase

In view of the above the main inputs will be as follows

Steel coils 85 000 tonsyear

Zinc 870 tonsyear

Electricity 2500 kVA

Water 2000 m3month (of which 400 m3 will be potable water)

Liquid Natural Gas (LNG) 270 NM3hour

Sodium hydroxide (NaOH) 1000 m3year

Hydrochloric acid (HCl) 800 m3year

Chrome (Cr+3) 10 m3year

The main outputs will be

Galvanized steel 80 000 tonsyear

Scrap metal 20 tonsyear

General waste 65 tonsyear

Hazardous waste 2 m3month

Wastewater 012 Mlweek

Atmospheric emissions lt 5 ppm

213 Installations on site

The bulk of the operations involved in the galvanizing process occur along a

continuous galvanizing line (See Figure 2 below) which is the main piece of

machinery required for the proposed galvanising plant

Figure 2 Continuous Galvanizing Line

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-4

Water is one of the major inputs and is used throughout the galvanizing process notably

for rinsing and cooling purposes and as a mixing agent for the various chemical

solutions The plant will have a water treatment plant on site to treat the water used in

the various processes (approx 250 m3

of wastewater per week) The wastewater

treatment facility will be operated by a professional water treatment company as Casa

Steel does not have the required expertise in house to treat its process water Sulphuric

acid (H2SO4) is used as part of the treatment process to reduce caustic soda The

neutralised water is discharged to the sewer while any sludge is disposed of as

hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)

will be disposed of

Some critical areas of the galvanizing process such as the zinc pot require uninterrupted

power It is therefore proposed to install an LNG burner to maintain the zinc bath at a

temperature of between 450 and 460degC

22 LOCATION OF THE PROPOSED GALVANIZING PLANT

The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast

of Port Elizabeth in the Eastern Cape (Figure 3)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-5

Figure 3 Location of the proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-6

23 NEED AND DESIRABILITY

The profitability of the proposed project has been established by Casa Steel and a

pre-feasibility study has confirmed that the proposed project was feasible from a

technical and financial point of view The Coega IDZ is specifically designed to host

facilities such as a galvanizing plant and can provide the necessary infrastructure

and services to its investors It therefore constitutes a very suitable location for the

project

24 ALTERNATIVES IDENTIFIED

Zone 6 has been specifically earmarked for heavy ferrous metal industries and is

therefore a suitable location for the proposed galvanizing plant as such no site

alternatives have been provided for and assessed in this EIA However prior to the

commencement of the EIA process Casa Steel was presented with a number of

different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the

selection of the site were

(a) The dimensions of the land the site should be at least 200 m long and

50 m wide in order to accommodate the galvanizing line and adjacent lay

down area and additional land should be available next to the site for future

expansion

(b) The fiscal arrangements applying to the site the site should be located

within the future Custom Controlled Area (CCA) as the bulk of the

production output of the plant will be exported

The no-go alternative is assessed in this report

25 CONSTRUCTION ASPECTS

The construction phase of the project will take about 12 months and will essentially

consist of erecting a building to house the galvanizing line and other equipment and

preparing a concrete laydown area adjacent to the building

The CDC will provide an access point from the existing tarred road that will lead to

the site

Approximately 100 workers from the surrounding areas will be contracted for the

construction work

The requirements in terms of services during construction are listed below

Water 1000 m3month

Electricity 2500 kVA

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-7

The CDC will provide temporary services for the construction phase including a

conservancy tank for flush toilets Sewage infrastructure will only be provided for the

operational phase

26 OPERATION ASPECTS

Before the plant can become fully operational the equipment and machinery will be

tested for approximately 3 months The supplier will supervise these tests as part of

the transfer of know-how and training of staff on the plant

Casa Steel will start operating the plant at a reduced capacity (about 50 000

tonsyear) for a period of time (mostly determined by market aspects) before bringing

production to full capacity (80 000 tonsyear) This is done by operating the line for

longer hours

Approximately 50 to 60 people will be working on the plant Approximately 6-10 of

these will be unskilled 40-45 skilled and about 5 people in managerial positions

The requirements in terms of services during operation are as follows

Water 2000 m3month

Electricity 2500 kVA

Effluent discharge 24 m3day

The CDC has entered into agreements with the municipality to secure the provision

of services such as water and electricity to its tenants Tenants in the IDZ have their

own agreements with the NMBM for electricity while the agreements for water and

sewage are with the Facilities Unit of the CDC

Regarding discharge of wastewater to the sewer the municipality indicated that the

only requirement is that the water discharged complies with applicable municipal

discharge standards

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 3-1

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT

31 OBJECTIVES

The main objectives of the EIA phase are to

Assess the significance of the environmental issues and impacts identified in the

scoping phase focusing on key impacts

Recommend appropriate measures to mitigate negative impacts and enhance the

benefits and include them in the draft EMP

Undertake a public participation process that provides opportunities for all

interested and affected parties (IampAPs) to be involved

32 AUTHORITY CONSULTATION

The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental

Liaison Committeersquo (ELC) which comprises representatives of various authorities

including DEDEAT the Department of Environmental Affairs (DEA) and Department

of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the

Coega Development Corporation (CDC) and Transnet National Ports Authority

(TNPA) The ELC has been specifically formed to facilitate EIA applications in the

IDZ

Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to

the clearance of vegetation should be included in the application A formal request

was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the

application and all registered stakeholders were informed of the request in writing on

19 October 2011

33 PUBLIC PARTICIPATION PROCESS CONDUCTED

On-site notices were replaced by a notification displayed on the CDCrsquos digital notice

board at the business centre in Zone 1 of the IDZ The eNotice was placed on

13 April 2011 and will remain for the full duration of the EIA process

Registered stakeholders will be notified in writing of the availability of the draft EIA

report and EMP which will also be advertised in a local newspaper Stakeholders

including state departments and the public will have forty (40) days to comment on

the draft EIA report and EMP The draft EIA report and EMP will be sent by email

where possible and made available for download on the ILISO website

(wwwilisocom)

A summary of all issues and comments received during the stakeholder consultation

process as well as of correspondence in that regard will be captured in an Issues

and Responses Report that will form an Appendix to the EIA Report

The list of registered IampAPs is included in Appendix A

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 3-2

34 LEGISLATION AND GUIDELINES CONSIDERED

The following legislation and guidelines were considered in the preparation of this

report

National Environmental Management Act Act No 107 of 1998

NEMA EIA Regulations 2010

National Environmental Management Air Quality Act Act No 39 of 2004

National Environmental Management Waste Act Act No 59 of 2008

Hazardous Substances Act Act 15 of 1993

Occupational Health and Safety Act Act 85 of 1993

Hazardous Chemical Substances Regulations 1995 (GNR 1179)

Major Hazard Installation Regulations 2001 (GNR 692)

National Water Act Act 36 of 1998

National Heritage Resources Act Act 25 of 1999

DEAT Integrated Environmental Management Information Series 1-5 and 12-15

NEMA draft Implementation Guideline

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Public Participation (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Alternatives (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Draft Guideline for Determining the Scope of Specialist

Involvement in EIA Processes (2005)

IAIA guidelines

National air quality standard for thoracic particulates Government Gazette

No 32816

Listed activities and associated minimum standards identified in terms of section

21 of the National Environmental Management Air Quality Act Act No 39 of

2004 Government Notice 248 of 2009

Minimum Requirements for the Handling Classification and Disposal of

Hazardous Waste DWAF Waste Management Series (1998)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-1

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION

The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega

IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay

to the north of the N2 highway between Port Elizabeth and Grahamstown east of the

Coega River

The co-ordinates of the corners of the site are shown in Table 1

Table 1 Coordinates of site corners for the proposed galvanizing plant

Point Longitude Latitude

A 25deg411126E 33deg45587S

B 25deg411156E 33deg45499S

C 25deg411938E 33deg45131S

D 25deg412174E 33deg45481S

E 25deg412508E 33deg45979S

F 25deg412634E 33deg451160S

G 25deg411782E 33deg451560S

H 25deg411692E 33deg451428S

J 25deg411314E 33deg45868S

Figure 4 Zone layout in the Coega IDZ

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-2

Figure 5 Site location

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-3

42 SOCIO-ECONOMIC CHARACTERISTICS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the

NMBM There are no residents within the IDZ

As far as the broader NMBM and Eastern Cape Province are concerned the

following can be noted The NMBM is located within the Eastern Cape Province the

2nd largest Province in South Africa (3rd in terms of population) characterised by a

predominantly black population with low incomes and high levels of unemployment

(CES 2010)

The NMBM has a population of just above 11 million and covers an area of

1 950 km2 It is the main urban and industrial centre of the province and Port

Elizabeth in particular which forms part of the NMBM is the commercial capital of

the Eastern Cape 52 of the NMBM population is female and 37 is below the

age of 20 these two groups are particularly affected by unemployment

43 BIOPHYSICAL CHARACTERISTICS

431 Surface and ground water

No rivers occur in Zone 6 There is however a natural attenuation pond on the

southern most part of the site which will have to be avoided

The IDZ is underlain by calcrete sand and gravel deposits that overlie low

permeability clays These clays limit the vertical infiltration of rainwater and induce a

horizontal groundwater flow towards the Coega River channel which is the most

significant surface water feature in the Coega IDZ Consequently rapid run-off takes

place following precipitation (Jacobs 2008)

Groundwater levels at Coega are generally about 3 to 5 m below surface ie just

above the contact between the permeable sands and the underlying impermeable

clays The groundwater flow direction is to the southeast following the surface water

drainage direction (Jacobs 2008)

432 Climate and atmospheric conditions

Port Elizabeth has a warm temperate climate and the temperature ranges are not

extreme Exceptionally high temperatures may be experienced during berg wind

conditions which occur frequently during autumn and winter Extreme temperatures

also occur during summer with little accompanying wind

The wind regime for the area largely reflects the synoptic scale circulation with

dominant westerly and northwesterly flow fields representing the pre-frontal

conditions and south-westerly flow fields representing the frontal conditions The

south-easterly and south-westerly wind flow (land breeze) increases during daytime

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-4

conditions with westerly and north-westerly wind flow increasing during the night (sea

breeze)

The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of

Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15

km southwest) and Port Elizabeth (~23 km southwest)

An ambient air monitoring network has been established in the Coega IDZ which

consists of three monitors Saltworks Motherwell and Amsterdamplein Although

NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative

impacts due to the proposed Galvanising Plant is PM10 A maximum daily average

PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed

SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3

was exceeded on 17 days in 2007 and 26 days in 2008

Existing sources of emissions in the vicinity of the proposed galvanizing plant include

industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other

fugitive dust sources (von Gruenewaldt 2011b)

433 Geology and soils

Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel

and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly

limestone and conglomerate

434 Terrestrial ecology

This section draws from the EIA report compiled for the Agni Steel (formerly Afro-

Asia) steel processing facility which is adjacent to the proposed site for the

galvanizing plant (Jacobs 2008)

The area consists largely of grasses succulents and scrubby bush with alien

species making up the greater part of the more dense vegetation

Zone 6 falls within the inland vegetation and is characterised by a vegetation type

referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the

Coega IDZ and has been found to have three times the level of endemism of other

vegetation communities in the Coega IDZ Bontveld therefore has a high

conservation status Two Bontveld conservation areas have been identified within the

IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)

Bontveld that will be destroyed as a result of development in the IDZ will be given

conservation status in these two areas

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-5

Figure 6 Coega IDZ Open Space Management Plan (OSMP)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-6

Certain areas in the IDZ are invaded by alien plant species The most common

invader species is rooikrans (Acacia cyclops) which presently forms large

monospecific stands in areas throughout the Coega IDZ There are several other

aliens present that pose a threat to the flora of this area including the prickly pear

(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)

Loss of vegetation and alien plant invasion due to human activity has resulted in a

reduction in the diversity of terrestrial fauna

The majority of mammals present in the Coega IDZ are small or medium-sized Of

the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed

gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of

Algoa Bay however it is not considered threatened The gerbil is common in

foredune and dune thicket habitat in the Coega region and is therefore unlikely to

occur on the proposed site

A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird

species are resident or common to the area Most diversity occurs in the thicket

although the coastal area also supports specialised avifauna Two species of tern

the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well

as the Cape gannet (Morus capensis) and the African penguin (Spheniscus

demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne

caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant

(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser

flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns

are two of the most endangered coastal species in South Africa Other bird species

of conservation concern include the Whitefronted plover (Charadrius marginatus)

African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus

bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus

ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides

paradisea) Breeding pairs of Damara terns and African black oyster catchers have

been observed in the coastal dunes of the IDZ but should not be affected by

developments that fall outside the dune areas

The Eastern Cape supports nearly a third (approximately 133 species) of the reptile

species recorded in South Africa More than half of the Eastern Capersquos endemic

reptile species occur in the Algoa Bay area giving the region a high conservation

value A total of 63 reptile species are believed to occur within the Coega IDZ The

majority of these are found in Succulent Thicket and riverine habitats Only a few

reptile species occur in the coastal dunes and estuarine habitats More than a third of

the species are described as relatively tolerant of disturbed environments provided

that migration corridors of suitable habitat are maintained to link pristine habitats

Twenty two reptiles are of special concern including five endemic species (two of

which may also be endangered) four endangered sea turtles eight species listed

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-7

with CITES one rare species and four species at the periphery of their range

Fourteen of these species of special concern are confirmed as occurring on or within

2 km of the Coega IDZ

A total of 32 amphibian species and sub-species occur in the Eastern Cape

representing almost a third of the species recorded in South Africa However none of

the species are endemic or Red Data Book species Based on previous studies in the

area it is estimated that approximately 17 amphibian species occur within the Coega

IDZ Four species are listed as peripheral but none are threatened internationally

These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog

(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and

the bubbling kassina (Kassina senegalensis)

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated

vegetation has not been extensively studied One grasshopper species Acrotylos

hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue

(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis

pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in

four localities in the Eastern Cape one of which is within the Coega IDZ The Coega

copper Aloeides clarki is endemic to this particular region of the Eastern Cape and

is currently known to occur in three localities two of which are in the Coega IDZ The

localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the

Coega IDZ and their distributions were taken into account when defining Coegarsquos

open space system and Development Framework Plan

435 Land use and topography

The land is currently undeveloped and earmarked for industrial development The

site is relatively flat ranging from an elevation of 66 masl on the northern-most

corner to 59 masl at the southern-most corner

436 Heritage and archaeological survey

Extensive studies have been undertaken in Zone 6 with respect to heritage aspects

Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a

2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond

2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is

currently being finalised

Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing

Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha

in extent and was located next to the R102 road to Motherwell Kaplan conducted

HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi

Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will

now be located in Zone 5)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-8

The various archaeological investigations reached similar observations and

conclusions Stone tools of various densities and types were found throughout the

zone The majority of the stone tools were mainly of Earlier and Middle Stone Age

and occasional Later Stone Age origins (Figure 4)

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble

gravels exposed by tracks in Zone 6 (Source Binneman 2010)

The stone tools which comprised of quartzite flakes chunks flaked pebblecobble

and cores were randomly distributed across the landscape and are in secondary

context There were no lsquoconcentrationsrsquo of tools observed which suggested any

spatial patterning or activity areas although these may be present or covered by soil

and vegetation

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 5-1

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED

The following environmental issues and potential impacts were identified in the

Scoping phase

51 AIR QUALITY

The galvanizing process generates atmospheric emissions with particulates and

hydrogen chloride representing the main pollutants of concern The plant is fitted with

air extraction as well as scrubber systems which are designed to retain the bulk of

pollutants and particles for each of the processes in such a way that less than 5 ppm

of gases and particles will be released into the atmosphere after the fume scrubber

Other sources of impact on air quality include emissions from the LNG burner as well

as emissions and dust from the transport of steel and other materials in trucks

Construction activities will also create dust and gas emissions due to the clearing of

groundcover tipping of material to storage pile levelling of area wind erosion from

storage piles vehicle and construction equipment activity and tailpipe emissions

from vehicles and construction equipment such as graders scrapers and dozers

Overall the air quality impact assessment (Gruenewaldt 2011b) found that

The predicted particulate oxides of nitrogen carbon monoxide and sulphur

dioxide concentrations are all below the National Ambient Air Quality Standards

for all averaging periods

The predicted off-site concentrations of hydrogen chloride are well below the

most stringent effect screening levels

No odour threshold exceedances for hydrogen chloride were predicted to occur

due to routine operations at the Steel Galvanising Plant The South Wales

Environmental Protection Authority stipulates that an odour unit of 20 is

acceptable for urban areas The odour unit would be lt10 directly off-site for

hydrogen chloride

Abnormal emissions can occur in exceptional circumstances Start-up will not

cause abnormal emissions as the scrubbers will be commissioned first and will be

functioning once the plant starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions would be emitted as a

building fugitive

The hourly hydrogen chloride ground level concentrations (directly offsite) were

predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based

on the emission limits as stipulated for listed activities for galvanising processes)

using a screen model which assumes worst case meteorological conditions The

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-2

health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming

abnormal emissions emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset conditions will still

be well within the health effect screening levels

Similarly the hourly particulate emissions from the building fugitives during upset

conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for

listed activities for galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly

off-site

Therefore if emissions are 5 times higher normal they will still be within health effect

screening levels and the daily PM10 NAAQS levels

In the case of a fire a cocktail of gases and particulates could be emitted and could

be over the recommended levels This situation will however be dealt with as an

emergency and normalised as quickly as is possible

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS

The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of

its heritage potential and there are no proposed protected geosites in Zone 6

Should any artefacts be discovered during construction procedures stipulated in the

draft EMP will apply

53 BIODIVERSITY AND CONSERVATION

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

In terms of terrestrial fauna the CDCrsquos open space management plan provides for

the preservation of certain corridors The destruction of certain habitats as a result of

the development will therefore not automatically result in the loss of certain species

54 WATER QUALITY

There is a natural attenuation pond on the southern most part of the site which will be

avoided

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through

spills or leaks

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-3

This risk can however be minimized if not avoided altogether The floor of the factory

will be designed as a bunded area to contain any spills and the entire process will be

contained Potential spills or leaks will therefore be contained and will not impact on

water resources Storm water is therefore considered clean water under normal

operational conditions An oil trap will be placed at the exit of the site to ensure that

no grease from the laydown area enters the stormwater system

Spills and leaks can occur during the handling or the transport of hazardous

substances Best practice guidelines will be followed to ensure that this risk is

adequately managed

Wastewater discharged to sewer will be treated to comply with municipal discharge

standards and is not expected to have an impact on the chemical characteristics of

the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be

discharged from the plant is small in relation to the total volume received at the

Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works

(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently

operated at 61 of its capacity which is approximately 80 Mℓday Thus the

0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore

not have any significant impact on the WWTW

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES

The plant will generate a relatively small amount of solid waste in the form of scrap

metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)

The scrap metal may be sold to other steel processing facilities such as Agni Steel

which will be located next to the plant or collected and disposed of with the rest of

the solid waste by a licensed service provider

As mentioned previously there will be a wastewater treatment plant on site which will

neutralise process water (012 Mlweek) in order to ensure it is of a standard

acceptable for discharge to sewer Waste in the form of sludge from the

neutralization or spent acid must be disposed of as a hazardous waste Solid waste

from the filters used for air quality control is also in this category These wastes can

usually be tested and then delisted which means that it can be placed in a general

purpose landfill

Hazardous effluent from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-

site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored

and removed on a monthly basis is limited to 10 m3

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-4

A number of substances classified as hazardous are used in the galvanizing process

(Table 2) and the transport and handling of these is subject to certain rules and

guidelines In particular the material safety data sheets (cf Appendix H) should be

referred to for inter alia hazards identification accidental release measures

handling and storage precautions exposure controlpersonal protection ecological

information and transport information The Hazardous Chemical Substances

Regulations 1995 should also be adhered to in respect of the transport and storage

of hazardous chemical substances

Table 2 Hazardous materials to be used on site

Major Input Materials

Substance

listed in the

SABS 0228

Group II

hazardous

substances

Volumes to be

stored on site at

any one time

Diesel radic 2000 litres

Liquid petroleum radic 20 000 liters

Sodium hydroxide (NaOH)

(used for degreasing) 8 radic 1000m

3

Hydrochloric acid (HCI)

(used for pickling) 8 radic 800m

3

Zinc (used for galvanising) - TBD

Trivalent chromium (CR+3

)

(used for chromating) 8 radic 10m

3

Sulphuric acid (H2SO4) (used for

treatment of waste water on site) 8 radic TBD

Ammonium Hydroxide (NH4OH) 8 radic TBD

TBD ndash To be determined

Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one

time) and is classified as a flammable substance Specification for flammable storage

facilities in accordance with the requirements of the Nelson Mandela Bay

Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for

quantities between 5000 and 20 000 liters the substance must be kept in a

flammable liquid store which complies with the requirements of a specification

obtainable from the Department Some of the requirements are

Flammable liquid and solid storage facilities are only permitted on the ground

floor

Decanting of flammable liquids and solids are not permitted within any building

Due to the fact that there are flammable materials on site a certificate may be

required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and

Emergency Services Department to confirm that facilities for flammable storage

are in accordance with their requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-5

Because of the permanent installation and high quantity of liquid petroleum on site

the Major Hazard Installation Regulations 2001 promulgated under the Occupational

Health and Safety Act No 85 of 1993 applies A written application for approval of

the installation is required to be submitted to the chief inspector Department of

Labour provincial director Department of Labour and NMBM prior to construction

In addition a risk assessment should be formulated covering all hazardous materials

together with an emergency preparedness and response plan

56 HEALTH AND SAFETY

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling instructions as well as occupational exposure limits

are indicated in the material safety data sheets of the various substances used

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as

provide site supervision including executing tests (individual test cold run and hot

run) during 3 months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the

EMP

In addition the emergency preparedness and response plan will cover the health and

safety aspects related to emergency situations

57 TRAFFIC

The volumes of traffic at the IDZ are currently relatively low and variable depending

on the different zones in the IDZ however these volumes will increase as more

developments are implemented

The construction phase of the Casa Steel development will take about 12 months

and will essentially consist of erecting a building to house the galvanizing line and

other equipment and preparing a concrete laydown area adjacent to the building

The traffic that would be generated during the construction phase can be expected to

be less than the traffic that would be generated by the Casa Steel development when

it is fully operational

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-6

In the operation phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and

from the Port of Ngqura

The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the

Casa Steel development would be off Ring Road 1 The other roads of significance

for the Casa Steel development are the N2 Neptune Road MR435 and MR450

Access to the port is given by Neptune Road Road Link NEP-03 has not yet been

built

Figure 8 Coega IDZ road network identification

(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-7

Figure 9 Coega IDZ road network

Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No

01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-8

The distribution of freight trips is fixed as the majority of trips will be made between

the Port of Ngqura and the Casa Steel site With regard to personnel trips there are

various points of origins (the surrounding residential areas) that could be used by

staff going to the Casa Steel site The distribution of personnel trips is based on

existing traffic count information and is shown in Figure 10

Figure 10 Trip distribution for freight and personnel trips

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The resultant expected Casa Steel traffic assignment is shown in Figure 11

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-9

Figure 11 Morning peak hour Casa Steel development traffic

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The traffic that is expected to be generated by the Casa Steel development is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low

and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)

Consultation has taken place with Transnet Port Authority (TPA) to establish the

impact of the galvanizing plant operations on traffic inside the port The additional

ships entering and exiting the port of Ngqura as a result of the proposed development

will have a negligible impact on port traffic and TPA indicated that it would be well

within the portrsquos capacity

58 NOISE

Noise is not foreseen to be a significant issue insofar as the noise levels inside the

plant and at the boundary of the site will not exceed the limits prescribed by the CDC

Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels

during the day and 60 decibels at night

Mitigation of noise impacts will be addressed in the design of the noise-emitting

components of the plant and their enclosures

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-10

59 SOCIO-ECONOMIC ASPECTS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of

NMBM There are no residents within the IDZ

The direct socio-economic impacts of the proposed project are thus limited to the

employment generated by the project during construction and operation Job creation

remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)

and the IDZ and Port of Ngqura are expected to become a significant catalyst to the

economic growth of the Municipality and the region with current investments at

Coega creating more jobs and stimulating the economy

In this context the proposed galvanizing plant will make a positive contribution

towards the achievement of these goals

There will be 50 to 60 employees during operation phase distributed as follows

Figure 12 Casa Steel organisation chart

Even though a large part of the inputs will be imported and the bulk of the production

output will be exported there will be some positive impacts for the economy of the

region and of South Africa in general Notably the requirements of the plant for

water electricity waste collection and disposal waste water treatment and transport

for example will create business for the various service providers and have an

indirect impact on employment and fiscal revenues as a result

From a visual impact point of view it can be anticipated that the landscape in the IDZ

will be significantly affected over time by developments related to the establishment

of the port and various industries

HEAD ( WORKS )

MGR ( COMM) MGR ( ADMNHR ) Manager marketing

MANAGER OPERATION MANAGER MANAGER MANAGER Q C

AC FIN PUR ampSTORE

PPC SH-GALV SH-tech

SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF

1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO

JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF

2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO

WORKERS WORKERS 7NOS

15 7

RAW MAT amp

DESP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 6-1

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY

A description of the nature of the impact any specific legal requirements and the

stage (constructiondecommissioning or operation) will be given Impacts are

considered to be the same during construction and decommissioning The

significance of the potential impacts will be considered before and after identified

mitigation is implemented

The following criteria will be used to evaluate significance

Nature The nature of the impact will be classified as positive or negative and

direct or indirect

Extent and location Magnitude of the impact and is classified as

Local the impacted area is only at the site ndash the actual extent of the activity

Regional the impacted area extends to the surrounding immediate and

neighbouring properties

National the impact can be considered to be of national importance

Duration This measures the lifetime of the impact and is classified as

o Short term the impact will be for 0 ndash 3 years or only last for the period of

construction

o Medium term three to ten years

o Long term longer than 10 years or the impact will continue for the entire

operational lifetime of the project

o Permanent this applies to the impact that will remain after the operational

lifetime of the project

Intensity This is the degree to which the project affects or changes the

environment and is classified as

o Low the change is slight and often not noticeable and the natural functioning

of the environment is not affected

o Medium The environment is remarkably altered but still functions in a

modified way

o High Functioning of the affected environment is disturbed and can cease

Probability This is the likelihood or the chances that the impact will occur and

is classified as

o Low during the normal operation of the project no impacts are expected

o Medium the impact is likely to occur if extra care is not taken to mitigate

them

o High the environment will be affected irrespectively in some cases such

impact can be reduced

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 6-2

Confidence This is the level knowledgeinformation the environmental impact

practitioner or a specialist had in hisher judgement and is rated as

o Low the judgement is based on intuition and not on knowledge or

information

o Medium common sense and general knowledge informs the decision

o High Scientific and or proven information has been used to give such a

judgment

Significance Based on the above criteria the significance of issues will be

determined This is the importance of the impact in terms of physical extent and

time scale and is rated as

o Low the impacts are less important

o Medium the impacts are important and require attention mitigation is

required to reduce the negative impacts

o High the impacts are of great importance Mitigation is therefore crucial

Cumulative Impacts The possible cumulative impacts will also be considered

Mitigation Mitigation for significant issues is incorporated into the EMP for

construction

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 7-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS

71 IMPACTS DURING CONSTRUCTION

711 Air quality

Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris

handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine

particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural

operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks

and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)

Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Fugitive particulate emissions (dust)

related to construction activities Regional

Short

term Medium High High Medium Regional

Short

term Low High High Low

Construction vehicle gas emissions Regional Short

term Medium High High Medium Regional

Short

term Low High High Low

712 Heritage and archaeological resources

Naturedescription of impact excavation activities may impact on unidentified heritage resources

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-2

Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based

on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments

Heritage and archaeological

resources Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on unidentified heritage

resources Local

Short

term

Medium -

high Low High Low

713 Biodiversity and conservation

Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation

importance and cause soil contamination

Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species

Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan

and has compiled a list of protected species to be rescued (see draft EMP)

Biodiversity and conservation Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Loss of fauna and flora Local Perma

nent

Medium -

high High High High Local

Permanen

t Medium High High Medium

Soil contamination Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-3

714 Water related impacts

Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater

runoff spills and leaks Soil erosion

Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of

spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste

disposal Stormwater quality monitoring (see draft EMP)

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Soil erosion Local Short

term Medium Medium High Medium Local

Short

term Medium Low High Low

715 Waste management

Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed

Commentmitigation see draft EMP and waste management plan

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-4

Waste management Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Local

Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

716 Health and safety

Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Short

term

Medium -

high

Medium -

high High High Local

Short

term

Medium -

high Low High Low

717 Traffic

Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and

construction workers from surrounding areas and transport of equipment from the port

Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low

Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and

accurate estimates of quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-5

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Increased traffic on N2 and within the

IDZ Regional

Short

term Low High High Low

718 Noise

Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Short

term

Medium-

high High High Medium Local

Short

term Medium High High Medium

719 Socio-economic

Naturedescription of impact temporary employment will be created during the construction phase

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-6

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Temporary employment Regional Short

term Medium High High Medium

72 IMPACTS DURING OPERATION

721 Air quality

NatureDescription of impact gas and particulate emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning

Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local

sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and

veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute

to background fine particulate concentrations (von Gruenewaldt 2011b)

Assumptions and limitations Potential release of CR6+

As no emission factors are available for trivalent chromium processing the

potential impacts due to these activities could not be quantified

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Dust emitted from traffic on paved roads Regional Long Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-7

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

term

Hydrogen chloride emissions from

pickling process Local

Long

term Low High High Low

Particulate emissions (smoke) from

galvanizing process (due to the

volatilization of flux)

Local Long

term Low High High Low

Particulate oxides of nitrogen carbon

monoxide and sulphur dioxide emissions

from LNG burner

Local Long

term Low High High Low

Nuisance related to odour Local Long

term Low Low High Low

Abnormally high hydrogen chloride and

particulate emissions due to scrubber

malfunction

Local Short

term Medium Low High Medium

Gases (eg SOx NOx CO etc) and

smoke emitted in case of a fire Local

Short

term High Low High Medium

722 Water quality

NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks

Commentmitigation see draft EMP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-8

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Stormwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

723 Waste management and hazardous substances

NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous

waste both can affect environmental quality and human health

Commentmitigation see draft EMP and waste management plan

Waste management and hazardous

substances Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Regional

Long

term High

Medium -

high High High Regional Long term High Low High Low

Soilwaterair pollution due to improper

transport storage and handling of

hazardous substances

Regional Long

term High

Medium -

high High High Regional Long term High Low High Low

Health hazard Local Long

term High

Medium -

high High High Local Long term High Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-9

724 Health and safety

Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Long

term

Medium-

high

Medium-

high High High Local Long term

Medium-

high Low High Low

725 Traffic

Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on

the road network

Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak

hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road

network within Zone 6 of the IDZ (Iliso 2011)

Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)

Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of

quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-10

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on traffic and capacity of the N2 Regional Long

term Low High High Low

Impact on traffic and capacity of ring

road 1 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR435 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR450 Local

Long

term Low High High Low

Impact on traffic and capacity of

Neptune road Local

Long

term Low High High Low

726 Noise

Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Long

term Medium High High Medium Local Long term Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-11

727 Socio-economic

Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate

revenue for the municipality and the region as a whole

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Employment and economic growth Regional Short

term Medium High High Medium

73 COMPARATIVE ASSESSMENT OF IMPACTS

During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as

low during operation after mitigation

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 8-1

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

As a tenant operating in the IDZ Casa Steel will be required to comply with all

current and future CDC requirements as well as with the relevant conditions of

permits licences issued to CDC (eg Integrated Stormwater Masterplan for the

eastern side of the Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)

In particular the CDC has its own requirements regarding the monitoring of certain

aspects of the project such as the quality of the effluent and the noise levels These

have been incorporated into the EMP

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 9-1

9 ENVIRONMENTAL IMPACT STATEMENT

All predicted negative impacts can be mitigated to a low significance The only

exceptions are biodiversity as the construction of the plant will result in the

destruction of habitat and loss of fauna and flora and noise impacts inherent to

construction activities Mitigation measures have been included in the EMP for these

impacts and they have a medium significance post-mitigation

Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium to

long term similar impacts are likely to occur due to ongoing developments in the IDZ

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 10-1

10 CONCLUSION AND RECOMMENDATIONS

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as

other infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified

and assessed No fatal flaws have been identified

It is recommended that the project be approved subject to the conditions listed in

chapter 9 and adherence to the EMP requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 11-1

11 REFERENCES

Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ

Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants

Bennie JS (2010) The historical component (built environment) of the Heritage

Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port

Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report

compiled for Eastern Cape Heritage Consultants

Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater

Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay

Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage

Consultants

BKS (2006) Coega Industrial Development Zone Transport Study Volume 3

Demand Modelling Report Final Draft

Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I

Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6

Report compiled for SRK Consulting

Coastal amp Environmental Services (2010) Environmental Impact Assessment for the

Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone

Volume 3 Environmental Impact Assessment Report CES Grahamstown

Coega Development Corporation (2008) Industry Waste Management Plan -

Strategic Master Plan Report

Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants

Report No CDCSHE 03 8122

Department of Water Affairs and Forestry (1998) Waste Management Series

ldquoMinimum Requirements For The Handling Classification And Disposal Of

Hazardous Wasterdquo Second Edition

Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising

Plant in the Coega Industrial Development Zone

Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the

Coega Industrial Development Zone (IDZ) Specialist Water Study

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 11-2

Jacobs E (2008) Final Environmental Impact Report and Draft Environmental

Management Plan Proposed Steel Recycling and Processing Facility within the

Coega IDZ Report compiled for SRK Consulting

Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY

Galvanising Plant in the Coega Industrial Development Zone Waste Management

and Hazardous Substances Report compiled for ILISO Consulting

RSA National air quality standard for thoracic particulates (PM10) SA standards

(Government Gazette No 32816)

von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed

Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape

Report compiled for ILISO Consulting

von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel

Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report

compiled for ILISO Consulting

Additional sources

Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed

Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared

for Coastal Environmental Services

Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed

Kalagadi Manganese smelter in the Coega Industrial Development Zone Port

Elizabeth Eastern Cape Province Report prepared for Coastal Environmental

Services

Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia

steel recycling facility at the Coega Industrial Development Area Port Elizabeth

Prepared for SRK Consulting Port Elizabeth

APPENDIX A

LIST OF INTERESTED AND

AFFECTED PARTIES

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

DEDEARegional Manager

and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza

DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza

DEA Ocean and

CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza

DEA Ocean and

Coast

Oceanographer land-

based sources of

marine pollution

Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza

DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza

CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza

CDCEnvironmental

Project

Manager

Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza

TNPAPort of Ngqura

Environmental

Manager

Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet

NMBMEnvironmental

ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza

NMBMEnvironmental

ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza

DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza

DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza

WESSASenior Conservation

Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza

Zwartkops

ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700

hughlauegmailcom

zwartkopstrustiafricacom

SANParksNational Marine

CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza

Department Of

LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza

NMBM Air Quality

Division

Assistant

DirectorAir

Pollution and Noise

Templeton Titima 079 490 0574 Ttitimamandelametrogovza

NMBM Air Quality

DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza

NUMSARegional

RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

Department of

HealthNadiema

van der

Bergh083 378 2103

nadiemavanderberghimpiloecprovgov

za

DWA Chief Services

Officer

Joseph Jacobs 041 586 4884 jjacobsdwafgovza

EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza

NUMSecretary of union

officesZandile Xhentsa 043 743 6597 zxhentsanumorgza

DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza

Dynamic

CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom

EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza

Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza

UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom

lprincezago2uticom

Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza

Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza

Absa Mr Johann Steyn 082 3775820 johannstabsacoza

Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza

PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza

Universal

EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza

Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza

GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom

Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza

NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom

DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza

DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza

TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet

DWA Mr Landile Jack JackLdwagovza

DWA Ms Lizna Fourie FourieL4dwagovza

APPENDIX B

NOTICE OF ATMOSPHERIC

EMISSIONS LICENCE APPLICATION

AND ADVERTISEMENT

APPENDIX C

NOTICE OF COMMENT PERIOD FOR

DRAFT SCOPING REPORT

APPENDIX D

SUMMARY OF ISSUES RAISED AND

RESPONSES THERETO

April 2012

1

PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL

DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))

IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt

AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt

This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses

provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process

conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the

Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

2

IssueCommentQuestion Date

received Origin Response

1 Please provide more information with respect to the potential

dangers including the toxicity of the proposed project

07032011

By email

Wayne Poulton

(Bosun Brick

tenant at the

IDZ)

An Environmental Impact Assessment (EIA) was undertaken

which assessed the potential toxicity of the emissions and

effluent Mitigation measures were also recommended in the draft

Environmental Management Programme (EMP) to avoid

minimise or compensate any significant impacts The Draft

Environmental Impact Report and draft EMP were made available

to stakeholders for comment in March 2012

2 Do you have a Background Information Document (BID) or

similar that provides more information on the project

27032011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The BID was sent to all registered IampAPs on 4 May 2011

3 The RoD issued to the CDC on 632007 for the change in

land use for the remaining area of the Coega IDZ includes a

number of requirements with respect to

atmospheric emissions that should be considered in the

Atmospheric Emissions Licence (AEL) application such as

prohibiting and monitoring where possible visible emission

plumes to the atmosphere In particular the

recommendations on pp87-91 of the final revised Scoping

Report dated Nov 2006 must be implemented (clause 421)

04042011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

We have obtained copies of the documents referred to and ensure

that these requirements were taken into account in the

environmental assessment and AEL application

4 If the Port of Ngqura is used for import and export the scope

of the traffic impact assessment (TIA) should also include the

port

10052011

By email

Elliot

Motsoahole

(TNPA Port of

Ngqura)

The scope of the TIA was extended to include port related traffic

The TNPA at the Port of Ngqura was consulted and does not

have any objection to the project TNPA has indicated that the

development would require a minimum number of vessels per

year which would have minimal impact on the Port operations

However due notice would have to be given to the Port of Ngqura

before a vessel is scheduled to arrive so that the vessel can be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

3

IssueCommentQuestion Date

received Origin Response

accommodated at an available berth

5 Concerns with respect to potential stormwater pollution

draining into the Coega catchment and the port of Ngqura

The port needs to be dredged and heavy metals present a

risk in that regard

16052011

By

telephone

Andrew Lucas

(Department of

Water Affairs)

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination by effluent waste or

hazardousdangerous substances is very low

Thus no metals oils or other contaminants are expected to be

present in the stormwater

However stormwater pollution can occur in exceptional

circumstances such as accidents and emergencies The

emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

6 All steel sheets bathing unit must be under roof

7 The sludge out of the decreasing bath will be high in Na and

pH Therefore handling and disposal must be clarified up front

in this project

8 Per se the wastewater from decreasing bath will have high

ph and the component from the pickling unit will have low ph

Then it may be assumed that both streams will neutralize

each other Please then clarify proposed sewer discharge

with Nelson Mandela Bay Municipality up-front for acceptance

of influent as per the documented proposal

9 Pickling may result in dissolved metals How does your team

expect to deal with this As it is planned for discharge into

24052011

By email

Landile Jack

(Department of

Water Affairs)

All bathing units will be under roof

Effluent from the degreasing and pickling baths will be discharged

to the wastewater treatment plant The respectively alkaline and

acidic effluents will mix and neutralise each other in the

wastewater treatment plant Calcium or gypsum will be added if

required to complete the neutralisation process Effluent from the

treatment plant will be discharged to sewer Contact has been

made with the relevant officials and the Municipalityrsquos

requirements have been obtained The effluent discharged to

sewer will notably comply with the applicable discharge standards

Traces of metals (eg iron) may be present but will not exceed

prescribed thresholds The necessary authorisation will be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

4

IssueCommentQuestion Date

received Origin Response

sewer Clarity and acceptance needs to be agreed with

Nelson Mandela Bay Municipality Who owns the sewer

10 Quenching unit will results to Zinc particles How will this

affect sewer discharge This again must be dealt with within

the negotiations with the Municipality

11 Once all has been agreed with the Municipality and at the

same time due negotiations must be done with hazardous

waste courier and disposal facility to accept the hazardous

waste identified in all production lines

12 Of note is the low volume of the proposed WWTW facility ie

250 cubmweek And the no discharge of the quenching

water ie over-flow and cooling only Hence Zinc particles

generation

obtained from the municipality

The sludge from the treatment plant will be collected by a licensed

service provider and disposed of at a permitted site

The quenching bath will be periodically emptied (every 6 months)

and the water discharged will go to the water treatment plant Zinc

particles will settle in the sludge which will be disposed of at a

permitted site

Contact has been made with EnviroServ who manages the

Aloes II HH waste site regarding collection and disposal of

hazardous waste (See waste management report)

13 Investigate the potential effects of toxicity andor influence of

emissions waste and hazardous substances both in

terrestrial and marine fauna

14 With regards to water usage where is the plant going to

extract its waters used in galvanization andor waste

management process ie rainfall rivers or even from the

sea) and which avenues would be more environmental

friendly and effective

31052011

By email

A Bewana

(SANPARKS)

Emissions waste and hazardous substances are not expected to

affect terrestrial or marine ecosystems The air quality study

concluded that atmospheric emissions would not be harmful to

human health and by extension terrestrial fauna There are no

standards for air quality for defining faunal impacts therefore by

ensuring that standards for humans are complied with the impact

on fauna is deemed to be acceptable In this case the impact of

emissions on terrestrial and marine fauna are thus not significant

Solid and liquid wastes both general and hazardous as well as

hazardous substances will be stored handled and disposed of

appropriately to as not to cause harm to terrestrial or marine

fauna

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

5

IssueCommentQuestion Date

received Origin Response

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination and hence land-based

marine pollution by effluent waste or hazardousdangerous

substances is very low

The risk of emissions waste and hazardous substances to

terrestrial and marine fauna is thus very low

However pollution of terrestrial and marine ecosystems can occur

in exceptional circumstances such as accidents and emergencies

The emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

The CDC has an agreement with the NMBM to supply potable

water to the Coega IDZ Currently the infrastructure to supply

return effluent (RE) to the IDZ is not in place therefore Casa Steel

will be supplied with potable water up until such time as the

following 2 options of RE are available

1) Upgrading of the existing Fishwater Flats waste water

treatment works (between IDZ amp PE) including RE plant

and infrastructure to pipe RE to the IDZ (EIA for the

upgrade is underway)

2) Construction of a new waste water treatment works

including RE plant in Zone 9 of the Coega IDZ

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option should be investigated further between Agni and Casa The

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

6

IssueCommentQuestion Date

received Origin Response

CDC can facilitate discussions between the 2 investors

Compliance with CDC Permits amp Requirements

15 It should be made clear that tenants will be required to

comply with CDC requirements and the relevant conditions of

permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water

Licence for its Storm Water Systems on the

East Side of the Coega River that tenants will

need to take cognizance of The contents of the

ldquoIntegrated Stormwater Masterplan for the

eastern side of the Coega IDZ Oct 2010rdquo

especially the Table of best practice p53

onwards may need to be taken cognizance of

o CDC is developing an Operations

Environmental Management Plan that will place

certain obligations on tenants

16 Environmental audits and data collected during monitoring

(eg stack emissions stormwater) will need to be shared with

CDC

Air Emissions

17 Presumably permanent in stack monitoring will be required in

terms of AEL permit requirements

18 Abnormal operating conditions resulting in air emissions ndash I

could find nothing in the EIR to indicate under what

circumstances these could occur (eg start-up) potential

frequency and duration and the impact on ambient air quality

ndash these events usually result in the most problems wrt air

emissions

09042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

15 Compliance with the CDCrsquos Permits amp Requirements has

been included explicitly as a requirement in the EIR (p8-1) and

EMP (pp18 and 25) in the following terms

ldquoAs a tenant operating in the IDZ Casa Steel will be required to

comply with all current and future CDC requirements as well as

with the relevant conditions of permits licences issued to CDC

(eg Integrated Stormwater Masterplan for the eastern side of the

Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)rdquo

16 The need to communicate with the CDC on monitoring and

auditing activities was emphasised in Chapter 8 of the EMP The

following paragraphs were added

ldquoDuring construction the environmental officer will be responsible

for monitoring compliance with the EMP and authorisation

conditions and keeping records as required in the EMP andor

authorisation conditions

The ECO will conduct site inspections every two weeks audit the

records kept by the environmental officer and submit an

environmental compliance report every two months to the

authorities and the CDC (via the Environmental Monitoring

Committeersquos ECO)

During operation the health and safety officer will monitor

compliance with the EMP and the conditions of the Environmental

Authorisation Data collected during monitoring activities and any

environmental audits conducted will be shared with authorities

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

7

IssueCommentQuestion Date

received Origin Response

Water

19 Large volumes of (2000 m3mth) of water are required of

which only 400m3 needs to be potable The NMBM return

effluent system will provide non-potable water once it is

constructed What other water recycling initiatives can be

utilized to reduce potable water requirements (the ISWMP for

the eastern side of the Coega IDZ has some best practice

guidelines collecting rainwater from the roof etc)

General

20 There is no mention of how the CDC Architectural Guidelines

will be incorporated into the development (eg to prevent a

stark uniform warehouse type development)

21 Does NMBM have adequate fire services to cover this

development Apart from the large petroleum store are there

any other large fire hazards

22 Reports from the tenantrsquos ECO during construction and from

the SHE Officer during operations should be channeled to the

Coega Environmental Monitoring Committee This can be

directly or preferably via the EMCrsquos ECO (this will be while

the EMC and ECO are in place) A precedent has been set

for this in the Environmental Authorisations for Agni-Steel and

Kalagadi Manganese Smelter

23 All mitigation actions emanating from the EIR should be

summarized (preferably in a table) If compliance with them is

to be part of the Environmental Authorization from DEDEAT

then they (or the ones that DEDEAT deems to be applicable)

and the CDC (via the Environmental Monitoring Committeersquos

ECO)

The ECO (during construction) and the health and safety officer

(during operation) will report to the Coega Environmental

Monitoring Committee (EMC) via the EMCrsquos ECO (this will be

while the EMC and ECO are in place)rdquo

17 The draft EMP recommends regular monitoring of emissions

from the scrubbers and from the chromating process Additional

emissions monitoring requirements will be confirmed once the

AEL is issued Mention has been made in the EMP (pp11 and 19)

that all AEL conditions including monitoring and reporting

requirements should be adhered to

18 Abnormal emissions can occur in exceptional circumstances

Start-up will not cause abnormal emissions as the scrubbers

will be commissioned first and will be functioning once the plant

starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions

would be emitted as a building fugitive

The hourly hydrogen chloride ground level concentrations

(directly offsite) were predicted to be 239 microgmsup3 (based on the

emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits

as stipulated for listed activities for galvanising processes) using a

screen model which assumes worst case meteorological

conditions The health effect screening level for hourly HCl

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

8

IssueCommentQuestion Date

received Origin Response

should be attached to the EA as an Appendix (otherwise no

one knows about them or takes cognizance of them)

concentrations is 2100 microgmsup3 Assuming abnormal emissions

emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset

conditions will still be well within the health effect screening

levels

Similarly the hourly particulate emissions from the building

fugitives during upset conditions would amount to 293 microgmsup3

(based on the emission limits as stipulated for listed activities for

galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1

January 2015) directly off-site

Therefore if emissions are 5 times higher normal they will still be

within health effect screening levels and the daily PM10 NAAQS

levels

In the case of a fire a cocktail of gases and particulates could be

emitted and could be over the recommended levels This

situation will however be dealt with as an emergency and

normalised as quickly as is possible

The above has been added to the impact identificationdescription

and assessment sections of the EIR

19 The CDC has an agreement with the NMBM to supply

potable water to the Coega IDZ Currently the infrastructure to

supply return effluent to the IDZ is not in place therefore Casa

Steel will be supplied with potable water up until such time as the

infrastructure is in place

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

9

IssueCommentQuestion Date

received Origin Response

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option will be investigated further between Agni and Casa The

CDC has come forward to facilitate discussions between the two

investors

Other water recycling initiatives such as rainwater harvesting

have been considered but are not practical

20 The CDCrsquos Architectural and Landscape Design guidelines

contain requirements pertaining to such aspects as the height

orientation and mass and form of buildings as well as guidelines

for landscaping and signage in order to ensure an attractive

development and achieve an architectural integrity within the

Coega IDZ The plans for the proposed galvanizing plant will be

submitted to the Design Review Committee for approval as

required by the CDC

21 Casa Steel will be required to install fire hydrants according

to the NMBMrsquos standardsrequirements The CDC will provide

potable water (up until such time as return effluent is available)

and a connection to the boundary of the site which will be

connected to the fire hydrants The installation of the fire hydrants

will require approval by the Metrorsquos Fire Chief as was done for

Agni-Steel one of the investors in Zone 6

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

10

IssueCommentQuestion Date

received Origin Response

The Coega IDZ falls within the NMBM and therefore the rates and

taxes paid by the CDC covers the fire services for which the Metro

is responsible Currently the Metro has sufficient capacity to

provide fire services to the tenants within the IDZ This was

confirmed in discussion with the CDCrsquos Infrastructure

Development Unit It is however unknown at which point the

Metrorsquos Disaster Management Plan would not be able to

accommodate servicing tenants in the IDZ

The LNG burner is the only major fire hazard on the plant

22 See response to item 16 above

23 Key mitigation and management measures emanating from

the EIR were recapitulated in Chapter 9 of the EIR to form part of

the conditions attached to the Environmental Authorization from

DEDEAT All mitigation measures recommended as a result of the

impact assessment are presented in a table in the draft EMP

which is appended to the EIR (Appendix J)

24 Hydrogen chloride is one of the main emissions There are no

ambient air quality guidelines for HCl and the EIR says

concentrations will be well within health parameters

However the main problem with HCl is its corrosive effect -

there is absolutely no mention of this in the draft EIR nor air

specialist report

There needs to be some sort of comment assessment as to

whether HCl emissions are likely to impact on for example

the adjacent Agni-Steel Plant wrt corrosion - their factory

structure will be made of steel

11042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The atmospheric corrosion of metals is a complex process with

both the extent of deterioration and the mechanisms varying

considerably depending on the metal Depending on the way

pollutants are transported from the atmosphere to the corroding

surface two types of deposition processes are recognized in

atmospheric corrosion ndash dry deposition and wet deposition Wet

deposition refers to precipitation whereas dry deposition refers to

the remaining processes including gas phase deposition and

particle deposition The most important pollutants acting as

corrosive agents are sulphur and nitrogen compounds including

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

11

IssueCommentQuestion Date

received Origin Response

The EIR specialist rpt suggests monitoring HCl at ground

level on the property boundary and this is supported in case

there are complaints from neighbours

secondary pollutants and particulates Pollutants can contribute to

corrosivity individually however there may be a synergistic effect

when more than one of these pollutants is present in the

environment being affected In the field of atmospheric corrosion

sulphur dioxide is the single most investigated gaseous pollutant

and the quantification of the direct contribution of sulphur dioxide

to the corrosion process of metallic materials is comparatively well

understood (Tidblad amp Kucera 1998)

Very little work has reported on the effect of HCl on the

degradation of materials in the environment with no local dose-

response thresholds developed for corrosion occurring due to HCl

exposures This is probably because HCl which is present

outdoors in markedly reduced concentrations when compared

with SO2 has not been considered to contribute to significant

degradation of materials (Syed 2006) For this reason the

incremental corrosion due to HCl from the Coega Galvanising

Plant cannot be quantified

25 It is unacceptable for ILISO to be using CDC maps (see

figure 9 ndash pg5-6) without these maps being referenced

accordingly particularly when it appears that a CDC map has

been used and then overlaid with features by an unknown

author (ie CASA steel site Port (where the boundaries

depicted are incorrect) and a North legend which is out of

keeping with the overall cartographic intent of the original

work

26 Figure 10 is not referenced appropriately and I believe that I

commented previously in respect to references to roads not

12042012

By email

Graham Taylor

(Spatial

Development

Manager -

Infrastructure

Development

CDC)

This has been rectified in the final version of the report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

12

IssueCommentQuestion Date

received Origin Response

yet built As a result Figure 10 is confusing and clarity needs

to be provided in terms of referencing In addition the Port

shape is irregular and similar to the comment above

27 I acknowledge the emergency preparedness and response

plan but please confirm that this includes pro-active routine

monitoring of storm water leaving your premises to verify that

your assumptions of clean storm water are correct

13042012

By post

Andrew Lucas

(Director

WRampU

Department of

Water Affairs)

Pro-active routine monitoring of stormwater leaving the premises

will be undertaken This has been explicitly emphasised in

chapter 8 of the draft EMP

28 Will portablechemical toilets be used during construction

29 What provisions have been made for storm water drainage

during construction

18042012

By

telephone

Department of

Water Affairs

Port Elizabeth

Chemical toilets will be used during construction

The Casa Steel site will be located at the corner of two roads

drainage of stormwater from the site will take place through the

roadsrsquo drainage system

From Lea September [mailtoleailisocom]

Sent 11 March 2011 0935 AM

To Wayne Poulton

Cc Terry Baker

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Wayne

An Environmental Impact Assessment (EIA) will be undertaken for this project during the

next 10 to 12 months

We foresee that some of the key environmental impacts of the project will be in terms of air

quality water quality waste and hazardous substances

At this stage I am not able to give you any details regarding the potential toxicity of the

emissions andor effluent However specialist studies will be conducted as part of the EIA

that will determine the key impacts of the project Mitigation measures will also be identified

to avoid minimise or compensate any significant impacts

You are registered on the stakeholder database and you will be kept informed of progress in

the EIA process you will notably get the opportunity to access the reports produced and

provide any feedback on them

Please feel free to contact me should you need any further information

Best regards

Lea September

From Wayne Poulton [mailtowaynepbosuncoza]

Sent 07 March 2011 1257 PM

To Lea September

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

Please can you provide me with some more information as to the potential dangers including

the toxicity of this

Kind regards

Wayne

From Lea September [mailtoleailisocom]

Sent 04 March 2011 1123

To Lea September

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 March 2011 0745 AM

To Paul Martin

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 05 April 2011 0847 AM

To Paul Martin

Cc Terry Baker Renee von Gruenewaldt

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Thank you Paul for this information

I have downloaded a copy of the RoD and Scoping report you referred to and will make sure

these requirements are taken into account in the environmental assessment

Best regards

Lea September

From Paul Martin [mailtopmartinaxxesscoza]

Sent 04 April 2011 0955 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Further to my comments on 27311

Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in

the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega

IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised

scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions

including prohibiting and monitoring where possible visible emission plumes to the atmosphere

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Paul Martin

Sent Monday March 28 2011 745 AM

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 10 May 2011 0327 PM

To ElliotMotsoaholetransnetnet

Cc Terry Baker

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Mr Motsoahole

Thank you for your input on this issue

The Port of Ngqura will indeed be used for import and export At the moment the scope of

the traffic impact assessment only covers road traffic I have however relayed the matter to

our traffic specialist and we will consider this issue in the finalization of the Scoping Report I

will keep you informed of any developments in that regard

I trust this is acceptable to you

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]

Sent 10 May 2011 0855 AM

To Lea September

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

It has been noted that Casa Steel will source steel coils from various markets internationally and

in South Africa and the bulk of the plantrsquos production output will be exported to African countries

However there is no mention of logistic requirements

Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will

be used the scope of traffic impact assessment should also include the port

Regards

From Lea September [mailtoleailisocom]

Sent 04 May 2011 0747 AM

To Lea September

Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

Please find attached a letter announcing the EIA process underway for the proposed 80 000

tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as

a Background Information Document (BID) outlining the details of the project

Please contact me should you require any further information on this project

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

Elliot Motsoahole

Manager - Environment

Transnet National Ports Authority

Port of Nqqura

Port Control Building Klub Road Port Elizabeth 6212

PO Box 612054 Bluewater Bay 6212

+27 41 507 8450

+27 86 674 7729

Cell +27 83 542 5619

E-mail Elliotmotsoaholetransnetnet

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

DISCLAIMER The information contained in this communication is subject to copyright and

intended only for the use of leailisocom Unauthorised use disclosure or copying is

strictly prohibited Should a virus infection occur as a result of this communication the sender

will not be liable If you have received this communication in error please notify

elliotmotsoaholetransnetnet

From Lea September [mailtoleailisocom]

Sent 25 May 2011 1147 AM

To Jack Landile (ELS)

Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi

Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Landile

Thank you for your input

Contact has been made with the relevant Municipal Directorate and we will follow up with

them to obtain clarifications on all these issues

I have added both Lizna and yourself on the database and will keep you updated on

progress on this project

Best regards

Lea September

From Jack Landile (ELS) [mailtoJackLdwagovza]

Sent 24 May 2011 0524 PM

To Fourie Lizna (ELS)

Cc Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Hi Lizna

I missed you on this sorry

I linked Pieter twice Instead

Regards

Landile

From Jack Landile (ELS)

Sent 24 May 2011 0445 PM

To leailisocom

Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Lea

The e-mail you sent to Mr Kooverji dated 19 May 2011 refer

Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are

All steel sheets bathing unit must be under roof

The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project

Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal

Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer

Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality

Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines

Of note is the low volume of the proposed WWTW facility ie 250 cubmweek

And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles

generation

Regards

Landile

From Lea September [mailtoleailisocom]

Sent 19 May 2011 0947 AM

To Lea September

Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Stakeholder

Please find attached the remaining appendices to the draft Scoping report for the proposed

80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 June 2011 0411 PM

To Aphiwe Bewana

Subject RE Proposed 80 000 TPY Galvanizing plant in Coega

Dear Mr Bewana

Thank you for your input and apologies for the late reply

We have taken note of your comments and are will be taking them forward in the EIA phase

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Aphiwe Bewana [mailtoaphiwebewanagmailcom]

Sent 31 May 2011 1205 PM

To Lea September

Subject Re Proposed 80 000 TPY Galvanizing plant in Coega

Comment

Re Proposed 80 000 TPY Galvanizing plant in Coega

As SANParks we would like the EIA phase to investigate the potential effects of toxicity

andor influence of emissions waste and hazardous substances both in terrestrial and

marine fauna In the draft scoping report reference has been made with regards to the

terrestrial fauna but there is no attention to potential effects to marine fauna

Equally with regards to water usage where is the plant going to extract its waters used in

galvanization andor waste management process ie rainfall rivers or even from the sea)

and which avenues would be more environmental friendly and effective

Regards

Aphiwe Bewana

Marine Planner

South African National Parks

POBox 76693

NMMU

Port Elizabeth

6031

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 06 July 2011 1031 AM

To Lea September

Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Hi Lea

Irsquove reviewed the Final Scoping Report Herewith a few comments

1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the

Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a

revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the

NMBLP Please include only those in the IDZ as part of your IAP list

Regards

Andrea

From Lea September [mailtoleailisocom]

Sent Wednesday July 06 2011 859 AM

To Lea Septemberrsquo

Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Dear Stakeholder

The final scoping report for the above-mentioned project (attached) is available for comment

until 27 July 2011

The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic

commentaryrdquo tab

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 09 April 2012 1159 AM

To Lea September

Subject Comments on Galvanising Plant EIR Coega IDZ

Lea

Attached are my comments on the Draft EIR for the Coega IDZ galvanising

plant

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

Email attachment

COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ

Dr Paul Martin PO Box 61029

Bluewater Bay 6212 Tel 041 4665698

Email pmartinaxxesscoza

Compliance with CDC Permits amp Requirements

It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of

o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants

Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC

Air Emissions

Presumably permanent in stack monitoring will be required in terms of AEL permit requirements

Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions

Water

Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)

General

There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)

Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards

Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter

All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 11 April 2012 1245 PM

To Lea September

Subject Fw Comments on Galvanising Plant EIR Coega IDZ

Lea

One other comment on that I have on the Galvanising Plant Draft EIR

Hydrogen chloride is one of the main emissions There are no ambient air

quality guidelines for HCl and the EIR says concentrations will be well

within health parameters

However the main problem with HCl is its corrosive effect - there is

absolutely no mention of this in the draft EIR nor air specialist report

There needs to be some sort of comment assessment as to whether HCl

emissions are likely to impact on for example the adjacent Agni-Steel

Plant wrt corrosion - their factory structure will be made of steel

The EIR specialist rpt suggests monitoring HCl at ground level on the

property boundary and this is supported in case there are complaints from

neighbours

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Paul Martin ltpmartinaxxesscozagt

To Lea September ltleailisocomgt

Sent Monday April 09 2012 1158 AM

Subject Comments on Galvanising Plant EIR Coega IDZ

gt Lea

gt

gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising

gt plant

gt

gt

gt Dr Paul Martin

gt PO Box 61029

gt Bluewater Bay 6212

gt Tel 041 4665698

gt Cell 0732524111

gt email pmartinaxxesscoza

gt

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 12 April 2012 1139 AM

To Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Hi Lea

Hope yoursquore keeping well

I have requested comments from my colleagues and the CDC Casa team on the Draft EIR

Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report

Regards

Andrea

From Graham Taylor

Sent Thursday April 12 2012 838 AM

To Andrea Von Holdt Firhana Sam

Cc Johan Fourie Maria van Zyl Melikhaya Sihawu

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Andrea Firhana

Firhana if you could please ensure that the co-ordinates provided in the EIR correspond

with our records (pages 4-1 amp 4-2)

My comments are as follows

It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work

Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above

Regards

Graham Taylor

Spatial Development Manager - Infrastructure Development

Mobile 0832283055

Office 0414030454

Facsimile 0865185033

Email GrahamTaylorcoegacoza

Website wwwcoegacom

right PLACE | right TIME | right CHOICE

This email and all contents are subject to the following disclaimer

httpwwwcoegacomemaildisclaimerhtml

From Lea September [mailtoleailisocom]

Sent 04 May 2012 0411 PM

To Andrea Von Holdt

Cc Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Dear Andrea

We have taken note of the comments from the GIS Unit These issues have been rectified in

the final version of the EIR

Please can you forward to the relevant persons at the GIS Unit

Thank you

Best regards

Lea September

APPENDIX E

BACKGROUND INFORMATION

DOCUMENT

APPENDIX F

AIR QUALITY IMPACT ASSESSMENT

APPENDIX G

TRAFFIC IMPACT ASSESSMENT

APPENDIX H

WASTE MANAGEMENT AND HAZARDOUS

SUBSTANCES SPECIALIST STUDY

APPENDIX I

WATER QUALITY SPECIALIST STUDY

APPENDIX J

ENVIRONMENTAL MANAGEMENT

PROGRAMME

Page 9: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 vii

The proposed galvanizing plant will make a positive contribution by creating jobs during

construction and operation and generating business for the various service providers

Fatal flaws

No fatal flaws have been identified

The significance of these potential key environmental impacts were assessed in the EIA

phase and the findings of this phase of investigations are presented in this report

The main findings of the EIA are as follows

During construction impacts post-mitigation are low with the exception of noise and

biodiversity as the construction of the plant will result in the destruction of habitat

and loss of fauna and flora and noise impacts inherent to construction activities

Mitigation measures have been included in the EMP for these impacts and they have

a medium significance post-mitigation

All impacts were assessed as low during operation after mitigation

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium

to long term similar impacts are likely to occur due to ongoing developments in the

IDZ

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

The CDC has its own requirements regarding the monitoring of certain aspects of the

project such as the quality of the effluent and the noise levels These have been

incorporated into the EMP Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as other

infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified and

assessed No fatal flaws have been identified

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 viii

It is recommended that the project be approved subject to the conditions listed above

and adherence to the EMP recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-1

1 INTRODUCTION

11 BACKGROUND

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)

Nelson Mandela Bay Municipality Eastern Cape Province

The demand for galvanised steel products is high in South Africa and Africa and is

expected to increase in the foreseeable future From an economic point of view the

proposed project has therefore been found to be viable

Casa Steel will source the steel coils from various markets internationally and in

South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is

destined to be exported mainly to African countries

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

An Environmental Impact Assessment (EIA) is required as the proposed project

involves several activities listed in terms of Section 24 of the National Environmental

Management Act (NEMA) No 107 of 1998 as amended and requires an

environmental authorisation

The following listed activities requiring environmental authorisation have been

identified

Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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 metres

Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped

land to industrial use greater than 1 ha but less than 20 ha in size outside an

urban area

Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any

process or activity requiring a license in terms of national or provincial legislation

governing the generation or release of emissions

Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5

hectares or more of vegetation where 75 or more of the vegetative cover

constitutes indigenous vegetation except where such removal of vegetation is

required for

(i) purposes of agriculture or afforestation inside areas identified in

spatial instruments adopted by the competent authority for

agriculture or afforestation purposes

(ii) the undertaking of a process or activity included in the list of waste

management activities published in terms of section 19 of the

National Environmental Management Waste Act 2008 (Act No 59

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-2

of 2008) in which case the activity is regarded to be excluded from

this list

(iii) the undertaking of a linear activity falling below the thresholds in

Notice 544 of 2010

Hot dip galvanizing is a listed activity in terms of section 21 of the National

Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires

an Atmospheric Emissions Licence (AEL)

In addition the treatment of wastewater with an annual throughput capacity of more

than 2000 m3 is a listed activity in terms of the National Environmental Management

Waste Act 59 of 2008 and requires a waste management licence

ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental

Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact

Assessment process in terms of section 24 of NEMA for the construction and

operation of the proposed galvanizing plant The EIA process covers all aspects of

the project and informs all three applications (for environmental authorisation waste

management licence and AEL)

13 PURPOSE OF THIS REPORT

This report builds on the scoping report submitted to the Eastern Cape Department of

Economic Development and Environmental Affairs (DEDEA) and the Nelson

Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It

describes the proposed project and presents the findings of the second phase of

investigations (EIA phase)

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT

PRACTITIONER (EAP)

The EIA was managed by Ms Terry Baker a certified Environmental Assessment

Practitioner with 20 years of working experience She has a MA in Environmental

Management and specialises in Environmental Impact Assessments and Project

Management She has been involved in a variety of different types of EIAs including

for water supply projects dams transmission lines roads and airports in South

Africa Botswana Uganda Lesotho and Mozambique She has been involved in

water resource management and public participation programmes on a number of

projects Terry has also been involved in the use of Geographic Information Systems

environmental status quo reports water quality assessments socio-economic and

institutional development projects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-3

15 PROJECT TEAM

In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen

(water quality specialist) and Lea September (EAP) with specialist input from Renee

von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous

substances) and Seniel Pillay (Traffic Impact Assessor)

The Business Unit Head of the ILISO Environmental Management Discipline Group

Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is

a Fellow of the South African Institution of Civil Engineers a member of the South

African Society of Aquatic Scientists of the Environmental Scientific Association of

the International Water Association of the Water Institute of South Africa and of the

Vaal River Catchment Association He is a certified Environmental Assessment

Practitioner with 30 years experience who specialises in project management

environmental impact assessments and water resource planning He specifically has

extensive experience in water quality especially water quality management water

quality monitoring and water quality assessment Martin has experience in managing

projects that involve multi-disciplinary teams and public consultation and

participation in South Africa and abroad

Lea September is an Environmental Assessment Practitioner with a Masters degree

in Environmental Management She has experience in impact assessment and

environmental management and has been responsible for drafting impact

assessment reports and Environmental Management Programmes and conducting

public participation processes as well as high level environmental screenings for a

variety of projects in the energy water transport and industrial sectors

Renee von Gruenewaldt has nine-years experience in the field of air pollution

impact assessment and air quality management Prior to becoming involved in air

quality consultation she was part of the Highveld Boundary Layer Wind Research

Group based at the University of Pretoria Since joining Environmental Management

Services (the company now Airshed Planning Professionals) she has undertaken

numerous air pollution impact studies and has provided extensive guidance to both

industry and government on air quality management practices

Pieter Smuts graduated as a Civil Engineer and became involved in the field of

municipal engineering and infrastructure construction He has specialized during the

last twelve years in solid waste management He has completed waste management

plans feasibility studies and final designs of waste management facilities in South

Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and

the review of the Mavoco hazardous waste landfill design in Maputo Mozambique

and completed a study on hazardous waste (textile factory sludge) management in

Maseru Lesotho

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-4

Seniel Pillay is a transportation engineer with over 16 years experience in

transportation planning and traffic engineering He has been involved in a wide

range of projects ranging from developing the Transport Operations Plan for the

FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System

for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller

traffic impact assessments for inter alia road improvement schemes Of particular

relevance to this project his experience includes Heavy Goods Vehicle Study for

eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact

Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash

Preliminary Transportation Assessment

16 STRUCTURE OF THIS REPORT

The proposed project and the alternatives considered are described in Chapter 2

Chapter 3 details the approach adopted for the EIA phase

The biophysical and socio-economic environment affected by the activity is described

in Chapter 4

The environmental impacts identified are discussed in Chapter 5

The EIA methodology is described in Chapter 6 and Chapter 7 presents the results

of the impact assessment

The environmental impact statement is presented in Chapter 8

Finally Chapter 9 spell out the conclusions and recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-1

2 DESCRIPTION OF THE PROPOSED PROJECT

21 TECHNICAL ASPECTS

211 The galvanizing process

Galvanizing consists of coating steel with zinc in order to protect it from corrosion

Before steel strips can be galvanized they undergo a pre-treatment in order to

ensure that the steel sheets are free from any surface oxides as they enter the

molten zinc coating Bath This is done by removing the oil from the steel sheets (in

the degreasing unit) and then removing the rust from the surface of the sheet (in the

pickling unit)

The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The

melting zinc on the strip surface will be cooled and solidified through air cooling in the

cooling tower

Finally the galvanised steel sheets are dipped into a water quenching tank in order to

further cool the sheets from about 150degC to 40degC

It is possible to make galvanised steel more durable by chromating it Approximately

50 of the galvanised steel production output will receive chromate passivation

treatment after quenching the galvanised steel sheets will be sprayed with a chrome

solution (3 kgcm2)

After galvanizing and chromating the steel sheets are cut to achieve the desired coil

size and weight and transported to the storage yard

The process flow diagram below (Figure 1) illustrates the main stages of the

galvanizing process and indicates the major inputs and outputs as well as the

resulting effluent and atmospheric emissions

Draft Environmenal Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-2

Figure 1 Process flow diagram for proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-3

212 Main inputs and outputs in operational phase

In view of the above the main inputs will be as follows

Steel coils 85 000 tonsyear

Zinc 870 tonsyear

Electricity 2500 kVA

Water 2000 m3month (of which 400 m3 will be potable water)

Liquid Natural Gas (LNG) 270 NM3hour

Sodium hydroxide (NaOH) 1000 m3year

Hydrochloric acid (HCl) 800 m3year

Chrome (Cr+3) 10 m3year

The main outputs will be

Galvanized steel 80 000 tonsyear

Scrap metal 20 tonsyear

General waste 65 tonsyear

Hazardous waste 2 m3month

Wastewater 012 Mlweek

Atmospheric emissions lt 5 ppm

213 Installations on site

The bulk of the operations involved in the galvanizing process occur along a

continuous galvanizing line (See Figure 2 below) which is the main piece of

machinery required for the proposed galvanising plant

Figure 2 Continuous Galvanizing Line

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-4

Water is one of the major inputs and is used throughout the galvanizing process notably

for rinsing and cooling purposes and as a mixing agent for the various chemical

solutions The plant will have a water treatment plant on site to treat the water used in

the various processes (approx 250 m3

of wastewater per week) The wastewater

treatment facility will be operated by a professional water treatment company as Casa

Steel does not have the required expertise in house to treat its process water Sulphuric

acid (H2SO4) is used as part of the treatment process to reduce caustic soda The

neutralised water is discharged to the sewer while any sludge is disposed of as

hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)

will be disposed of

Some critical areas of the galvanizing process such as the zinc pot require uninterrupted

power It is therefore proposed to install an LNG burner to maintain the zinc bath at a

temperature of between 450 and 460degC

22 LOCATION OF THE PROPOSED GALVANIZING PLANT

The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast

of Port Elizabeth in the Eastern Cape (Figure 3)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-5

Figure 3 Location of the proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-6

23 NEED AND DESIRABILITY

The profitability of the proposed project has been established by Casa Steel and a

pre-feasibility study has confirmed that the proposed project was feasible from a

technical and financial point of view The Coega IDZ is specifically designed to host

facilities such as a galvanizing plant and can provide the necessary infrastructure

and services to its investors It therefore constitutes a very suitable location for the

project

24 ALTERNATIVES IDENTIFIED

Zone 6 has been specifically earmarked for heavy ferrous metal industries and is

therefore a suitable location for the proposed galvanizing plant as such no site

alternatives have been provided for and assessed in this EIA However prior to the

commencement of the EIA process Casa Steel was presented with a number of

different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the

selection of the site were

(a) The dimensions of the land the site should be at least 200 m long and

50 m wide in order to accommodate the galvanizing line and adjacent lay

down area and additional land should be available next to the site for future

expansion

(b) The fiscal arrangements applying to the site the site should be located

within the future Custom Controlled Area (CCA) as the bulk of the

production output of the plant will be exported

The no-go alternative is assessed in this report

25 CONSTRUCTION ASPECTS

The construction phase of the project will take about 12 months and will essentially

consist of erecting a building to house the galvanizing line and other equipment and

preparing a concrete laydown area adjacent to the building

The CDC will provide an access point from the existing tarred road that will lead to

the site

Approximately 100 workers from the surrounding areas will be contracted for the

construction work

The requirements in terms of services during construction are listed below

Water 1000 m3month

Electricity 2500 kVA

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-7

The CDC will provide temporary services for the construction phase including a

conservancy tank for flush toilets Sewage infrastructure will only be provided for the

operational phase

26 OPERATION ASPECTS

Before the plant can become fully operational the equipment and machinery will be

tested for approximately 3 months The supplier will supervise these tests as part of

the transfer of know-how and training of staff on the plant

Casa Steel will start operating the plant at a reduced capacity (about 50 000

tonsyear) for a period of time (mostly determined by market aspects) before bringing

production to full capacity (80 000 tonsyear) This is done by operating the line for

longer hours

Approximately 50 to 60 people will be working on the plant Approximately 6-10 of

these will be unskilled 40-45 skilled and about 5 people in managerial positions

The requirements in terms of services during operation are as follows

Water 2000 m3month

Electricity 2500 kVA

Effluent discharge 24 m3day

The CDC has entered into agreements with the municipality to secure the provision

of services such as water and electricity to its tenants Tenants in the IDZ have their

own agreements with the NMBM for electricity while the agreements for water and

sewage are with the Facilities Unit of the CDC

Regarding discharge of wastewater to the sewer the municipality indicated that the

only requirement is that the water discharged complies with applicable municipal

discharge standards

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 3-1

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT

31 OBJECTIVES

The main objectives of the EIA phase are to

Assess the significance of the environmental issues and impacts identified in the

scoping phase focusing on key impacts

Recommend appropriate measures to mitigate negative impacts and enhance the

benefits and include them in the draft EMP

Undertake a public participation process that provides opportunities for all

interested and affected parties (IampAPs) to be involved

32 AUTHORITY CONSULTATION

The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental

Liaison Committeersquo (ELC) which comprises representatives of various authorities

including DEDEAT the Department of Environmental Affairs (DEA) and Department

of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the

Coega Development Corporation (CDC) and Transnet National Ports Authority

(TNPA) The ELC has been specifically formed to facilitate EIA applications in the

IDZ

Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to

the clearance of vegetation should be included in the application A formal request

was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the

application and all registered stakeholders were informed of the request in writing on

19 October 2011

33 PUBLIC PARTICIPATION PROCESS CONDUCTED

On-site notices were replaced by a notification displayed on the CDCrsquos digital notice

board at the business centre in Zone 1 of the IDZ The eNotice was placed on

13 April 2011 and will remain for the full duration of the EIA process

Registered stakeholders will be notified in writing of the availability of the draft EIA

report and EMP which will also be advertised in a local newspaper Stakeholders

including state departments and the public will have forty (40) days to comment on

the draft EIA report and EMP The draft EIA report and EMP will be sent by email

where possible and made available for download on the ILISO website

(wwwilisocom)

A summary of all issues and comments received during the stakeholder consultation

process as well as of correspondence in that regard will be captured in an Issues

and Responses Report that will form an Appendix to the EIA Report

The list of registered IampAPs is included in Appendix A

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 3-2

34 LEGISLATION AND GUIDELINES CONSIDERED

The following legislation and guidelines were considered in the preparation of this

report

National Environmental Management Act Act No 107 of 1998

NEMA EIA Regulations 2010

National Environmental Management Air Quality Act Act No 39 of 2004

National Environmental Management Waste Act Act No 59 of 2008

Hazardous Substances Act Act 15 of 1993

Occupational Health and Safety Act Act 85 of 1993

Hazardous Chemical Substances Regulations 1995 (GNR 1179)

Major Hazard Installation Regulations 2001 (GNR 692)

National Water Act Act 36 of 1998

National Heritage Resources Act Act 25 of 1999

DEAT Integrated Environmental Management Information Series 1-5 and 12-15

NEMA draft Implementation Guideline

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Public Participation (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Alternatives (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Draft Guideline for Determining the Scope of Specialist

Involvement in EIA Processes (2005)

IAIA guidelines

National air quality standard for thoracic particulates Government Gazette

No 32816

Listed activities and associated minimum standards identified in terms of section

21 of the National Environmental Management Air Quality Act Act No 39 of

2004 Government Notice 248 of 2009

Minimum Requirements for the Handling Classification and Disposal of

Hazardous Waste DWAF Waste Management Series (1998)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-1

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION

The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega

IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay

to the north of the N2 highway between Port Elizabeth and Grahamstown east of the

Coega River

The co-ordinates of the corners of the site are shown in Table 1

Table 1 Coordinates of site corners for the proposed galvanizing plant

Point Longitude Latitude

A 25deg411126E 33deg45587S

B 25deg411156E 33deg45499S

C 25deg411938E 33deg45131S

D 25deg412174E 33deg45481S

E 25deg412508E 33deg45979S

F 25deg412634E 33deg451160S

G 25deg411782E 33deg451560S

H 25deg411692E 33deg451428S

J 25deg411314E 33deg45868S

Figure 4 Zone layout in the Coega IDZ

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-2

Figure 5 Site location

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-3

42 SOCIO-ECONOMIC CHARACTERISTICS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the

NMBM There are no residents within the IDZ

As far as the broader NMBM and Eastern Cape Province are concerned the

following can be noted The NMBM is located within the Eastern Cape Province the

2nd largest Province in South Africa (3rd in terms of population) characterised by a

predominantly black population with low incomes and high levels of unemployment

(CES 2010)

The NMBM has a population of just above 11 million and covers an area of

1 950 km2 It is the main urban and industrial centre of the province and Port

Elizabeth in particular which forms part of the NMBM is the commercial capital of

the Eastern Cape 52 of the NMBM population is female and 37 is below the

age of 20 these two groups are particularly affected by unemployment

43 BIOPHYSICAL CHARACTERISTICS

431 Surface and ground water

No rivers occur in Zone 6 There is however a natural attenuation pond on the

southern most part of the site which will have to be avoided

The IDZ is underlain by calcrete sand and gravel deposits that overlie low

permeability clays These clays limit the vertical infiltration of rainwater and induce a

horizontal groundwater flow towards the Coega River channel which is the most

significant surface water feature in the Coega IDZ Consequently rapid run-off takes

place following precipitation (Jacobs 2008)

Groundwater levels at Coega are generally about 3 to 5 m below surface ie just

above the contact between the permeable sands and the underlying impermeable

clays The groundwater flow direction is to the southeast following the surface water

drainage direction (Jacobs 2008)

432 Climate and atmospheric conditions

Port Elizabeth has a warm temperate climate and the temperature ranges are not

extreme Exceptionally high temperatures may be experienced during berg wind

conditions which occur frequently during autumn and winter Extreme temperatures

also occur during summer with little accompanying wind

The wind regime for the area largely reflects the synoptic scale circulation with

dominant westerly and northwesterly flow fields representing the pre-frontal

conditions and south-westerly flow fields representing the frontal conditions The

south-easterly and south-westerly wind flow (land breeze) increases during daytime

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-4

conditions with westerly and north-westerly wind flow increasing during the night (sea

breeze)

The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of

Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15

km southwest) and Port Elizabeth (~23 km southwest)

An ambient air monitoring network has been established in the Coega IDZ which

consists of three monitors Saltworks Motherwell and Amsterdamplein Although

NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative

impacts due to the proposed Galvanising Plant is PM10 A maximum daily average

PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed

SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3

was exceeded on 17 days in 2007 and 26 days in 2008

Existing sources of emissions in the vicinity of the proposed galvanizing plant include

industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other

fugitive dust sources (von Gruenewaldt 2011b)

433 Geology and soils

Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel

and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly

limestone and conglomerate

434 Terrestrial ecology

This section draws from the EIA report compiled for the Agni Steel (formerly Afro-

Asia) steel processing facility which is adjacent to the proposed site for the

galvanizing plant (Jacobs 2008)

The area consists largely of grasses succulents and scrubby bush with alien

species making up the greater part of the more dense vegetation

Zone 6 falls within the inland vegetation and is characterised by a vegetation type

referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the

Coega IDZ and has been found to have three times the level of endemism of other

vegetation communities in the Coega IDZ Bontveld therefore has a high

conservation status Two Bontveld conservation areas have been identified within the

IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)

Bontveld that will be destroyed as a result of development in the IDZ will be given

conservation status in these two areas

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-5

Figure 6 Coega IDZ Open Space Management Plan (OSMP)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-6

Certain areas in the IDZ are invaded by alien plant species The most common

invader species is rooikrans (Acacia cyclops) which presently forms large

monospecific stands in areas throughout the Coega IDZ There are several other

aliens present that pose a threat to the flora of this area including the prickly pear

(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)

Loss of vegetation and alien plant invasion due to human activity has resulted in a

reduction in the diversity of terrestrial fauna

The majority of mammals present in the Coega IDZ are small or medium-sized Of

the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed

gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of

Algoa Bay however it is not considered threatened The gerbil is common in

foredune and dune thicket habitat in the Coega region and is therefore unlikely to

occur on the proposed site

A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird

species are resident or common to the area Most diversity occurs in the thicket

although the coastal area also supports specialised avifauna Two species of tern

the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well

as the Cape gannet (Morus capensis) and the African penguin (Spheniscus

demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne

caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant

(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser

flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns

are two of the most endangered coastal species in South Africa Other bird species

of conservation concern include the Whitefronted plover (Charadrius marginatus)

African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus

bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus

ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides

paradisea) Breeding pairs of Damara terns and African black oyster catchers have

been observed in the coastal dunes of the IDZ but should not be affected by

developments that fall outside the dune areas

The Eastern Cape supports nearly a third (approximately 133 species) of the reptile

species recorded in South Africa More than half of the Eastern Capersquos endemic

reptile species occur in the Algoa Bay area giving the region a high conservation

value A total of 63 reptile species are believed to occur within the Coega IDZ The

majority of these are found in Succulent Thicket and riverine habitats Only a few

reptile species occur in the coastal dunes and estuarine habitats More than a third of

the species are described as relatively tolerant of disturbed environments provided

that migration corridors of suitable habitat are maintained to link pristine habitats

Twenty two reptiles are of special concern including five endemic species (two of

which may also be endangered) four endangered sea turtles eight species listed

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-7

with CITES one rare species and four species at the periphery of their range

Fourteen of these species of special concern are confirmed as occurring on or within

2 km of the Coega IDZ

A total of 32 amphibian species and sub-species occur in the Eastern Cape

representing almost a third of the species recorded in South Africa However none of

the species are endemic or Red Data Book species Based on previous studies in the

area it is estimated that approximately 17 amphibian species occur within the Coega

IDZ Four species are listed as peripheral but none are threatened internationally

These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog

(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and

the bubbling kassina (Kassina senegalensis)

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated

vegetation has not been extensively studied One grasshopper species Acrotylos

hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue

(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis

pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in

four localities in the Eastern Cape one of which is within the Coega IDZ The Coega

copper Aloeides clarki is endemic to this particular region of the Eastern Cape and

is currently known to occur in three localities two of which are in the Coega IDZ The

localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the

Coega IDZ and their distributions were taken into account when defining Coegarsquos

open space system and Development Framework Plan

435 Land use and topography

The land is currently undeveloped and earmarked for industrial development The

site is relatively flat ranging from an elevation of 66 masl on the northern-most

corner to 59 masl at the southern-most corner

436 Heritage and archaeological survey

Extensive studies have been undertaken in Zone 6 with respect to heritage aspects

Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a

2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond

2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is

currently being finalised

Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing

Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha

in extent and was located next to the R102 road to Motherwell Kaplan conducted

HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi

Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will

now be located in Zone 5)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-8

The various archaeological investigations reached similar observations and

conclusions Stone tools of various densities and types were found throughout the

zone The majority of the stone tools were mainly of Earlier and Middle Stone Age

and occasional Later Stone Age origins (Figure 4)

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble

gravels exposed by tracks in Zone 6 (Source Binneman 2010)

The stone tools which comprised of quartzite flakes chunks flaked pebblecobble

and cores were randomly distributed across the landscape and are in secondary

context There were no lsquoconcentrationsrsquo of tools observed which suggested any

spatial patterning or activity areas although these may be present or covered by soil

and vegetation

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 5-1

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED

The following environmental issues and potential impacts were identified in the

Scoping phase

51 AIR QUALITY

The galvanizing process generates atmospheric emissions with particulates and

hydrogen chloride representing the main pollutants of concern The plant is fitted with

air extraction as well as scrubber systems which are designed to retain the bulk of

pollutants and particles for each of the processes in such a way that less than 5 ppm

of gases and particles will be released into the atmosphere after the fume scrubber

Other sources of impact on air quality include emissions from the LNG burner as well

as emissions and dust from the transport of steel and other materials in trucks

Construction activities will also create dust and gas emissions due to the clearing of

groundcover tipping of material to storage pile levelling of area wind erosion from

storage piles vehicle and construction equipment activity and tailpipe emissions

from vehicles and construction equipment such as graders scrapers and dozers

Overall the air quality impact assessment (Gruenewaldt 2011b) found that

The predicted particulate oxides of nitrogen carbon monoxide and sulphur

dioxide concentrations are all below the National Ambient Air Quality Standards

for all averaging periods

The predicted off-site concentrations of hydrogen chloride are well below the

most stringent effect screening levels

No odour threshold exceedances for hydrogen chloride were predicted to occur

due to routine operations at the Steel Galvanising Plant The South Wales

Environmental Protection Authority stipulates that an odour unit of 20 is

acceptable for urban areas The odour unit would be lt10 directly off-site for

hydrogen chloride

Abnormal emissions can occur in exceptional circumstances Start-up will not

cause abnormal emissions as the scrubbers will be commissioned first and will be

functioning once the plant starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions would be emitted as a

building fugitive

The hourly hydrogen chloride ground level concentrations (directly offsite) were

predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based

on the emission limits as stipulated for listed activities for galvanising processes)

using a screen model which assumes worst case meteorological conditions The

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-2

health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming

abnormal emissions emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset conditions will still

be well within the health effect screening levels

Similarly the hourly particulate emissions from the building fugitives during upset

conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for

listed activities for galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly

off-site

Therefore if emissions are 5 times higher normal they will still be within health effect

screening levels and the daily PM10 NAAQS levels

In the case of a fire a cocktail of gases and particulates could be emitted and could

be over the recommended levels This situation will however be dealt with as an

emergency and normalised as quickly as is possible

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS

The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of

its heritage potential and there are no proposed protected geosites in Zone 6

Should any artefacts be discovered during construction procedures stipulated in the

draft EMP will apply

53 BIODIVERSITY AND CONSERVATION

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

In terms of terrestrial fauna the CDCrsquos open space management plan provides for

the preservation of certain corridors The destruction of certain habitats as a result of

the development will therefore not automatically result in the loss of certain species

54 WATER QUALITY

There is a natural attenuation pond on the southern most part of the site which will be

avoided

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through

spills or leaks

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-3

This risk can however be minimized if not avoided altogether The floor of the factory

will be designed as a bunded area to contain any spills and the entire process will be

contained Potential spills or leaks will therefore be contained and will not impact on

water resources Storm water is therefore considered clean water under normal

operational conditions An oil trap will be placed at the exit of the site to ensure that

no grease from the laydown area enters the stormwater system

Spills and leaks can occur during the handling or the transport of hazardous

substances Best practice guidelines will be followed to ensure that this risk is

adequately managed

Wastewater discharged to sewer will be treated to comply with municipal discharge

standards and is not expected to have an impact on the chemical characteristics of

the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be

discharged from the plant is small in relation to the total volume received at the

Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works

(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently

operated at 61 of its capacity which is approximately 80 Mℓday Thus the

0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore

not have any significant impact on the WWTW

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES

The plant will generate a relatively small amount of solid waste in the form of scrap

metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)

The scrap metal may be sold to other steel processing facilities such as Agni Steel

which will be located next to the plant or collected and disposed of with the rest of

the solid waste by a licensed service provider

As mentioned previously there will be a wastewater treatment plant on site which will

neutralise process water (012 Mlweek) in order to ensure it is of a standard

acceptable for discharge to sewer Waste in the form of sludge from the

neutralization or spent acid must be disposed of as a hazardous waste Solid waste

from the filters used for air quality control is also in this category These wastes can

usually be tested and then delisted which means that it can be placed in a general

purpose landfill

Hazardous effluent from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-

site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored

and removed on a monthly basis is limited to 10 m3

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-4

A number of substances classified as hazardous are used in the galvanizing process

(Table 2) and the transport and handling of these is subject to certain rules and

guidelines In particular the material safety data sheets (cf Appendix H) should be

referred to for inter alia hazards identification accidental release measures

handling and storage precautions exposure controlpersonal protection ecological

information and transport information The Hazardous Chemical Substances

Regulations 1995 should also be adhered to in respect of the transport and storage

of hazardous chemical substances

Table 2 Hazardous materials to be used on site

Major Input Materials

Substance

listed in the

SABS 0228

Group II

hazardous

substances

Volumes to be

stored on site at

any one time

Diesel radic 2000 litres

Liquid petroleum radic 20 000 liters

Sodium hydroxide (NaOH)

(used for degreasing) 8 radic 1000m

3

Hydrochloric acid (HCI)

(used for pickling) 8 radic 800m

3

Zinc (used for galvanising) - TBD

Trivalent chromium (CR+3

)

(used for chromating) 8 radic 10m

3

Sulphuric acid (H2SO4) (used for

treatment of waste water on site) 8 radic TBD

Ammonium Hydroxide (NH4OH) 8 radic TBD

TBD ndash To be determined

Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one

time) and is classified as a flammable substance Specification for flammable storage

facilities in accordance with the requirements of the Nelson Mandela Bay

Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for

quantities between 5000 and 20 000 liters the substance must be kept in a

flammable liquid store which complies with the requirements of a specification

obtainable from the Department Some of the requirements are

Flammable liquid and solid storage facilities are only permitted on the ground

floor

Decanting of flammable liquids and solids are not permitted within any building

Due to the fact that there are flammable materials on site a certificate may be

required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and

Emergency Services Department to confirm that facilities for flammable storage

are in accordance with their requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-5

Because of the permanent installation and high quantity of liquid petroleum on site

the Major Hazard Installation Regulations 2001 promulgated under the Occupational

Health and Safety Act No 85 of 1993 applies A written application for approval of

the installation is required to be submitted to the chief inspector Department of

Labour provincial director Department of Labour and NMBM prior to construction

In addition a risk assessment should be formulated covering all hazardous materials

together with an emergency preparedness and response plan

56 HEALTH AND SAFETY

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling instructions as well as occupational exposure limits

are indicated in the material safety data sheets of the various substances used

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as

provide site supervision including executing tests (individual test cold run and hot

run) during 3 months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the

EMP

In addition the emergency preparedness and response plan will cover the health and

safety aspects related to emergency situations

57 TRAFFIC

The volumes of traffic at the IDZ are currently relatively low and variable depending

on the different zones in the IDZ however these volumes will increase as more

developments are implemented

The construction phase of the Casa Steel development will take about 12 months

and will essentially consist of erecting a building to house the galvanizing line and

other equipment and preparing a concrete laydown area adjacent to the building

The traffic that would be generated during the construction phase can be expected to

be less than the traffic that would be generated by the Casa Steel development when

it is fully operational

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-6

In the operation phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and

from the Port of Ngqura

The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the

Casa Steel development would be off Ring Road 1 The other roads of significance

for the Casa Steel development are the N2 Neptune Road MR435 and MR450

Access to the port is given by Neptune Road Road Link NEP-03 has not yet been

built

Figure 8 Coega IDZ road network identification

(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-7

Figure 9 Coega IDZ road network

Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No

01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-8

The distribution of freight trips is fixed as the majority of trips will be made between

the Port of Ngqura and the Casa Steel site With regard to personnel trips there are

various points of origins (the surrounding residential areas) that could be used by

staff going to the Casa Steel site The distribution of personnel trips is based on

existing traffic count information and is shown in Figure 10

Figure 10 Trip distribution for freight and personnel trips

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The resultant expected Casa Steel traffic assignment is shown in Figure 11

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-9

Figure 11 Morning peak hour Casa Steel development traffic

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The traffic that is expected to be generated by the Casa Steel development is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low

and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)

Consultation has taken place with Transnet Port Authority (TPA) to establish the

impact of the galvanizing plant operations on traffic inside the port The additional

ships entering and exiting the port of Ngqura as a result of the proposed development

will have a negligible impact on port traffic and TPA indicated that it would be well

within the portrsquos capacity

58 NOISE

Noise is not foreseen to be a significant issue insofar as the noise levels inside the

plant and at the boundary of the site will not exceed the limits prescribed by the CDC

Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels

during the day and 60 decibels at night

Mitigation of noise impacts will be addressed in the design of the noise-emitting

components of the plant and their enclosures

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-10

59 SOCIO-ECONOMIC ASPECTS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of

NMBM There are no residents within the IDZ

The direct socio-economic impacts of the proposed project are thus limited to the

employment generated by the project during construction and operation Job creation

remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)

and the IDZ and Port of Ngqura are expected to become a significant catalyst to the

economic growth of the Municipality and the region with current investments at

Coega creating more jobs and stimulating the economy

In this context the proposed galvanizing plant will make a positive contribution

towards the achievement of these goals

There will be 50 to 60 employees during operation phase distributed as follows

Figure 12 Casa Steel organisation chart

Even though a large part of the inputs will be imported and the bulk of the production

output will be exported there will be some positive impacts for the economy of the

region and of South Africa in general Notably the requirements of the plant for

water electricity waste collection and disposal waste water treatment and transport

for example will create business for the various service providers and have an

indirect impact on employment and fiscal revenues as a result

From a visual impact point of view it can be anticipated that the landscape in the IDZ

will be significantly affected over time by developments related to the establishment

of the port and various industries

HEAD ( WORKS )

MGR ( COMM) MGR ( ADMNHR ) Manager marketing

MANAGER OPERATION MANAGER MANAGER MANAGER Q C

AC FIN PUR ampSTORE

PPC SH-GALV SH-tech

SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF

1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO

JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF

2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO

WORKERS WORKERS 7NOS

15 7

RAW MAT amp

DESP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 6-1

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY

A description of the nature of the impact any specific legal requirements and the

stage (constructiondecommissioning or operation) will be given Impacts are

considered to be the same during construction and decommissioning The

significance of the potential impacts will be considered before and after identified

mitigation is implemented

The following criteria will be used to evaluate significance

Nature The nature of the impact will be classified as positive or negative and

direct or indirect

Extent and location Magnitude of the impact and is classified as

Local the impacted area is only at the site ndash the actual extent of the activity

Regional the impacted area extends to the surrounding immediate and

neighbouring properties

National the impact can be considered to be of national importance

Duration This measures the lifetime of the impact and is classified as

o Short term the impact will be for 0 ndash 3 years or only last for the period of

construction

o Medium term three to ten years

o Long term longer than 10 years or the impact will continue for the entire

operational lifetime of the project

o Permanent this applies to the impact that will remain after the operational

lifetime of the project

Intensity This is the degree to which the project affects or changes the

environment and is classified as

o Low the change is slight and often not noticeable and the natural functioning

of the environment is not affected

o Medium The environment is remarkably altered but still functions in a

modified way

o High Functioning of the affected environment is disturbed and can cease

Probability This is the likelihood or the chances that the impact will occur and

is classified as

o Low during the normal operation of the project no impacts are expected

o Medium the impact is likely to occur if extra care is not taken to mitigate

them

o High the environment will be affected irrespectively in some cases such

impact can be reduced

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 6-2

Confidence This is the level knowledgeinformation the environmental impact

practitioner or a specialist had in hisher judgement and is rated as

o Low the judgement is based on intuition and not on knowledge or

information

o Medium common sense and general knowledge informs the decision

o High Scientific and or proven information has been used to give such a

judgment

Significance Based on the above criteria the significance of issues will be

determined This is the importance of the impact in terms of physical extent and

time scale and is rated as

o Low the impacts are less important

o Medium the impacts are important and require attention mitigation is

required to reduce the negative impacts

o High the impacts are of great importance Mitigation is therefore crucial

Cumulative Impacts The possible cumulative impacts will also be considered

Mitigation Mitigation for significant issues is incorporated into the EMP for

construction

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 7-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS

71 IMPACTS DURING CONSTRUCTION

711 Air quality

Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris

handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine

particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural

operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks

and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)

Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Fugitive particulate emissions (dust)

related to construction activities Regional

Short

term Medium High High Medium Regional

Short

term Low High High Low

Construction vehicle gas emissions Regional Short

term Medium High High Medium Regional

Short

term Low High High Low

712 Heritage and archaeological resources

Naturedescription of impact excavation activities may impact on unidentified heritage resources

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-2

Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based

on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments

Heritage and archaeological

resources Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on unidentified heritage

resources Local

Short

term

Medium -

high Low High Low

713 Biodiversity and conservation

Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation

importance and cause soil contamination

Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species

Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan

and has compiled a list of protected species to be rescued (see draft EMP)

Biodiversity and conservation Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Loss of fauna and flora Local Perma

nent

Medium -

high High High High Local

Permanen

t Medium High High Medium

Soil contamination Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-3

714 Water related impacts

Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater

runoff spills and leaks Soil erosion

Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of

spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste

disposal Stormwater quality monitoring (see draft EMP)

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Soil erosion Local Short

term Medium Medium High Medium Local

Short

term Medium Low High Low

715 Waste management

Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed

Commentmitigation see draft EMP and waste management plan

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-4

Waste management Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Local

Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

716 Health and safety

Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Short

term

Medium -

high

Medium -

high High High Local

Short

term

Medium -

high Low High Low

717 Traffic

Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and

construction workers from surrounding areas and transport of equipment from the port

Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low

Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and

accurate estimates of quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-5

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Increased traffic on N2 and within the

IDZ Regional

Short

term Low High High Low

718 Noise

Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Short

term

Medium-

high High High Medium Local

Short

term Medium High High Medium

719 Socio-economic

Naturedescription of impact temporary employment will be created during the construction phase

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-6

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Temporary employment Regional Short

term Medium High High Medium

72 IMPACTS DURING OPERATION

721 Air quality

NatureDescription of impact gas and particulate emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning

Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local

sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and

veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute

to background fine particulate concentrations (von Gruenewaldt 2011b)

Assumptions and limitations Potential release of CR6+

As no emission factors are available for trivalent chromium processing the

potential impacts due to these activities could not be quantified

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Dust emitted from traffic on paved roads Regional Long Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-7

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

term

Hydrogen chloride emissions from

pickling process Local

Long

term Low High High Low

Particulate emissions (smoke) from

galvanizing process (due to the

volatilization of flux)

Local Long

term Low High High Low

Particulate oxides of nitrogen carbon

monoxide and sulphur dioxide emissions

from LNG burner

Local Long

term Low High High Low

Nuisance related to odour Local Long

term Low Low High Low

Abnormally high hydrogen chloride and

particulate emissions due to scrubber

malfunction

Local Short

term Medium Low High Medium

Gases (eg SOx NOx CO etc) and

smoke emitted in case of a fire Local

Short

term High Low High Medium

722 Water quality

NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks

Commentmitigation see draft EMP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-8

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Stormwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

723 Waste management and hazardous substances

NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous

waste both can affect environmental quality and human health

Commentmitigation see draft EMP and waste management plan

Waste management and hazardous

substances Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Regional

Long

term High

Medium -

high High High Regional Long term High Low High Low

Soilwaterair pollution due to improper

transport storage and handling of

hazardous substances

Regional Long

term High

Medium -

high High High Regional Long term High Low High Low

Health hazard Local Long

term High

Medium -

high High High Local Long term High Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-9

724 Health and safety

Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Long

term

Medium-

high

Medium-

high High High Local Long term

Medium-

high Low High Low

725 Traffic

Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on

the road network

Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak

hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road

network within Zone 6 of the IDZ (Iliso 2011)

Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)

Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of

quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-10

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on traffic and capacity of the N2 Regional Long

term Low High High Low

Impact on traffic and capacity of ring

road 1 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR435 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR450 Local

Long

term Low High High Low

Impact on traffic and capacity of

Neptune road Local

Long

term Low High High Low

726 Noise

Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Long

term Medium High High Medium Local Long term Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-11

727 Socio-economic

Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate

revenue for the municipality and the region as a whole

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Employment and economic growth Regional Short

term Medium High High Medium

73 COMPARATIVE ASSESSMENT OF IMPACTS

During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as

low during operation after mitigation

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 8-1

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

As a tenant operating in the IDZ Casa Steel will be required to comply with all

current and future CDC requirements as well as with the relevant conditions of

permits licences issued to CDC (eg Integrated Stormwater Masterplan for the

eastern side of the Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)

In particular the CDC has its own requirements regarding the monitoring of certain

aspects of the project such as the quality of the effluent and the noise levels These

have been incorporated into the EMP

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 9-1

9 ENVIRONMENTAL IMPACT STATEMENT

All predicted negative impacts can be mitigated to a low significance The only

exceptions are biodiversity as the construction of the plant will result in the

destruction of habitat and loss of fauna and flora and noise impacts inherent to

construction activities Mitigation measures have been included in the EMP for these

impacts and they have a medium significance post-mitigation

Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium to

long term similar impacts are likely to occur due to ongoing developments in the IDZ

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 10-1

10 CONCLUSION AND RECOMMENDATIONS

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as

other infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified

and assessed No fatal flaws have been identified

It is recommended that the project be approved subject to the conditions listed in

chapter 9 and adherence to the EMP requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 11-1

11 REFERENCES

Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ

Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants

Bennie JS (2010) The historical component (built environment) of the Heritage

Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port

Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report

compiled for Eastern Cape Heritage Consultants

Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater

Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay

Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage

Consultants

BKS (2006) Coega Industrial Development Zone Transport Study Volume 3

Demand Modelling Report Final Draft

Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I

Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6

Report compiled for SRK Consulting

Coastal amp Environmental Services (2010) Environmental Impact Assessment for the

Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone

Volume 3 Environmental Impact Assessment Report CES Grahamstown

Coega Development Corporation (2008) Industry Waste Management Plan -

Strategic Master Plan Report

Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants

Report No CDCSHE 03 8122

Department of Water Affairs and Forestry (1998) Waste Management Series

ldquoMinimum Requirements For The Handling Classification And Disposal Of

Hazardous Wasterdquo Second Edition

Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising

Plant in the Coega Industrial Development Zone

Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the

Coega Industrial Development Zone (IDZ) Specialist Water Study

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 11-2

Jacobs E (2008) Final Environmental Impact Report and Draft Environmental

Management Plan Proposed Steel Recycling and Processing Facility within the

Coega IDZ Report compiled for SRK Consulting

Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY

Galvanising Plant in the Coega Industrial Development Zone Waste Management

and Hazardous Substances Report compiled for ILISO Consulting

RSA National air quality standard for thoracic particulates (PM10) SA standards

(Government Gazette No 32816)

von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed

Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape

Report compiled for ILISO Consulting

von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel

Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report

compiled for ILISO Consulting

Additional sources

Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed

Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared

for Coastal Environmental Services

Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed

Kalagadi Manganese smelter in the Coega Industrial Development Zone Port

Elizabeth Eastern Cape Province Report prepared for Coastal Environmental

Services

Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia

steel recycling facility at the Coega Industrial Development Area Port Elizabeth

Prepared for SRK Consulting Port Elizabeth

APPENDIX A

LIST OF INTERESTED AND

AFFECTED PARTIES

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

DEDEARegional Manager

and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza

DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza

DEA Ocean and

CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza

DEA Ocean and

Coast

Oceanographer land-

based sources of

marine pollution

Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza

DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza

CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza

CDCEnvironmental

Project

Manager

Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza

TNPAPort of Ngqura

Environmental

Manager

Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet

NMBMEnvironmental

ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza

NMBMEnvironmental

ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza

DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza

DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza

WESSASenior Conservation

Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza

Zwartkops

ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700

hughlauegmailcom

zwartkopstrustiafricacom

SANParksNational Marine

CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza

Department Of

LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza

NMBM Air Quality

Division

Assistant

DirectorAir

Pollution and Noise

Templeton Titima 079 490 0574 Ttitimamandelametrogovza

NMBM Air Quality

DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza

NUMSARegional

RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

Department of

HealthNadiema

van der

Bergh083 378 2103

nadiemavanderberghimpiloecprovgov

za

DWA Chief Services

Officer

Joseph Jacobs 041 586 4884 jjacobsdwafgovza

EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza

NUMSecretary of union

officesZandile Xhentsa 043 743 6597 zxhentsanumorgza

DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza

Dynamic

CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom

EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza

Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza

UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom

lprincezago2uticom

Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza

Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza

Absa Mr Johann Steyn 082 3775820 johannstabsacoza

Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza

PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza

Universal

EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza

Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza

GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom

Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza

NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom

DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza

DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza

TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet

DWA Mr Landile Jack JackLdwagovza

DWA Ms Lizna Fourie FourieL4dwagovza

APPENDIX B

NOTICE OF ATMOSPHERIC

EMISSIONS LICENCE APPLICATION

AND ADVERTISEMENT

APPENDIX C

NOTICE OF COMMENT PERIOD FOR

DRAFT SCOPING REPORT

APPENDIX D

SUMMARY OF ISSUES RAISED AND

RESPONSES THERETO

April 2012

1

PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL

DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))

IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt

AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt

This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses

provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process

conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the

Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

2

IssueCommentQuestion Date

received Origin Response

1 Please provide more information with respect to the potential

dangers including the toxicity of the proposed project

07032011

By email

Wayne Poulton

(Bosun Brick

tenant at the

IDZ)

An Environmental Impact Assessment (EIA) was undertaken

which assessed the potential toxicity of the emissions and

effluent Mitigation measures were also recommended in the draft

Environmental Management Programme (EMP) to avoid

minimise or compensate any significant impacts The Draft

Environmental Impact Report and draft EMP were made available

to stakeholders for comment in March 2012

2 Do you have a Background Information Document (BID) or

similar that provides more information on the project

27032011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The BID was sent to all registered IampAPs on 4 May 2011

3 The RoD issued to the CDC on 632007 for the change in

land use for the remaining area of the Coega IDZ includes a

number of requirements with respect to

atmospheric emissions that should be considered in the

Atmospheric Emissions Licence (AEL) application such as

prohibiting and monitoring where possible visible emission

plumes to the atmosphere In particular the

recommendations on pp87-91 of the final revised Scoping

Report dated Nov 2006 must be implemented (clause 421)

04042011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

We have obtained copies of the documents referred to and ensure

that these requirements were taken into account in the

environmental assessment and AEL application

4 If the Port of Ngqura is used for import and export the scope

of the traffic impact assessment (TIA) should also include the

port

10052011

By email

Elliot

Motsoahole

(TNPA Port of

Ngqura)

The scope of the TIA was extended to include port related traffic

The TNPA at the Port of Ngqura was consulted and does not

have any objection to the project TNPA has indicated that the

development would require a minimum number of vessels per

year which would have minimal impact on the Port operations

However due notice would have to be given to the Port of Ngqura

before a vessel is scheduled to arrive so that the vessel can be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

3

IssueCommentQuestion Date

received Origin Response

accommodated at an available berth

5 Concerns with respect to potential stormwater pollution

draining into the Coega catchment and the port of Ngqura

The port needs to be dredged and heavy metals present a

risk in that regard

16052011

By

telephone

Andrew Lucas

(Department of

Water Affairs)

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination by effluent waste or

hazardousdangerous substances is very low

Thus no metals oils or other contaminants are expected to be

present in the stormwater

However stormwater pollution can occur in exceptional

circumstances such as accidents and emergencies The

emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

6 All steel sheets bathing unit must be under roof

7 The sludge out of the decreasing bath will be high in Na and

pH Therefore handling and disposal must be clarified up front

in this project

8 Per se the wastewater from decreasing bath will have high

ph and the component from the pickling unit will have low ph

Then it may be assumed that both streams will neutralize

each other Please then clarify proposed sewer discharge

with Nelson Mandela Bay Municipality up-front for acceptance

of influent as per the documented proposal

9 Pickling may result in dissolved metals How does your team

expect to deal with this As it is planned for discharge into

24052011

By email

Landile Jack

(Department of

Water Affairs)

All bathing units will be under roof

Effluent from the degreasing and pickling baths will be discharged

to the wastewater treatment plant The respectively alkaline and

acidic effluents will mix and neutralise each other in the

wastewater treatment plant Calcium or gypsum will be added if

required to complete the neutralisation process Effluent from the

treatment plant will be discharged to sewer Contact has been

made with the relevant officials and the Municipalityrsquos

requirements have been obtained The effluent discharged to

sewer will notably comply with the applicable discharge standards

Traces of metals (eg iron) may be present but will not exceed

prescribed thresholds The necessary authorisation will be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

4

IssueCommentQuestion Date

received Origin Response

sewer Clarity and acceptance needs to be agreed with

Nelson Mandela Bay Municipality Who owns the sewer

10 Quenching unit will results to Zinc particles How will this

affect sewer discharge This again must be dealt with within

the negotiations with the Municipality

11 Once all has been agreed with the Municipality and at the

same time due negotiations must be done with hazardous

waste courier and disposal facility to accept the hazardous

waste identified in all production lines

12 Of note is the low volume of the proposed WWTW facility ie

250 cubmweek And the no discharge of the quenching

water ie over-flow and cooling only Hence Zinc particles

generation

obtained from the municipality

The sludge from the treatment plant will be collected by a licensed

service provider and disposed of at a permitted site

The quenching bath will be periodically emptied (every 6 months)

and the water discharged will go to the water treatment plant Zinc

particles will settle in the sludge which will be disposed of at a

permitted site

Contact has been made with EnviroServ who manages the

Aloes II HH waste site regarding collection and disposal of

hazardous waste (See waste management report)

13 Investigate the potential effects of toxicity andor influence of

emissions waste and hazardous substances both in

terrestrial and marine fauna

14 With regards to water usage where is the plant going to

extract its waters used in galvanization andor waste

management process ie rainfall rivers or even from the

sea) and which avenues would be more environmental

friendly and effective

31052011

By email

A Bewana

(SANPARKS)

Emissions waste and hazardous substances are not expected to

affect terrestrial or marine ecosystems The air quality study

concluded that atmospheric emissions would not be harmful to

human health and by extension terrestrial fauna There are no

standards for air quality for defining faunal impacts therefore by

ensuring that standards for humans are complied with the impact

on fauna is deemed to be acceptable In this case the impact of

emissions on terrestrial and marine fauna are thus not significant

Solid and liquid wastes both general and hazardous as well as

hazardous substances will be stored handled and disposed of

appropriately to as not to cause harm to terrestrial or marine

fauna

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

5

IssueCommentQuestion Date

received Origin Response

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination and hence land-based

marine pollution by effluent waste or hazardousdangerous

substances is very low

The risk of emissions waste and hazardous substances to

terrestrial and marine fauna is thus very low

However pollution of terrestrial and marine ecosystems can occur

in exceptional circumstances such as accidents and emergencies

The emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

The CDC has an agreement with the NMBM to supply potable

water to the Coega IDZ Currently the infrastructure to supply

return effluent (RE) to the IDZ is not in place therefore Casa Steel

will be supplied with potable water up until such time as the

following 2 options of RE are available

1) Upgrading of the existing Fishwater Flats waste water

treatment works (between IDZ amp PE) including RE plant

and infrastructure to pipe RE to the IDZ (EIA for the

upgrade is underway)

2) Construction of a new waste water treatment works

including RE plant in Zone 9 of the Coega IDZ

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option should be investigated further between Agni and Casa The

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

6

IssueCommentQuestion Date

received Origin Response

CDC can facilitate discussions between the 2 investors

Compliance with CDC Permits amp Requirements

15 It should be made clear that tenants will be required to

comply with CDC requirements and the relevant conditions of

permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water

Licence for its Storm Water Systems on the

East Side of the Coega River that tenants will

need to take cognizance of The contents of the

ldquoIntegrated Stormwater Masterplan for the

eastern side of the Coega IDZ Oct 2010rdquo

especially the Table of best practice p53

onwards may need to be taken cognizance of

o CDC is developing an Operations

Environmental Management Plan that will place

certain obligations on tenants

16 Environmental audits and data collected during monitoring

(eg stack emissions stormwater) will need to be shared with

CDC

Air Emissions

17 Presumably permanent in stack monitoring will be required in

terms of AEL permit requirements

18 Abnormal operating conditions resulting in air emissions ndash I

could find nothing in the EIR to indicate under what

circumstances these could occur (eg start-up) potential

frequency and duration and the impact on ambient air quality

ndash these events usually result in the most problems wrt air

emissions

09042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

15 Compliance with the CDCrsquos Permits amp Requirements has

been included explicitly as a requirement in the EIR (p8-1) and

EMP (pp18 and 25) in the following terms

ldquoAs a tenant operating in the IDZ Casa Steel will be required to

comply with all current and future CDC requirements as well as

with the relevant conditions of permits licences issued to CDC

(eg Integrated Stormwater Masterplan for the eastern side of the

Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)rdquo

16 The need to communicate with the CDC on monitoring and

auditing activities was emphasised in Chapter 8 of the EMP The

following paragraphs were added

ldquoDuring construction the environmental officer will be responsible

for monitoring compliance with the EMP and authorisation

conditions and keeping records as required in the EMP andor

authorisation conditions

The ECO will conduct site inspections every two weeks audit the

records kept by the environmental officer and submit an

environmental compliance report every two months to the

authorities and the CDC (via the Environmental Monitoring

Committeersquos ECO)

During operation the health and safety officer will monitor

compliance with the EMP and the conditions of the Environmental

Authorisation Data collected during monitoring activities and any

environmental audits conducted will be shared with authorities

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

7

IssueCommentQuestion Date

received Origin Response

Water

19 Large volumes of (2000 m3mth) of water are required of

which only 400m3 needs to be potable The NMBM return

effluent system will provide non-potable water once it is

constructed What other water recycling initiatives can be

utilized to reduce potable water requirements (the ISWMP for

the eastern side of the Coega IDZ has some best practice

guidelines collecting rainwater from the roof etc)

General

20 There is no mention of how the CDC Architectural Guidelines

will be incorporated into the development (eg to prevent a

stark uniform warehouse type development)

21 Does NMBM have adequate fire services to cover this

development Apart from the large petroleum store are there

any other large fire hazards

22 Reports from the tenantrsquos ECO during construction and from

the SHE Officer during operations should be channeled to the

Coega Environmental Monitoring Committee This can be

directly or preferably via the EMCrsquos ECO (this will be while

the EMC and ECO are in place) A precedent has been set

for this in the Environmental Authorisations for Agni-Steel and

Kalagadi Manganese Smelter

23 All mitigation actions emanating from the EIR should be

summarized (preferably in a table) If compliance with them is

to be part of the Environmental Authorization from DEDEAT

then they (or the ones that DEDEAT deems to be applicable)

and the CDC (via the Environmental Monitoring Committeersquos

ECO)

The ECO (during construction) and the health and safety officer

(during operation) will report to the Coega Environmental

Monitoring Committee (EMC) via the EMCrsquos ECO (this will be

while the EMC and ECO are in place)rdquo

17 The draft EMP recommends regular monitoring of emissions

from the scrubbers and from the chromating process Additional

emissions monitoring requirements will be confirmed once the

AEL is issued Mention has been made in the EMP (pp11 and 19)

that all AEL conditions including monitoring and reporting

requirements should be adhered to

18 Abnormal emissions can occur in exceptional circumstances

Start-up will not cause abnormal emissions as the scrubbers

will be commissioned first and will be functioning once the plant

starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions

would be emitted as a building fugitive

The hourly hydrogen chloride ground level concentrations

(directly offsite) were predicted to be 239 microgmsup3 (based on the

emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits

as stipulated for listed activities for galvanising processes) using a

screen model which assumes worst case meteorological

conditions The health effect screening level for hourly HCl

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

8

IssueCommentQuestion Date

received Origin Response

should be attached to the EA as an Appendix (otherwise no

one knows about them or takes cognizance of them)

concentrations is 2100 microgmsup3 Assuming abnormal emissions

emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset

conditions will still be well within the health effect screening

levels

Similarly the hourly particulate emissions from the building

fugitives during upset conditions would amount to 293 microgmsup3

(based on the emission limits as stipulated for listed activities for

galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1

January 2015) directly off-site

Therefore if emissions are 5 times higher normal they will still be

within health effect screening levels and the daily PM10 NAAQS

levels

In the case of a fire a cocktail of gases and particulates could be

emitted and could be over the recommended levels This

situation will however be dealt with as an emergency and

normalised as quickly as is possible

The above has been added to the impact identificationdescription

and assessment sections of the EIR

19 The CDC has an agreement with the NMBM to supply

potable water to the Coega IDZ Currently the infrastructure to

supply return effluent to the IDZ is not in place therefore Casa

Steel will be supplied with potable water up until such time as the

infrastructure is in place

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

9

IssueCommentQuestion Date

received Origin Response

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option will be investigated further between Agni and Casa The

CDC has come forward to facilitate discussions between the two

investors

Other water recycling initiatives such as rainwater harvesting

have been considered but are not practical

20 The CDCrsquos Architectural and Landscape Design guidelines

contain requirements pertaining to such aspects as the height

orientation and mass and form of buildings as well as guidelines

for landscaping and signage in order to ensure an attractive

development and achieve an architectural integrity within the

Coega IDZ The plans for the proposed galvanizing plant will be

submitted to the Design Review Committee for approval as

required by the CDC

21 Casa Steel will be required to install fire hydrants according

to the NMBMrsquos standardsrequirements The CDC will provide

potable water (up until such time as return effluent is available)

and a connection to the boundary of the site which will be

connected to the fire hydrants The installation of the fire hydrants

will require approval by the Metrorsquos Fire Chief as was done for

Agni-Steel one of the investors in Zone 6

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

10

IssueCommentQuestion Date

received Origin Response

The Coega IDZ falls within the NMBM and therefore the rates and

taxes paid by the CDC covers the fire services for which the Metro

is responsible Currently the Metro has sufficient capacity to

provide fire services to the tenants within the IDZ This was

confirmed in discussion with the CDCrsquos Infrastructure

Development Unit It is however unknown at which point the

Metrorsquos Disaster Management Plan would not be able to

accommodate servicing tenants in the IDZ

The LNG burner is the only major fire hazard on the plant

22 See response to item 16 above

23 Key mitigation and management measures emanating from

the EIR were recapitulated in Chapter 9 of the EIR to form part of

the conditions attached to the Environmental Authorization from

DEDEAT All mitigation measures recommended as a result of the

impact assessment are presented in a table in the draft EMP

which is appended to the EIR (Appendix J)

24 Hydrogen chloride is one of the main emissions There are no

ambient air quality guidelines for HCl and the EIR says

concentrations will be well within health parameters

However the main problem with HCl is its corrosive effect -

there is absolutely no mention of this in the draft EIR nor air

specialist report

There needs to be some sort of comment assessment as to

whether HCl emissions are likely to impact on for example

the adjacent Agni-Steel Plant wrt corrosion - their factory

structure will be made of steel

11042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The atmospheric corrosion of metals is a complex process with

both the extent of deterioration and the mechanisms varying

considerably depending on the metal Depending on the way

pollutants are transported from the atmosphere to the corroding

surface two types of deposition processes are recognized in

atmospheric corrosion ndash dry deposition and wet deposition Wet

deposition refers to precipitation whereas dry deposition refers to

the remaining processes including gas phase deposition and

particle deposition The most important pollutants acting as

corrosive agents are sulphur and nitrogen compounds including

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

11

IssueCommentQuestion Date

received Origin Response

The EIR specialist rpt suggests monitoring HCl at ground

level on the property boundary and this is supported in case

there are complaints from neighbours

secondary pollutants and particulates Pollutants can contribute to

corrosivity individually however there may be a synergistic effect

when more than one of these pollutants is present in the

environment being affected In the field of atmospheric corrosion

sulphur dioxide is the single most investigated gaseous pollutant

and the quantification of the direct contribution of sulphur dioxide

to the corrosion process of metallic materials is comparatively well

understood (Tidblad amp Kucera 1998)

Very little work has reported on the effect of HCl on the

degradation of materials in the environment with no local dose-

response thresholds developed for corrosion occurring due to HCl

exposures This is probably because HCl which is present

outdoors in markedly reduced concentrations when compared

with SO2 has not been considered to contribute to significant

degradation of materials (Syed 2006) For this reason the

incremental corrosion due to HCl from the Coega Galvanising

Plant cannot be quantified

25 It is unacceptable for ILISO to be using CDC maps (see

figure 9 ndash pg5-6) without these maps being referenced

accordingly particularly when it appears that a CDC map has

been used and then overlaid with features by an unknown

author (ie CASA steel site Port (where the boundaries

depicted are incorrect) and a North legend which is out of

keeping with the overall cartographic intent of the original

work

26 Figure 10 is not referenced appropriately and I believe that I

commented previously in respect to references to roads not

12042012

By email

Graham Taylor

(Spatial

Development

Manager -

Infrastructure

Development

CDC)

This has been rectified in the final version of the report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

12

IssueCommentQuestion Date

received Origin Response

yet built As a result Figure 10 is confusing and clarity needs

to be provided in terms of referencing In addition the Port

shape is irregular and similar to the comment above

27 I acknowledge the emergency preparedness and response

plan but please confirm that this includes pro-active routine

monitoring of storm water leaving your premises to verify that

your assumptions of clean storm water are correct

13042012

By post

Andrew Lucas

(Director

WRampU

Department of

Water Affairs)

Pro-active routine monitoring of stormwater leaving the premises

will be undertaken This has been explicitly emphasised in

chapter 8 of the draft EMP

28 Will portablechemical toilets be used during construction

29 What provisions have been made for storm water drainage

during construction

18042012

By

telephone

Department of

Water Affairs

Port Elizabeth

Chemical toilets will be used during construction

The Casa Steel site will be located at the corner of two roads

drainage of stormwater from the site will take place through the

roadsrsquo drainage system

From Lea September [mailtoleailisocom]

Sent 11 March 2011 0935 AM

To Wayne Poulton

Cc Terry Baker

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Wayne

An Environmental Impact Assessment (EIA) will be undertaken for this project during the

next 10 to 12 months

We foresee that some of the key environmental impacts of the project will be in terms of air

quality water quality waste and hazardous substances

At this stage I am not able to give you any details regarding the potential toxicity of the

emissions andor effluent However specialist studies will be conducted as part of the EIA

that will determine the key impacts of the project Mitigation measures will also be identified

to avoid minimise or compensate any significant impacts

You are registered on the stakeholder database and you will be kept informed of progress in

the EIA process you will notably get the opportunity to access the reports produced and

provide any feedback on them

Please feel free to contact me should you need any further information

Best regards

Lea September

From Wayne Poulton [mailtowaynepbosuncoza]

Sent 07 March 2011 1257 PM

To Lea September

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

Please can you provide me with some more information as to the potential dangers including

the toxicity of this

Kind regards

Wayne

From Lea September [mailtoleailisocom]

Sent 04 March 2011 1123

To Lea September

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 March 2011 0745 AM

To Paul Martin

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 05 April 2011 0847 AM

To Paul Martin

Cc Terry Baker Renee von Gruenewaldt

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Thank you Paul for this information

I have downloaded a copy of the RoD and Scoping report you referred to and will make sure

these requirements are taken into account in the environmental assessment

Best regards

Lea September

From Paul Martin [mailtopmartinaxxesscoza]

Sent 04 April 2011 0955 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Further to my comments on 27311

Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in

the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega

IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised

scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions

including prohibiting and monitoring where possible visible emission plumes to the atmosphere

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Paul Martin

Sent Monday March 28 2011 745 AM

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 10 May 2011 0327 PM

To ElliotMotsoaholetransnetnet

Cc Terry Baker

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Mr Motsoahole

Thank you for your input on this issue

The Port of Ngqura will indeed be used for import and export At the moment the scope of

the traffic impact assessment only covers road traffic I have however relayed the matter to

our traffic specialist and we will consider this issue in the finalization of the Scoping Report I

will keep you informed of any developments in that regard

I trust this is acceptable to you

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]

Sent 10 May 2011 0855 AM

To Lea September

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

It has been noted that Casa Steel will source steel coils from various markets internationally and

in South Africa and the bulk of the plantrsquos production output will be exported to African countries

However there is no mention of logistic requirements

Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will

be used the scope of traffic impact assessment should also include the port

Regards

From Lea September [mailtoleailisocom]

Sent 04 May 2011 0747 AM

To Lea September

Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

Please find attached a letter announcing the EIA process underway for the proposed 80 000

tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as

a Background Information Document (BID) outlining the details of the project

Please contact me should you require any further information on this project

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

Elliot Motsoahole

Manager - Environment

Transnet National Ports Authority

Port of Nqqura

Port Control Building Klub Road Port Elizabeth 6212

PO Box 612054 Bluewater Bay 6212

+27 41 507 8450

+27 86 674 7729

Cell +27 83 542 5619

E-mail Elliotmotsoaholetransnetnet

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

DISCLAIMER The information contained in this communication is subject to copyright and

intended only for the use of leailisocom Unauthorised use disclosure or copying is

strictly prohibited Should a virus infection occur as a result of this communication the sender

will not be liable If you have received this communication in error please notify

elliotmotsoaholetransnetnet

From Lea September [mailtoleailisocom]

Sent 25 May 2011 1147 AM

To Jack Landile (ELS)

Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi

Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Landile

Thank you for your input

Contact has been made with the relevant Municipal Directorate and we will follow up with

them to obtain clarifications on all these issues

I have added both Lizna and yourself on the database and will keep you updated on

progress on this project

Best regards

Lea September

From Jack Landile (ELS) [mailtoJackLdwagovza]

Sent 24 May 2011 0524 PM

To Fourie Lizna (ELS)

Cc Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Hi Lizna

I missed you on this sorry

I linked Pieter twice Instead

Regards

Landile

From Jack Landile (ELS)

Sent 24 May 2011 0445 PM

To leailisocom

Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Lea

The e-mail you sent to Mr Kooverji dated 19 May 2011 refer

Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are

All steel sheets bathing unit must be under roof

The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project

Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal

Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer

Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality

Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines

Of note is the low volume of the proposed WWTW facility ie 250 cubmweek

And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles

generation

Regards

Landile

From Lea September [mailtoleailisocom]

Sent 19 May 2011 0947 AM

To Lea September

Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Stakeholder

Please find attached the remaining appendices to the draft Scoping report for the proposed

80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 June 2011 0411 PM

To Aphiwe Bewana

Subject RE Proposed 80 000 TPY Galvanizing plant in Coega

Dear Mr Bewana

Thank you for your input and apologies for the late reply

We have taken note of your comments and are will be taking them forward in the EIA phase

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Aphiwe Bewana [mailtoaphiwebewanagmailcom]

Sent 31 May 2011 1205 PM

To Lea September

Subject Re Proposed 80 000 TPY Galvanizing plant in Coega

Comment

Re Proposed 80 000 TPY Galvanizing plant in Coega

As SANParks we would like the EIA phase to investigate the potential effects of toxicity

andor influence of emissions waste and hazardous substances both in terrestrial and

marine fauna In the draft scoping report reference has been made with regards to the

terrestrial fauna but there is no attention to potential effects to marine fauna

Equally with regards to water usage where is the plant going to extract its waters used in

galvanization andor waste management process ie rainfall rivers or even from the sea)

and which avenues would be more environmental friendly and effective

Regards

Aphiwe Bewana

Marine Planner

South African National Parks

POBox 76693

NMMU

Port Elizabeth

6031

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 06 July 2011 1031 AM

To Lea September

Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Hi Lea

Irsquove reviewed the Final Scoping Report Herewith a few comments

1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the

Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a

revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the

NMBLP Please include only those in the IDZ as part of your IAP list

Regards

Andrea

From Lea September [mailtoleailisocom]

Sent Wednesday July 06 2011 859 AM

To Lea Septemberrsquo

Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Dear Stakeholder

The final scoping report for the above-mentioned project (attached) is available for comment

until 27 July 2011

The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic

commentaryrdquo tab

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 09 April 2012 1159 AM

To Lea September

Subject Comments on Galvanising Plant EIR Coega IDZ

Lea

Attached are my comments on the Draft EIR for the Coega IDZ galvanising

plant

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

Email attachment

COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ

Dr Paul Martin PO Box 61029

Bluewater Bay 6212 Tel 041 4665698

Email pmartinaxxesscoza

Compliance with CDC Permits amp Requirements

It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of

o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants

Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC

Air Emissions

Presumably permanent in stack monitoring will be required in terms of AEL permit requirements

Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions

Water

Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)

General

There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)

Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards

Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter

All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 11 April 2012 1245 PM

To Lea September

Subject Fw Comments on Galvanising Plant EIR Coega IDZ

Lea

One other comment on that I have on the Galvanising Plant Draft EIR

Hydrogen chloride is one of the main emissions There are no ambient air

quality guidelines for HCl and the EIR says concentrations will be well

within health parameters

However the main problem with HCl is its corrosive effect - there is

absolutely no mention of this in the draft EIR nor air specialist report

There needs to be some sort of comment assessment as to whether HCl

emissions are likely to impact on for example the adjacent Agni-Steel

Plant wrt corrosion - their factory structure will be made of steel

The EIR specialist rpt suggests monitoring HCl at ground level on the

property boundary and this is supported in case there are complaints from

neighbours

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Paul Martin ltpmartinaxxesscozagt

To Lea September ltleailisocomgt

Sent Monday April 09 2012 1158 AM

Subject Comments on Galvanising Plant EIR Coega IDZ

gt Lea

gt

gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising

gt plant

gt

gt

gt Dr Paul Martin

gt PO Box 61029

gt Bluewater Bay 6212

gt Tel 041 4665698

gt Cell 0732524111

gt email pmartinaxxesscoza

gt

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 12 April 2012 1139 AM

To Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Hi Lea

Hope yoursquore keeping well

I have requested comments from my colleagues and the CDC Casa team on the Draft EIR

Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report

Regards

Andrea

From Graham Taylor

Sent Thursday April 12 2012 838 AM

To Andrea Von Holdt Firhana Sam

Cc Johan Fourie Maria van Zyl Melikhaya Sihawu

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Andrea Firhana

Firhana if you could please ensure that the co-ordinates provided in the EIR correspond

with our records (pages 4-1 amp 4-2)

My comments are as follows

It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work

Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above

Regards

Graham Taylor

Spatial Development Manager - Infrastructure Development

Mobile 0832283055

Office 0414030454

Facsimile 0865185033

Email GrahamTaylorcoegacoza

Website wwwcoegacom

right PLACE | right TIME | right CHOICE

This email and all contents are subject to the following disclaimer

httpwwwcoegacomemaildisclaimerhtml

From Lea September [mailtoleailisocom]

Sent 04 May 2012 0411 PM

To Andrea Von Holdt

Cc Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Dear Andrea

We have taken note of the comments from the GIS Unit These issues have been rectified in

the final version of the EIR

Please can you forward to the relevant persons at the GIS Unit

Thank you

Best regards

Lea September

APPENDIX E

BACKGROUND INFORMATION

DOCUMENT

APPENDIX F

AIR QUALITY IMPACT ASSESSMENT

APPENDIX G

TRAFFIC IMPACT ASSESSMENT

APPENDIX H

WASTE MANAGEMENT AND HAZARDOUS

SUBSTANCES SPECIALIST STUDY

APPENDIX I

WATER QUALITY SPECIALIST STUDY

APPENDIX J

ENVIRONMENTAL MANAGEMENT

PROGRAMME

Page 10: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 viii

It is recommended that the project be approved subject to the conditions listed above

and adherence to the EMP recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-1

1 INTRODUCTION

11 BACKGROUND

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)

Nelson Mandela Bay Municipality Eastern Cape Province

The demand for galvanised steel products is high in South Africa and Africa and is

expected to increase in the foreseeable future From an economic point of view the

proposed project has therefore been found to be viable

Casa Steel will source the steel coils from various markets internationally and in

South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is

destined to be exported mainly to African countries

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

An Environmental Impact Assessment (EIA) is required as the proposed project

involves several activities listed in terms of Section 24 of the National Environmental

Management Act (NEMA) No 107 of 1998 as amended and requires an

environmental authorisation

The following listed activities requiring environmental authorisation have been

identified

Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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 metres

Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped

land to industrial use greater than 1 ha but less than 20 ha in size outside an

urban area

Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any

process or activity requiring a license in terms of national or provincial legislation

governing the generation or release of emissions

Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5

hectares or more of vegetation where 75 or more of the vegetative cover

constitutes indigenous vegetation except where such removal of vegetation is

required for

(i) purposes of agriculture or afforestation inside areas identified in

spatial instruments adopted by the competent authority for

agriculture or afforestation purposes

(ii) the undertaking of a process or activity included in the list of waste

management activities published in terms of section 19 of the

National Environmental Management Waste Act 2008 (Act No 59

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-2

of 2008) in which case the activity is regarded to be excluded from

this list

(iii) the undertaking of a linear activity falling below the thresholds in

Notice 544 of 2010

Hot dip galvanizing is a listed activity in terms of section 21 of the National

Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires

an Atmospheric Emissions Licence (AEL)

In addition the treatment of wastewater with an annual throughput capacity of more

than 2000 m3 is a listed activity in terms of the National Environmental Management

Waste Act 59 of 2008 and requires a waste management licence

ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental

Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact

Assessment process in terms of section 24 of NEMA for the construction and

operation of the proposed galvanizing plant The EIA process covers all aspects of

the project and informs all three applications (for environmental authorisation waste

management licence and AEL)

13 PURPOSE OF THIS REPORT

This report builds on the scoping report submitted to the Eastern Cape Department of

Economic Development and Environmental Affairs (DEDEA) and the Nelson

Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It

describes the proposed project and presents the findings of the second phase of

investigations (EIA phase)

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT

PRACTITIONER (EAP)

The EIA was managed by Ms Terry Baker a certified Environmental Assessment

Practitioner with 20 years of working experience She has a MA in Environmental

Management and specialises in Environmental Impact Assessments and Project

Management She has been involved in a variety of different types of EIAs including

for water supply projects dams transmission lines roads and airports in South

Africa Botswana Uganda Lesotho and Mozambique She has been involved in

water resource management and public participation programmes on a number of

projects Terry has also been involved in the use of Geographic Information Systems

environmental status quo reports water quality assessments socio-economic and

institutional development projects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-3

15 PROJECT TEAM

In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen

(water quality specialist) and Lea September (EAP) with specialist input from Renee

von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous

substances) and Seniel Pillay (Traffic Impact Assessor)

The Business Unit Head of the ILISO Environmental Management Discipline Group

Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is

a Fellow of the South African Institution of Civil Engineers a member of the South

African Society of Aquatic Scientists of the Environmental Scientific Association of

the International Water Association of the Water Institute of South Africa and of the

Vaal River Catchment Association He is a certified Environmental Assessment

Practitioner with 30 years experience who specialises in project management

environmental impact assessments and water resource planning He specifically has

extensive experience in water quality especially water quality management water

quality monitoring and water quality assessment Martin has experience in managing

projects that involve multi-disciplinary teams and public consultation and

participation in South Africa and abroad

Lea September is an Environmental Assessment Practitioner with a Masters degree

in Environmental Management She has experience in impact assessment and

environmental management and has been responsible for drafting impact

assessment reports and Environmental Management Programmes and conducting

public participation processes as well as high level environmental screenings for a

variety of projects in the energy water transport and industrial sectors

Renee von Gruenewaldt has nine-years experience in the field of air pollution

impact assessment and air quality management Prior to becoming involved in air

quality consultation she was part of the Highveld Boundary Layer Wind Research

Group based at the University of Pretoria Since joining Environmental Management

Services (the company now Airshed Planning Professionals) she has undertaken

numerous air pollution impact studies and has provided extensive guidance to both

industry and government on air quality management practices

Pieter Smuts graduated as a Civil Engineer and became involved in the field of

municipal engineering and infrastructure construction He has specialized during the

last twelve years in solid waste management He has completed waste management

plans feasibility studies and final designs of waste management facilities in South

Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and

the review of the Mavoco hazardous waste landfill design in Maputo Mozambique

and completed a study on hazardous waste (textile factory sludge) management in

Maseru Lesotho

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-4

Seniel Pillay is a transportation engineer with over 16 years experience in

transportation planning and traffic engineering He has been involved in a wide

range of projects ranging from developing the Transport Operations Plan for the

FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System

for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller

traffic impact assessments for inter alia road improvement schemes Of particular

relevance to this project his experience includes Heavy Goods Vehicle Study for

eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact

Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash

Preliminary Transportation Assessment

16 STRUCTURE OF THIS REPORT

The proposed project and the alternatives considered are described in Chapter 2

Chapter 3 details the approach adopted for the EIA phase

The biophysical and socio-economic environment affected by the activity is described

in Chapter 4

The environmental impacts identified are discussed in Chapter 5

The EIA methodology is described in Chapter 6 and Chapter 7 presents the results

of the impact assessment

The environmental impact statement is presented in Chapter 8

Finally Chapter 9 spell out the conclusions and recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-1

2 DESCRIPTION OF THE PROPOSED PROJECT

21 TECHNICAL ASPECTS

211 The galvanizing process

Galvanizing consists of coating steel with zinc in order to protect it from corrosion

Before steel strips can be galvanized they undergo a pre-treatment in order to

ensure that the steel sheets are free from any surface oxides as they enter the

molten zinc coating Bath This is done by removing the oil from the steel sheets (in

the degreasing unit) and then removing the rust from the surface of the sheet (in the

pickling unit)

The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The

melting zinc on the strip surface will be cooled and solidified through air cooling in the

cooling tower

Finally the galvanised steel sheets are dipped into a water quenching tank in order to

further cool the sheets from about 150degC to 40degC

It is possible to make galvanised steel more durable by chromating it Approximately

50 of the galvanised steel production output will receive chromate passivation

treatment after quenching the galvanised steel sheets will be sprayed with a chrome

solution (3 kgcm2)

After galvanizing and chromating the steel sheets are cut to achieve the desired coil

size and weight and transported to the storage yard

The process flow diagram below (Figure 1) illustrates the main stages of the

galvanizing process and indicates the major inputs and outputs as well as the

resulting effluent and atmospheric emissions

Draft Environmenal Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-2

Figure 1 Process flow diagram for proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-3

212 Main inputs and outputs in operational phase

In view of the above the main inputs will be as follows

Steel coils 85 000 tonsyear

Zinc 870 tonsyear

Electricity 2500 kVA

Water 2000 m3month (of which 400 m3 will be potable water)

Liquid Natural Gas (LNG) 270 NM3hour

Sodium hydroxide (NaOH) 1000 m3year

Hydrochloric acid (HCl) 800 m3year

Chrome (Cr+3) 10 m3year

The main outputs will be

Galvanized steel 80 000 tonsyear

Scrap metal 20 tonsyear

General waste 65 tonsyear

Hazardous waste 2 m3month

Wastewater 012 Mlweek

Atmospheric emissions lt 5 ppm

213 Installations on site

The bulk of the operations involved in the galvanizing process occur along a

continuous galvanizing line (See Figure 2 below) which is the main piece of

machinery required for the proposed galvanising plant

Figure 2 Continuous Galvanizing Line

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-4

Water is one of the major inputs and is used throughout the galvanizing process notably

for rinsing and cooling purposes and as a mixing agent for the various chemical

solutions The plant will have a water treatment plant on site to treat the water used in

the various processes (approx 250 m3

of wastewater per week) The wastewater

treatment facility will be operated by a professional water treatment company as Casa

Steel does not have the required expertise in house to treat its process water Sulphuric

acid (H2SO4) is used as part of the treatment process to reduce caustic soda The

neutralised water is discharged to the sewer while any sludge is disposed of as

hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)

will be disposed of

Some critical areas of the galvanizing process such as the zinc pot require uninterrupted

power It is therefore proposed to install an LNG burner to maintain the zinc bath at a

temperature of between 450 and 460degC

22 LOCATION OF THE PROPOSED GALVANIZING PLANT

The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast

of Port Elizabeth in the Eastern Cape (Figure 3)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-5

Figure 3 Location of the proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-6

23 NEED AND DESIRABILITY

The profitability of the proposed project has been established by Casa Steel and a

pre-feasibility study has confirmed that the proposed project was feasible from a

technical and financial point of view The Coega IDZ is specifically designed to host

facilities such as a galvanizing plant and can provide the necessary infrastructure

and services to its investors It therefore constitutes a very suitable location for the

project

24 ALTERNATIVES IDENTIFIED

Zone 6 has been specifically earmarked for heavy ferrous metal industries and is

therefore a suitable location for the proposed galvanizing plant as such no site

alternatives have been provided for and assessed in this EIA However prior to the

commencement of the EIA process Casa Steel was presented with a number of

different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the

selection of the site were

(a) The dimensions of the land the site should be at least 200 m long and

50 m wide in order to accommodate the galvanizing line and adjacent lay

down area and additional land should be available next to the site for future

expansion

(b) The fiscal arrangements applying to the site the site should be located

within the future Custom Controlled Area (CCA) as the bulk of the

production output of the plant will be exported

The no-go alternative is assessed in this report

25 CONSTRUCTION ASPECTS

The construction phase of the project will take about 12 months and will essentially

consist of erecting a building to house the galvanizing line and other equipment and

preparing a concrete laydown area adjacent to the building

The CDC will provide an access point from the existing tarred road that will lead to

the site

Approximately 100 workers from the surrounding areas will be contracted for the

construction work

The requirements in terms of services during construction are listed below

Water 1000 m3month

Electricity 2500 kVA

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-7

The CDC will provide temporary services for the construction phase including a

conservancy tank for flush toilets Sewage infrastructure will only be provided for the

operational phase

26 OPERATION ASPECTS

Before the plant can become fully operational the equipment and machinery will be

tested for approximately 3 months The supplier will supervise these tests as part of

the transfer of know-how and training of staff on the plant

Casa Steel will start operating the plant at a reduced capacity (about 50 000

tonsyear) for a period of time (mostly determined by market aspects) before bringing

production to full capacity (80 000 tonsyear) This is done by operating the line for

longer hours

Approximately 50 to 60 people will be working on the plant Approximately 6-10 of

these will be unskilled 40-45 skilled and about 5 people in managerial positions

The requirements in terms of services during operation are as follows

Water 2000 m3month

Electricity 2500 kVA

Effluent discharge 24 m3day

The CDC has entered into agreements with the municipality to secure the provision

of services such as water and electricity to its tenants Tenants in the IDZ have their

own agreements with the NMBM for electricity while the agreements for water and

sewage are with the Facilities Unit of the CDC

Regarding discharge of wastewater to the sewer the municipality indicated that the

only requirement is that the water discharged complies with applicable municipal

discharge standards

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 3-1

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT

31 OBJECTIVES

The main objectives of the EIA phase are to

Assess the significance of the environmental issues and impacts identified in the

scoping phase focusing on key impacts

Recommend appropriate measures to mitigate negative impacts and enhance the

benefits and include them in the draft EMP

Undertake a public participation process that provides opportunities for all

interested and affected parties (IampAPs) to be involved

32 AUTHORITY CONSULTATION

The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental

Liaison Committeersquo (ELC) which comprises representatives of various authorities

including DEDEAT the Department of Environmental Affairs (DEA) and Department

of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the

Coega Development Corporation (CDC) and Transnet National Ports Authority

(TNPA) The ELC has been specifically formed to facilitate EIA applications in the

IDZ

Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to

the clearance of vegetation should be included in the application A formal request

was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the

application and all registered stakeholders were informed of the request in writing on

19 October 2011

33 PUBLIC PARTICIPATION PROCESS CONDUCTED

On-site notices were replaced by a notification displayed on the CDCrsquos digital notice

board at the business centre in Zone 1 of the IDZ The eNotice was placed on

13 April 2011 and will remain for the full duration of the EIA process

Registered stakeholders will be notified in writing of the availability of the draft EIA

report and EMP which will also be advertised in a local newspaper Stakeholders

including state departments and the public will have forty (40) days to comment on

the draft EIA report and EMP The draft EIA report and EMP will be sent by email

where possible and made available for download on the ILISO website

(wwwilisocom)

A summary of all issues and comments received during the stakeholder consultation

process as well as of correspondence in that regard will be captured in an Issues

and Responses Report that will form an Appendix to the EIA Report

The list of registered IampAPs is included in Appendix A

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 3-2

34 LEGISLATION AND GUIDELINES CONSIDERED

The following legislation and guidelines were considered in the preparation of this

report

National Environmental Management Act Act No 107 of 1998

NEMA EIA Regulations 2010

National Environmental Management Air Quality Act Act No 39 of 2004

National Environmental Management Waste Act Act No 59 of 2008

Hazardous Substances Act Act 15 of 1993

Occupational Health and Safety Act Act 85 of 1993

Hazardous Chemical Substances Regulations 1995 (GNR 1179)

Major Hazard Installation Regulations 2001 (GNR 692)

National Water Act Act 36 of 1998

National Heritage Resources Act Act 25 of 1999

DEAT Integrated Environmental Management Information Series 1-5 and 12-15

NEMA draft Implementation Guideline

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Public Participation (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Alternatives (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Draft Guideline for Determining the Scope of Specialist

Involvement in EIA Processes (2005)

IAIA guidelines

National air quality standard for thoracic particulates Government Gazette

No 32816

Listed activities and associated minimum standards identified in terms of section

21 of the National Environmental Management Air Quality Act Act No 39 of

2004 Government Notice 248 of 2009

Minimum Requirements for the Handling Classification and Disposal of

Hazardous Waste DWAF Waste Management Series (1998)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-1

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION

The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega

IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay

to the north of the N2 highway between Port Elizabeth and Grahamstown east of the

Coega River

The co-ordinates of the corners of the site are shown in Table 1

Table 1 Coordinates of site corners for the proposed galvanizing plant

Point Longitude Latitude

A 25deg411126E 33deg45587S

B 25deg411156E 33deg45499S

C 25deg411938E 33deg45131S

D 25deg412174E 33deg45481S

E 25deg412508E 33deg45979S

F 25deg412634E 33deg451160S

G 25deg411782E 33deg451560S

H 25deg411692E 33deg451428S

J 25deg411314E 33deg45868S

Figure 4 Zone layout in the Coega IDZ

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-2

Figure 5 Site location

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-3

42 SOCIO-ECONOMIC CHARACTERISTICS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the

NMBM There are no residents within the IDZ

As far as the broader NMBM and Eastern Cape Province are concerned the

following can be noted The NMBM is located within the Eastern Cape Province the

2nd largest Province in South Africa (3rd in terms of population) characterised by a

predominantly black population with low incomes and high levels of unemployment

(CES 2010)

The NMBM has a population of just above 11 million and covers an area of

1 950 km2 It is the main urban and industrial centre of the province and Port

Elizabeth in particular which forms part of the NMBM is the commercial capital of

the Eastern Cape 52 of the NMBM population is female and 37 is below the

age of 20 these two groups are particularly affected by unemployment

43 BIOPHYSICAL CHARACTERISTICS

431 Surface and ground water

No rivers occur in Zone 6 There is however a natural attenuation pond on the

southern most part of the site which will have to be avoided

The IDZ is underlain by calcrete sand and gravel deposits that overlie low

permeability clays These clays limit the vertical infiltration of rainwater and induce a

horizontal groundwater flow towards the Coega River channel which is the most

significant surface water feature in the Coega IDZ Consequently rapid run-off takes

place following precipitation (Jacobs 2008)

Groundwater levels at Coega are generally about 3 to 5 m below surface ie just

above the contact between the permeable sands and the underlying impermeable

clays The groundwater flow direction is to the southeast following the surface water

drainage direction (Jacobs 2008)

432 Climate and atmospheric conditions

Port Elizabeth has a warm temperate climate and the temperature ranges are not

extreme Exceptionally high temperatures may be experienced during berg wind

conditions which occur frequently during autumn and winter Extreme temperatures

also occur during summer with little accompanying wind

The wind regime for the area largely reflects the synoptic scale circulation with

dominant westerly and northwesterly flow fields representing the pre-frontal

conditions and south-westerly flow fields representing the frontal conditions The

south-easterly and south-westerly wind flow (land breeze) increases during daytime

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-4

conditions with westerly and north-westerly wind flow increasing during the night (sea

breeze)

The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of

Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15

km southwest) and Port Elizabeth (~23 km southwest)

An ambient air monitoring network has been established in the Coega IDZ which

consists of three monitors Saltworks Motherwell and Amsterdamplein Although

NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative

impacts due to the proposed Galvanising Plant is PM10 A maximum daily average

PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed

SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3

was exceeded on 17 days in 2007 and 26 days in 2008

Existing sources of emissions in the vicinity of the proposed galvanizing plant include

industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other

fugitive dust sources (von Gruenewaldt 2011b)

433 Geology and soils

Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel

and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly

limestone and conglomerate

434 Terrestrial ecology

This section draws from the EIA report compiled for the Agni Steel (formerly Afro-

Asia) steel processing facility which is adjacent to the proposed site for the

galvanizing plant (Jacobs 2008)

The area consists largely of grasses succulents and scrubby bush with alien

species making up the greater part of the more dense vegetation

Zone 6 falls within the inland vegetation and is characterised by a vegetation type

referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the

Coega IDZ and has been found to have three times the level of endemism of other

vegetation communities in the Coega IDZ Bontveld therefore has a high

conservation status Two Bontveld conservation areas have been identified within the

IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)

Bontveld that will be destroyed as a result of development in the IDZ will be given

conservation status in these two areas

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-5

Figure 6 Coega IDZ Open Space Management Plan (OSMP)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-6

Certain areas in the IDZ are invaded by alien plant species The most common

invader species is rooikrans (Acacia cyclops) which presently forms large

monospecific stands in areas throughout the Coega IDZ There are several other

aliens present that pose a threat to the flora of this area including the prickly pear

(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)

Loss of vegetation and alien plant invasion due to human activity has resulted in a

reduction in the diversity of terrestrial fauna

The majority of mammals present in the Coega IDZ are small or medium-sized Of

the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed

gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of

Algoa Bay however it is not considered threatened The gerbil is common in

foredune and dune thicket habitat in the Coega region and is therefore unlikely to

occur on the proposed site

A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird

species are resident or common to the area Most diversity occurs in the thicket

although the coastal area also supports specialised avifauna Two species of tern

the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well

as the Cape gannet (Morus capensis) and the African penguin (Spheniscus

demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne

caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant

(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser

flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns

are two of the most endangered coastal species in South Africa Other bird species

of conservation concern include the Whitefronted plover (Charadrius marginatus)

African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus

bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus

ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides

paradisea) Breeding pairs of Damara terns and African black oyster catchers have

been observed in the coastal dunes of the IDZ but should not be affected by

developments that fall outside the dune areas

The Eastern Cape supports nearly a third (approximately 133 species) of the reptile

species recorded in South Africa More than half of the Eastern Capersquos endemic

reptile species occur in the Algoa Bay area giving the region a high conservation

value A total of 63 reptile species are believed to occur within the Coega IDZ The

majority of these are found in Succulent Thicket and riverine habitats Only a few

reptile species occur in the coastal dunes and estuarine habitats More than a third of

the species are described as relatively tolerant of disturbed environments provided

that migration corridors of suitable habitat are maintained to link pristine habitats

Twenty two reptiles are of special concern including five endemic species (two of

which may also be endangered) four endangered sea turtles eight species listed

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-7

with CITES one rare species and four species at the periphery of their range

Fourteen of these species of special concern are confirmed as occurring on or within

2 km of the Coega IDZ

A total of 32 amphibian species and sub-species occur in the Eastern Cape

representing almost a third of the species recorded in South Africa However none of

the species are endemic or Red Data Book species Based on previous studies in the

area it is estimated that approximately 17 amphibian species occur within the Coega

IDZ Four species are listed as peripheral but none are threatened internationally

These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog

(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and

the bubbling kassina (Kassina senegalensis)

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated

vegetation has not been extensively studied One grasshopper species Acrotylos

hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue

(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis

pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in

four localities in the Eastern Cape one of which is within the Coega IDZ The Coega

copper Aloeides clarki is endemic to this particular region of the Eastern Cape and

is currently known to occur in three localities two of which are in the Coega IDZ The

localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the

Coega IDZ and their distributions were taken into account when defining Coegarsquos

open space system and Development Framework Plan

435 Land use and topography

The land is currently undeveloped and earmarked for industrial development The

site is relatively flat ranging from an elevation of 66 masl on the northern-most

corner to 59 masl at the southern-most corner

436 Heritage and archaeological survey

Extensive studies have been undertaken in Zone 6 with respect to heritage aspects

Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a

2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond

2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is

currently being finalised

Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing

Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha

in extent and was located next to the R102 road to Motherwell Kaplan conducted

HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi

Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will

now be located in Zone 5)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-8

The various archaeological investigations reached similar observations and

conclusions Stone tools of various densities and types were found throughout the

zone The majority of the stone tools were mainly of Earlier and Middle Stone Age

and occasional Later Stone Age origins (Figure 4)

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble

gravels exposed by tracks in Zone 6 (Source Binneman 2010)

The stone tools which comprised of quartzite flakes chunks flaked pebblecobble

and cores were randomly distributed across the landscape and are in secondary

context There were no lsquoconcentrationsrsquo of tools observed which suggested any

spatial patterning or activity areas although these may be present or covered by soil

and vegetation

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 5-1

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED

The following environmental issues and potential impacts were identified in the

Scoping phase

51 AIR QUALITY

The galvanizing process generates atmospheric emissions with particulates and

hydrogen chloride representing the main pollutants of concern The plant is fitted with

air extraction as well as scrubber systems which are designed to retain the bulk of

pollutants and particles for each of the processes in such a way that less than 5 ppm

of gases and particles will be released into the atmosphere after the fume scrubber

Other sources of impact on air quality include emissions from the LNG burner as well

as emissions and dust from the transport of steel and other materials in trucks

Construction activities will also create dust and gas emissions due to the clearing of

groundcover tipping of material to storage pile levelling of area wind erosion from

storage piles vehicle and construction equipment activity and tailpipe emissions

from vehicles and construction equipment such as graders scrapers and dozers

Overall the air quality impact assessment (Gruenewaldt 2011b) found that

The predicted particulate oxides of nitrogen carbon monoxide and sulphur

dioxide concentrations are all below the National Ambient Air Quality Standards

for all averaging periods

The predicted off-site concentrations of hydrogen chloride are well below the

most stringent effect screening levels

No odour threshold exceedances for hydrogen chloride were predicted to occur

due to routine operations at the Steel Galvanising Plant The South Wales

Environmental Protection Authority stipulates that an odour unit of 20 is

acceptable for urban areas The odour unit would be lt10 directly off-site for

hydrogen chloride

Abnormal emissions can occur in exceptional circumstances Start-up will not

cause abnormal emissions as the scrubbers will be commissioned first and will be

functioning once the plant starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions would be emitted as a

building fugitive

The hourly hydrogen chloride ground level concentrations (directly offsite) were

predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based

on the emission limits as stipulated for listed activities for galvanising processes)

using a screen model which assumes worst case meteorological conditions The

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-2

health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming

abnormal emissions emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset conditions will still

be well within the health effect screening levels

Similarly the hourly particulate emissions from the building fugitives during upset

conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for

listed activities for galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly

off-site

Therefore if emissions are 5 times higher normal they will still be within health effect

screening levels and the daily PM10 NAAQS levels

In the case of a fire a cocktail of gases and particulates could be emitted and could

be over the recommended levels This situation will however be dealt with as an

emergency and normalised as quickly as is possible

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS

The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of

its heritage potential and there are no proposed protected geosites in Zone 6

Should any artefacts be discovered during construction procedures stipulated in the

draft EMP will apply

53 BIODIVERSITY AND CONSERVATION

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

In terms of terrestrial fauna the CDCrsquos open space management plan provides for

the preservation of certain corridors The destruction of certain habitats as a result of

the development will therefore not automatically result in the loss of certain species

54 WATER QUALITY

There is a natural attenuation pond on the southern most part of the site which will be

avoided

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through

spills or leaks

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-3

This risk can however be minimized if not avoided altogether The floor of the factory

will be designed as a bunded area to contain any spills and the entire process will be

contained Potential spills or leaks will therefore be contained and will not impact on

water resources Storm water is therefore considered clean water under normal

operational conditions An oil trap will be placed at the exit of the site to ensure that

no grease from the laydown area enters the stormwater system

Spills and leaks can occur during the handling or the transport of hazardous

substances Best practice guidelines will be followed to ensure that this risk is

adequately managed

Wastewater discharged to sewer will be treated to comply with municipal discharge

standards and is not expected to have an impact on the chemical characteristics of

the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be

discharged from the plant is small in relation to the total volume received at the

Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works

(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently

operated at 61 of its capacity which is approximately 80 Mℓday Thus the

0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore

not have any significant impact on the WWTW

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES

The plant will generate a relatively small amount of solid waste in the form of scrap

metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)

The scrap metal may be sold to other steel processing facilities such as Agni Steel

which will be located next to the plant or collected and disposed of with the rest of

the solid waste by a licensed service provider

As mentioned previously there will be a wastewater treatment plant on site which will

neutralise process water (012 Mlweek) in order to ensure it is of a standard

acceptable for discharge to sewer Waste in the form of sludge from the

neutralization or spent acid must be disposed of as a hazardous waste Solid waste

from the filters used for air quality control is also in this category These wastes can

usually be tested and then delisted which means that it can be placed in a general

purpose landfill

Hazardous effluent from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-

site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored

and removed on a monthly basis is limited to 10 m3

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-4

A number of substances classified as hazardous are used in the galvanizing process

(Table 2) and the transport and handling of these is subject to certain rules and

guidelines In particular the material safety data sheets (cf Appendix H) should be

referred to for inter alia hazards identification accidental release measures

handling and storage precautions exposure controlpersonal protection ecological

information and transport information The Hazardous Chemical Substances

Regulations 1995 should also be adhered to in respect of the transport and storage

of hazardous chemical substances

Table 2 Hazardous materials to be used on site

Major Input Materials

Substance

listed in the

SABS 0228

Group II

hazardous

substances

Volumes to be

stored on site at

any one time

Diesel radic 2000 litres

Liquid petroleum radic 20 000 liters

Sodium hydroxide (NaOH)

(used for degreasing) 8 radic 1000m

3

Hydrochloric acid (HCI)

(used for pickling) 8 radic 800m

3

Zinc (used for galvanising) - TBD

Trivalent chromium (CR+3

)

(used for chromating) 8 radic 10m

3

Sulphuric acid (H2SO4) (used for

treatment of waste water on site) 8 radic TBD

Ammonium Hydroxide (NH4OH) 8 radic TBD

TBD ndash To be determined

Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one

time) and is classified as a flammable substance Specification for flammable storage

facilities in accordance with the requirements of the Nelson Mandela Bay

Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for

quantities between 5000 and 20 000 liters the substance must be kept in a

flammable liquid store which complies with the requirements of a specification

obtainable from the Department Some of the requirements are

Flammable liquid and solid storage facilities are only permitted on the ground

floor

Decanting of flammable liquids and solids are not permitted within any building

Due to the fact that there are flammable materials on site a certificate may be

required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and

Emergency Services Department to confirm that facilities for flammable storage

are in accordance with their requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-5

Because of the permanent installation and high quantity of liquid petroleum on site

the Major Hazard Installation Regulations 2001 promulgated under the Occupational

Health and Safety Act No 85 of 1993 applies A written application for approval of

the installation is required to be submitted to the chief inspector Department of

Labour provincial director Department of Labour and NMBM prior to construction

In addition a risk assessment should be formulated covering all hazardous materials

together with an emergency preparedness and response plan

56 HEALTH AND SAFETY

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling instructions as well as occupational exposure limits

are indicated in the material safety data sheets of the various substances used

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as

provide site supervision including executing tests (individual test cold run and hot

run) during 3 months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the

EMP

In addition the emergency preparedness and response plan will cover the health and

safety aspects related to emergency situations

57 TRAFFIC

The volumes of traffic at the IDZ are currently relatively low and variable depending

on the different zones in the IDZ however these volumes will increase as more

developments are implemented

The construction phase of the Casa Steel development will take about 12 months

and will essentially consist of erecting a building to house the galvanizing line and

other equipment and preparing a concrete laydown area adjacent to the building

The traffic that would be generated during the construction phase can be expected to

be less than the traffic that would be generated by the Casa Steel development when

it is fully operational

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-6

In the operation phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and

from the Port of Ngqura

The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the

Casa Steel development would be off Ring Road 1 The other roads of significance

for the Casa Steel development are the N2 Neptune Road MR435 and MR450

Access to the port is given by Neptune Road Road Link NEP-03 has not yet been

built

Figure 8 Coega IDZ road network identification

(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-7

Figure 9 Coega IDZ road network

Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No

01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-8

The distribution of freight trips is fixed as the majority of trips will be made between

the Port of Ngqura and the Casa Steel site With regard to personnel trips there are

various points of origins (the surrounding residential areas) that could be used by

staff going to the Casa Steel site The distribution of personnel trips is based on

existing traffic count information and is shown in Figure 10

Figure 10 Trip distribution for freight and personnel trips

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The resultant expected Casa Steel traffic assignment is shown in Figure 11

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-9

Figure 11 Morning peak hour Casa Steel development traffic

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The traffic that is expected to be generated by the Casa Steel development is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low

and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)

Consultation has taken place with Transnet Port Authority (TPA) to establish the

impact of the galvanizing plant operations on traffic inside the port The additional

ships entering and exiting the port of Ngqura as a result of the proposed development

will have a negligible impact on port traffic and TPA indicated that it would be well

within the portrsquos capacity

58 NOISE

Noise is not foreseen to be a significant issue insofar as the noise levels inside the

plant and at the boundary of the site will not exceed the limits prescribed by the CDC

Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels

during the day and 60 decibels at night

Mitigation of noise impacts will be addressed in the design of the noise-emitting

components of the plant and their enclosures

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-10

59 SOCIO-ECONOMIC ASPECTS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of

NMBM There are no residents within the IDZ

The direct socio-economic impacts of the proposed project are thus limited to the

employment generated by the project during construction and operation Job creation

remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)

and the IDZ and Port of Ngqura are expected to become a significant catalyst to the

economic growth of the Municipality and the region with current investments at

Coega creating more jobs and stimulating the economy

In this context the proposed galvanizing plant will make a positive contribution

towards the achievement of these goals

There will be 50 to 60 employees during operation phase distributed as follows

Figure 12 Casa Steel organisation chart

Even though a large part of the inputs will be imported and the bulk of the production

output will be exported there will be some positive impacts for the economy of the

region and of South Africa in general Notably the requirements of the plant for

water electricity waste collection and disposal waste water treatment and transport

for example will create business for the various service providers and have an

indirect impact on employment and fiscal revenues as a result

From a visual impact point of view it can be anticipated that the landscape in the IDZ

will be significantly affected over time by developments related to the establishment

of the port and various industries

HEAD ( WORKS )

MGR ( COMM) MGR ( ADMNHR ) Manager marketing

MANAGER OPERATION MANAGER MANAGER MANAGER Q C

AC FIN PUR ampSTORE

PPC SH-GALV SH-tech

SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF

1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO

JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF

2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO

WORKERS WORKERS 7NOS

15 7

RAW MAT amp

DESP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 6-1

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY

A description of the nature of the impact any specific legal requirements and the

stage (constructiondecommissioning or operation) will be given Impacts are

considered to be the same during construction and decommissioning The

significance of the potential impacts will be considered before and after identified

mitigation is implemented

The following criteria will be used to evaluate significance

Nature The nature of the impact will be classified as positive or negative and

direct or indirect

Extent and location Magnitude of the impact and is classified as

Local the impacted area is only at the site ndash the actual extent of the activity

Regional the impacted area extends to the surrounding immediate and

neighbouring properties

National the impact can be considered to be of national importance

Duration This measures the lifetime of the impact and is classified as

o Short term the impact will be for 0 ndash 3 years or only last for the period of

construction

o Medium term three to ten years

o Long term longer than 10 years or the impact will continue for the entire

operational lifetime of the project

o Permanent this applies to the impact that will remain after the operational

lifetime of the project

Intensity This is the degree to which the project affects or changes the

environment and is classified as

o Low the change is slight and often not noticeable and the natural functioning

of the environment is not affected

o Medium The environment is remarkably altered but still functions in a

modified way

o High Functioning of the affected environment is disturbed and can cease

Probability This is the likelihood or the chances that the impact will occur and

is classified as

o Low during the normal operation of the project no impacts are expected

o Medium the impact is likely to occur if extra care is not taken to mitigate

them

o High the environment will be affected irrespectively in some cases such

impact can be reduced

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 6-2

Confidence This is the level knowledgeinformation the environmental impact

practitioner or a specialist had in hisher judgement and is rated as

o Low the judgement is based on intuition and not on knowledge or

information

o Medium common sense and general knowledge informs the decision

o High Scientific and or proven information has been used to give such a

judgment

Significance Based on the above criteria the significance of issues will be

determined This is the importance of the impact in terms of physical extent and

time scale and is rated as

o Low the impacts are less important

o Medium the impacts are important and require attention mitigation is

required to reduce the negative impacts

o High the impacts are of great importance Mitigation is therefore crucial

Cumulative Impacts The possible cumulative impacts will also be considered

Mitigation Mitigation for significant issues is incorporated into the EMP for

construction

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 7-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS

71 IMPACTS DURING CONSTRUCTION

711 Air quality

Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris

handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine

particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural

operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks

and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)

Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Fugitive particulate emissions (dust)

related to construction activities Regional

Short

term Medium High High Medium Regional

Short

term Low High High Low

Construction vehicle gas emissions Regional Short

term Medium High High Medium Regional

Short

term Low High High Low

712 Heritage and archaeological resources

Naturedescription of impact excavation activities may impact on unidentified heritage resources

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-2

Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based

on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments

Heritage and archaeological

resources Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on unidentified heritage

resources Local

Short

term

Medium -

high Low High Low

713 Biodiversity and conservation

Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation

importance and cause soil contamination

Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species

Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan

and has compiled a list of protected species to be rescued (see draft EMP)

Biodiversity and conservation Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Loss of fauna and flora Local Perma

nent

Medium -

high High High High Local

Permanen

t Medium High High Medium

Soil contamination Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-3

714 Water related impacts

Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater

runoff spills and leaks Soil erosion

Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of

spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste

disposal Stormwater quality monitoring (see draft EMP)

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Soil erosion Local Short

term Medium Medium High Medium Local

Short

term Medium Low High Low

715 Waste management

Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed

Commentmitigation see draft EMP and waste management plan

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-4

Waste management Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Local

Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

716 Health and safety

Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Short

term

Medium -

high

Medium -

high High High Local

Short

term

Medium -

high Low High Low

717 Traffic

Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and

construction workers from surrounding areas and transport of equipment from the port

Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low

Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and

accurate estimates of quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-5

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Increased traffic on N2 and within the

IDZ Regional

Short

term Low High High Low

718 Noise

Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Short

term

Medium-

high High High Medium Local

Short

term Medium High High Medium

719 Socio-economic

Naturedescription of impact temporary employment will be created during the construction phase

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-6

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Temporary employment Regional Short

term Medium High High Medium

72 IMPACTS DURING OPERATION

721 Air quality

NatureDescription of impact gas and particulate emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning

Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local

sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and

veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute

to background fine particulate concentrations (von Gruenewaldt 2011b)

Assumptions and limitations Potential release of CR6+

As no emission factors are available for trivalent chromium processing the

potential impacts due to these activities could not be quantified

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Dust emitted from traffic on paved roads Regional Long Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-7

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

term

Hydrogen chloride emissions from

pickling process Local

Long

term Low High High Low

Particulate emissions (smoke) from

galvanizing process (due to the

volatilization of flux)

Local Long

term Low High High Low

Particulate oxides of nitrogen carbon

monoxide and sulphur dioxide emissions

from LNG burner

Local Long

term Low High High Low

Nuisance related to odour Local Long

term Low Low High Low

Abnormally high hydrogen chloride and

particulate emissions due to scrubber

malfunction

Local Short

term Medium Low High Medium

Gases (eg SOx NOx CO etc) and

smoke emitted in case of a fire Local

Short

term High Low High Medium

722 Water quality

NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks

Commentmitigation see draft EMP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-8

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Stormwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

723 Waste management and hazardous substances

NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous

waste both can affect environmental quality and human health

Commentmitigation see draft EMP and waste management plan

Waste management and hazardous

substances Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Regional

Long

term High

Medium -

high High High Regional Long term High Low High Low

Soilwaterair pollution due to improper

transport storage and handling of

hazardous substances

Regional Long

term High

Medium -

high High High Regional Long term High Low High Low

Health hazard Local Long

term High

Medium -

high High High Local Long term High Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-9

724 Health and safety

Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Long

term

Medium-

high

Medium-

high High High Local Long term

Medium-

high Low High Low

725 Traffic

Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on

the road network

Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak

hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road

network within Zone 6 of the IDZ (Iliso 2011)

Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)

Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of

quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-10

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on traffic and capacity of the N2 Regional Long

term Low High High Low

Impact on traffic and capacity of ring

road 1 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR435 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR450 Local

Long

term Low High High Low

Impact on traffic and capacity of

Neptune road Local

Long

term Low High High Low

726 Noise

Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Long

term Medium High High Medium Local Long term Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-11

727 Socio-economic

Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate

revenue for the municipality and the region as a whole

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Employment and economic growth Regional Short

term Medium High High Medium

73 COMPARATIVE ASSESSMENT OF IMPACTS

During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as

low during operation after mitigation

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 8-1

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

As a tenant operating in the IDZ Casa Steel will be required to comply with all

current and future CDC requirements as well as with the relevant conditions of

permits licences issued to CDC (eg Integrated Stormwater Masterplan for the

eastern side of the Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)

In particular the CDC has its own requirements regarding the monitoring of certain

aspects of the project such as the quality of the effluent and the noise levels These

have been incorporated into the EMP

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 9-1

9 ENVIRONMENTAL IMPACT STATEMENT

All predicted negative impacts can be mitigated to a low significance The only

exceptions are biodiversity as the construction of the plant will result in the

destruction of habitat and loss of fauna and flora and noise impacts inherent to

construction activities Mitigation measures have been included in the EMP for these

impacts and they have a medium significance post-mitigation

Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium to

long term similar impacts are likely to occur due to ongoing developments in the IDZ

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 10-1

10 CONCLUSION AND RECOMMENDATIONS

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as

other infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified

and assessed No fatal flaws have been identified

It is recommended that the project be approved subject to the conditions listed in

chapter 9 and adherence to the EMP requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 11-1

11 REFERENCES

Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ

Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants

Bennie JS (2010) The historical component (built environment) of the Heritage

Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port

Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report

compiled for Eastern Cape Heritage Consultants

Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater

Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay

Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage

Consultants

BKS (2006) Coega Industrial Development Zone Transport Study Volume 3

Demand Modelling Report Final Draft

Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I

Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6

Report compiled for SRK Consulting

Coastal amp Environmental Services (2010) Environmental Impact Assessment for the

Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone

Volume 3 Environmental Impact Assessment Report CES Grahamstown

Coega Development Corporation (2008) Industry Waste Management Plan -

Strategic Master Plan Report

Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants

Report No CDCSHE 03 8122

Department of Water Affairs and Forestry (1998) Waste Management Series

ldquoMinimum Requirements For The Handling Classification And Disposal Of

Hazardous Wasterdquo Second Edition

Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising

Plant in the Coega Industrial Development Zone

Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the

Coega Industrial Development Zone (IDZ) Specialist Water Study

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 11-2

Jacobs E (2008) Final Environmental Impact Report and Draft Environmental

Management Plan Proposed Steel Recycling and Processing Facility within the

Coega IDZ Report compiled for SRK Consulting

Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY

Galvanising Plant in the Coega Industrial Development Zone Waste Management

and Hazardous Substances Report compiled for ILISO Consulting

RSA National air quality standard for thoracic particulates (PM10) SA standards

(Government Gazette No 32816)

von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed

Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape

Report compiled for ILISO Consulting

von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel

Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report

compiled for ILISO Consulting

Additional sources

Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed

Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared

for Coastal Environmental Services

Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed

Kalagadi Manganese smelter in the Coega Industrial Development Zone Port

Elizabeth Eastern Cape Province Report prepared for Coastal Environmental

Services

Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia

steel recycling facility at the Coega Industrial Development Area Port Elizabeth

Prepared for SRK Consulting Port Elizabeth

APPENDIX A

LIST OF INTERESTED AND

AFFECTED PARTIES

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

DEDEARegional Manager

and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza

DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza

DEA Ocean and

CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza

DEA Ocean and

Coast

Oceanographer land-

based sources of

marine pollution

Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza

DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza

CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza

CDCEnvironmental

Project

Manager

Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza

TNPAPort of Ngqura

Environmental

Manager

Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet

NMBMEnvironmental

ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza

NMBMEnvironmental

ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza

DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza

DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza

WESSASenior Conservation

Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza

Zwartkops

ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700

hughlauegmailcom

zwartkopstrustiafricacom

SANParksNational Marine

CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza

Department Of

LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza

NMBM Air Quality

Division

Assistant

DirectorAir

Pollution and Noise

Templeton Titima 079 490 0574 Ttitimamandelametrogovza

NMBM Air Quality

DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza

NUMSARegional

RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

Department of

HealthNadiema

van der

Bergh083 378 2103

nadiemavanderberghimpiloecprovgov

za

DWA Chief Services

Officer

Joseph Jacobs 041 586 4884 jjacobsdwafgovza

EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza

NUMSecretary of union

officesZandile Xhentsa 043 743 6597 zxhentsanumorgza

DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza

Dynamic

CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom

EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza

Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza

UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom

lprincezago2uticom

Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza

Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza

Absa Mr Johann Steyn 082 3775820 johannstabsacoza

Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza

PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza

Universal

EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza

Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza

GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom

Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza

NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom

DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza

DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza

TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet

DWA Mr Landile Jack JackLdwagovza

DWA Ms Lizna Fourie FourieL4dwagovza

APPENDIX B

NOTICE OF ATMOSPHERIC

EMISSIONS LICENCE APPLICATION

AND ADVERTISEMENT

APPENDIX C

NOTICE OF COMMENT PERIOD FOR

DRAFT SCOPING REPORT

APPENDIX D

SUMMARY OF ISSUES RAISED AND

RESPONSES THERETO

April 2012

1

PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL

DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))

IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt

AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt

This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses

provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process

conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the

Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

2

IssueCommentQuestion Date

received Origin Response

1 Please provide more information with respect to the potential

dangers including the toxicity of the proposed project

07032011

By email

Wayne Poulton

(Bosun Brick

tenant at the

IDZ)

An Environmental Impact Assessment (EIA) was undertaken

which assessed the potential toxicity of the emissions and

effluent Mitigation measures were also recommended in the draft

Environmental Management Programme (EMP) to avoid

minimise or compensate any significant impacts The Draft

Environmental Impact Report and draft EMP were made available

to stakeholders for comment in March 2012

2 Do you have a Background Information Document (BID) or

similar that provides more information on the project

27032011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The BID was sent to all registered IampAPs on 4 May 2011

3 The RoD issued to the CDC on 632007 for the change in

land use for the remaining area of the Coega IDZ includes a

number of requirements with respect to

atmospheric emissions that should be considered in the

Atmospheric Emissions Licence (AEL) application such as

prohibiting and monitoring where possible visible emission

plumes to the atmosphere In particular the

recommendations on pp87-91 of the final revised Scoping

Report dated Nov 2006 must be implemented (clause 421)

04042011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

We have obtained copies of the documents referred to and ensure

that these requirements were taken into account in the

environmental assessment and AEL application

4 If the Port of Ngqura is used for import and export the scope

of the traffic impact assessment (TIA) should also include the

port

10052011

By email

Elliot

Motsoahole

(TNPA Port of

Ngqura)

The scope of the TIA was extended to include port related traffic

The TNPA at the Port of Ngqura was consulted and does not

have any objection to the project TNPA has indicated that the

development would require a minimum number of vessels per

year which would have minimal impact on the Port operations

However due notice would have to be given to the Port of Ngqura

before a vessel is scheduled to arrive so that the vessel can be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

3

IssueCommentQuestion Date

received Origin Response

accommodated at an available berth

5 Concerns with respect to potential stormwater pollution

draining into the Coega catchment and the port of Ngqura

The port needs to be dredged and heavy metals present a

risk in that regard

16052011

By

telephone

Andrew Lucas

(Department of

Water Affairs)

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination by effluent waste or

hazardousdangerous substances is very low

Thus no metals oils or other contaminants are expected to be

present in the stormwater

However stormwater pollution can occur in exceptional

circumstances such as accidents and emergencies The

emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

6 All steel sheets bathing unit must be under roof

7 The sludge out of the decreasing bath will be high in Na and

pH Therefore handling and disposal must be clarified up front

in this project

8 Per se the wastewater from decreasing bath will have high

ph and the component from the pickling unit will have low ph

Then it may be assumed that both streams will neutralize

each other Please then clarify proposed sewer discharge

with Nelson Mandela Bay Municipality up-front for acceptance

of influent as per the documented proposal

9 Pickling may result in dissolved metals How does your team

expect to deal with this As it is planned for discharge into

24052011

By email

Landile Jack

(Department of

Water Affairs)

All bathing units will be under roof

Effluent from the degreasing and pickling baths will be discharged

to the wastewater treatment plant The respectively alkaline and

acidic effluents will mix and neutralise each other in the

wastewater treatment plant Calcium or gypsum will be added if

required to complete the neutralisation process Effluent from the

treatment plant will be discharged to sewer Contact has been

made with the relevant officials and the Municipalityrsquos

requirements have been obtained The effluent discharged to

sewer will notably comply with the applicable discharge standards

Traces of metals (eg iron) may be present but will not exceed

prescribed thresholds The necessary authorisation will be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

4

IssueCommentQuestion Date

received Origin Response

sewer Clarity and acceptance needs to be agreed with

Nelson Mandela Bay Municipality Who owns the sewer

10 Quenching unit will results to Zinc particles How will this

affect sewer discharge This again must be dealt with within

the negotiations with the Municipality

11 Once all has been agreed with the Municipality and at the

same time due negotiations must be done with hazardous

waste courier and disposal facility to accept the hazardous

waste identified in all production lines

12 Of note is the low volume of the proposed WWTW facility ie

250 cubmweek And the no discharge of the quenching

water ie over-flow and cooling only Hence Zinc particles

generation

obtained from the municipality

The sludge from the treatment plant will be collected by a licensed

service provider and disposed of at a permitted site

The quenching bath will be periodically emptied (every 6 months)

and the water discharged will go to the water treatment plant Zinc

particles will settle in the sludge which will be disposed of at a

permitted site

Contact has been made with EnviroServ who manages the

Aloes II HH waste site regarding collection and disposal of

hazardous waste (See waste management report)

13 Investigate the potential effects of toxicity andor influence of

emissions waste and hazardous substances both in

terrestrial and marine fauna

14 With regards to water usage where is the plant going to

extract its waters used in galvanization andor waste

management process ie rainfall rivers or even from the

sea) and which avenues would be more environmental

friendly and effective

31052011

By email

A Bewana

(SANPARKS)

Emissions waste and hazardous substances are not expected to

affect terrestrial or marine ecosystems The air quality study

concluded that atmospheric emissions would not be harmful to

human health and by extension terrestrial fauna There are no

standards for air quality for defining faunal impacts therefore by

ensuring that standards for humans are complied with the impact

on fauna is deemed to be acceptable In this case the impact of

emissions on terrestrial and marine fauna are thus not significant

Solid and liquid wastes both general and hazardous as well as

hazardous substances will be stored handled and disposed of

appropriately to as not to cause harm to terrestrial or marine

fauna

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

5

IssueCommentQuestion Date

received Origin Response

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination and hence land-based

marine pollution by effluent waste or hazardousdangerous

substances is very low

The risk of emissions waste and hazardous substances to

terrestrial and marine fauna is thus very low

However pollution of terrestrial and marine ecosystems can occur

in exceptional circumstances such as accidents and emergencies

The emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

The CDC has an agreement with the NMBM to supply potable

water to the Coega IDZ Currently the infrastructure to supply

return effluent (RE) to the IDZ is not in place therefore Casa Steel

will be supplied with potable water up until such time as the

following 2 options of RE are available

1) Upgrading of the existing Fishwater Flats waste water

treatment works (between IDZ amp PE) including RE plant

and infrastructure to pipe RE to the IDZ (EIA for the

upgrade is underway)

2) Construction of a new waste water treatment works

including RE plant in Zone 9 of the Coega IDZ

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option should be investigated further between Agni and Casa The

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

6

IssueCommentQuestion Date

received Origin Response

CDC can facilitate discussions between the 2 investors

Compliance with CDC Permits amp Requirements

15 It should be made clear that tenants will be required to

comply with CDC requirements and the relevant conditions of

permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water

Licence for its Storm Water Systems on the

East Side of the Coega River that tenants will

need to take cognizance of The contents of the

ldquoIntegrated Stormwater Masterplan for the

eastern side of the Coega IDZ Oct 2010rdquo

especially the Table of best practice p53

onwards may need to be taken cognizance of

o CDC is developing an Operations

Environmental Management Plan that will place

certain obligations on tenants

16 Environmental audits and data collected during monitoring

(eg stack emissions stormwater) will need to be shared with

CDC

Air Emissions

17 Presumably permanent in stack monitoring will be required in

terms of AEL permit requirements

18 Abnormal operating conditions resulting in air emissions ndash I

could find nothing in the EIR to indicate under what

circumstances these could occur (eg start-up) potential

frequency and duration and the impact on ambient air quality

ndash these events usually result in the most problems wrt air

emissions

09042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

15 Compliance with the CDCrsquos Permits amp Requirements has

been included explicitly as a requirement in the EIR (p8-1) and

EMP (pp18 and 25) in the following terms

ldquoAs a tenant operating in the IDZ Casa Steel will be required to

comply with all current and future CDC requirements as well as

with the relevant conditions of permits licences issued to CDC

(eg Integrated Stormwater Masterplan for the eastern side of the

Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)rdquo

16 The need to communicate with the CDC on monitoring and

auditing activities was emphasised in Chapter 8 of the EMP The

following paragraphs were added

ldquoDuring construction the environmental officer will be responsible

for monitoring compliance with the EMP and authorisation

conditions and keeping records as required in the EMP andor

authorisation conditions

The ECO will conduct site inspections every two weeks audit the

records kept by the environmental officer and submit an

environmental compliance report every two months to the

authorities and the CDC (via the Environmental Monitoring

Committeersquos ECO)

During operation the health and safety officer will monitor

compliance with the EMP and the conditions of the Environmental

Authorisation Data collected during monitoring activities and any

environmental audits conducted will be shared with authorities

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

7

IssueCommentQuestion Date

received Origin Response

Water

19 Large volumes of (2000 m3mth) of water are required of

which only 400m3 needs to be potable The NMBM return

effluent system will provide non-potable water once it is

constructed What other water recycling initiatives can be

utilized to reduce potable water requirements (the ISWMP for

the eastern side of the Coega IDZ has some best practice

guidelines collecting rainwater from the roof etc)

General

20 There is no mention of how the CDC Architectural Guidelines

will be incorporated into the development (eg to prevent a

stark uniform warehouse type development)

21 Does NMBM have adequate fire services to cover this

development Apart from the large petroleum store are there

any other large fire hazards

22 Reports from the tenantrsquos ECO during construction and from

the SHE Officer during operations should be channeled to the

Coega Environmental Monitoring Committee This can be

directly or preferably via the EMCrsquos ECO (this will be while

the EMC and ECO are in place) A precedent has been set

for this in the Environmental Authorisations for Agni-Steel and

Kalagadi Manganese Smelter

23 All mitigation actions emanating from the EIR should be

summarized (preferably in a table) If compliance with them is

to be part of the Environmental Authorization from DEDEAT

then they (or the ones that DEDEAT deems to be applicable)

and the CDC (via the Environmental Monitoring Committeersquos

ECO)

The ECO (during construction) and the health and safety officer

(during operation) will report to the Coega Environmental

Monitoring Committee (EMC) via the EMCrsquos ECO (this will be

while the EMC and ECO are in place)rdquo

17 The draft EMP recommends regular monitoring of emissions

from the scrubbers and from the chromating process Additional

emissions monitoring requirements will be confirmed once the

AEL is issued Mention has been made in the EMP (pp11 and 19)

that all AEL conditions including monitoring and reporting

requirements should be adhered to

18 Abnormal emissions can occur in exceptional circumstances

Start-up will not cause abnormal emissions as the scrubbers

will be commissioned first and will be functioning once the plant

starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions

would be emitted as a building fugitive

The hourly hydrogen chloride ground level concentrations

(directly offsite) were predicted to be 239 microgmsup3 (based on the

emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits

as stipulated for listed activities for galvanising processes) using a

screen model which assumes worst case meteorological

conditions The health effect screening level for hourly HCl

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

8

IssueCommentQuestion Date

received Origin Response

should be attached to the EA as an Appendix (otherwise no

one knows about them or takes cognizance of them)

concentrations is 2100 microgmsup3 Assuming abnormal emissions

emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset

conditions will still be well within the health effect screening

levels

Similarly the hourly particulate emissions from the building

fugitives during upset conditions would amount to 293 microgmsup3

(based on the emission limits as stipulated for listed activities for

galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1

January 2015) directly off-site

Therefore if emissions are 5 times higher normal they will still be

within health effect screening levels and the daily PM10 NAAQS

levels

In the case of a fire a cocktail of gases and particulates could be

emitted and could be over the recommended levels This

situation will however be dealt with as an emergency and

normalised as quickly as is possible

The above has been added to the impact identificationdescription

and assessment sections of the EIR

19 The CDC has an agreement with the NMBM to supply

potable water to the Coega IDZ Currently the infrastructure to

supply return effluent to the IDZ is not in place therefore Casa

Steel will be supplied with potable water up until such time as the

infrastructure is in place

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

9

IssueCommentQuestion Date

received Origin Response

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option will be investigated further between Agni and Casa The

CDC has come forward to facilitate discussions between the two

investors

Other water recycling initiatives such as rainwater harvesting

have been considered but are not practical

20 The CDCrsquos Architectural and Landscape Design guidelines

contain requirements pertaining to such aspects as the height

orientation and mass and form of buildings as well as guidelines

for landscaping and signage in order to ensure an attractive

development and achieve an architectural integrity within the

Coega IDZ The plans for the proposed galvanizing plant will be

submitted to the Design Review Committee for approval as

required by the CDC

21 Casa Steel will be required to install fire hydrants according

to the NMBMrsquos standardsrequirements The CDC will provide

potable water (up until such time as return effluent is available)

and a connection to the boundary of the site which will be

connected to the fire hydrants The installation of the fire hydrants

will require approval by the Metrorsquos Fire Chief as was done for

Agni-Steel one of the investors in Zone 6

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

10

IssueCommentQuestion Date

received Origin Response

The Coega IDZ falls within the NMBM and therefore the rates and

taxes paid by the CDC covers the fire services for which the Metro

is responsible Currently the Metro has sufficient capacity to

provide fire services to the tenants within the IDZ This was

confirmed in discussion with the CDCrsquos Infrastructure

Development Unit It is however unknown at which point the

Metrorsquos Disaster Management Plan would not be able to

accommodate servicing tenants in the IDZ

The LNG burner is the only major fire hazard on the plant

22 See response to item 16 above

23 Key mitigation and management measures emanating from

the EIR were recapitulated in Chapter 9 of the EIR to form part of

the conditions attached to the Environmental Authorization from

DEDEAT All mitigation measures recommended as a result of the

impact assessment are presented in a table in the draft EMP

which is appended to the EIR (Appendix J)

24 Hydrogen chloride is one of the main emissions There are no

ambient air quality guidelines for HCl and the EIR says

concentrations will be well within health parameters

However the main problem with HCl is its corrosive effect -

there is absolutely no mention of this in the draft EIR nor air

specialist report

There needs to be some sort of comment assessment as to

whether HCl emissions are likely to impact on for example

the adjacent Agni-Steel Plant wrt corrosion - their factory

structure will be made of steel

11042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The atmospheric corrosion of metals is a complex process with

both the extent of deterioration and the mechanisms varying

considerably depending on the metal Depending on the way

pollutants are transported from the atmosphere to the corroding

surface two types of deposition processes are recognized in

atmospheric corrosion ndash dry deposition and wet deposition Wet

deposition refers to precipitation whereas dry deposition refers to

the remaining processes including gas phase deposition and

particle deposition The most important pollutants acting as

corrosive agents are sulphur and nitrogen compounds including

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

11

IssueCommentQuestion Date

received Origin Response

The EIR specialist rpt suggests monitoring HCl at ground

level on the property boundary and this is supported in case

there are complaints from neighbours

secondary pollutants and particulates Pollutants can contribute to

corrosivity individually however there may be a synergistic effect

when more than one of these pollutants is present in the

environment being affected In the field of atmospheric corrosion

sulphur dioxide is the single most investigated gaseous pollutant

and the quantification of the direct contribution of sulphur dioxide

to the corrosion process of metallic materials is comparatively well

understood (Tidblad amp Kucera 1998)

Very little work has reported on the effect of HCl on the

degradation of materials in the environment with no local dose-

response thresholds developed for corrosion occurring due to HCl

exposures This is probably because HCl which is present

outdoors in markedly reduced concentrations when compared

with SO2 has not been considered to contribute to significant

degradation of materials (Syed 2006) For this reason the

incremental corrosion due to HCl from the Coega Galvanising

Plant cannot be quantified

25 It is unacceptable for ILISO to be using CDC maps (see

figure 9 ndash pg5-6) without these maps being referenced

accordingly particularly when it appears that a CDC map has

been used and then overlaid with features by an unknown

author (ie CASA steel site Port (where the boundaries

depicted are incorrect) and a North legend which is out of

keeping with the overall cartographic intent of the original

work

26 Figure 10 is not referenced appropriately and I believe that I

commented previously in respect to references to roads not

12042012

By email

Graham Taylor

(Spatial

Development

Manager -

Infrastructure

Development

CDC)

This has been rectified in the final version of the report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

12

IssueCommentQuestion Date

received Origin Response

yet built As a result Figure 10 is confusing and clarity needs

to be provided in terms of referencing In addition the Port

shape is irregular and similar to the comment above

27 I acknowledge the emergency preparedness and response

plan but please confirm that this includes pro-active routine

monitoring of storm water leaving your premises to verify that

your assumptions of clean storm water are correct

13042012

By post

Andrew Lucas

(Director

WRampU

Department of

Water Affairs)

Pro-active routine monitoring of stormwater leaving the premises

will be undertaken This has been explicitly emphasised in

chapter 8 of the draft EMP

28 Will portablechemical toilets be used during construction

29 What provisions have been made for storm water drainage

during construction

18042012

By

telephone

Department of

Water Affairs

Port Elizabeth

Chemical toilets will be used during construction

The Casa Steel site will be located at the corner of two roads

drainage of stormwater from the site will take place through the

roadsrsquo drainage system

From Lea September [mailtoleailisocom]

Sent 11 March 2011 0935 AM

To Wayne Poulton

Cc Terry Baker

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Wayne

An Environmental Impact Assessment (EIA) will be undertaken for this project during the

next 10 to 12 months

We foresee that some of the key environmental impacts of the project will be in terms of air

quality water quality waste and hazardous substances

At this stage I am not able to give you any details regarding the potential toxicity of the

emissions andor effluent However specialist studies will be conducted as part of the EIA

that will determine the key impacts of the project Mitigation measures will also be identified

to avoid minimise or compensate any significant impacts

You are registered on the stakeholder database and you will be kept informed of progress in

the EIA process you will notably get the opportunity to access the reports produced and

provide any feedback on them

Please feel free to contact me should you need any further information

Best regards

Lea September

From Wayne Poulton [mailtowaynepbosuncoza]

Sent 07 March 2011 1257 PM

To Lea September

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

Please can you provide me with some more information as to the potential dangers including

the toxicity of this

Kind regards

Wayne

From Lea September [mailtoleailisocom]

Sent 04 March 2011 1123

To Lea September

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 March 2011 0745 AM

To Paul Martin

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 05 April 2011 0847 AM

To Paul Martin

Cc Terry Baker Renee von Gruenewaldt

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Thank you Paul for this information

I have downloaded a copy of the RoD and Scoping report you referred to and will make sure

these requirements are taken into account in the environmental assessment

Best regards

Lea September

From Paul Martin [mailtopmartinaxxesscoza]

Sent 04 April 2011 0955 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Further to my comments on 27311

Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in

the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega

IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised

scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions

including prohibiting and monitoring where possible visible emission plumes to the atmosphere

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Paul Martin

Sent Monday March 28 2011 745 AM

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 10 May 2011 0327 PM

To ElliotMotsoaholetransnetnet

Cc Terry Baker

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Mr Motsoahole

Thank you for your input on this issue

The Port of Ngqura will indeed be used for import and export At the moment the scope of

the traffic impact assessment only covers road traffic I have however relayed the matter to

our traffic specialist and we will consider this issue in the finalization of the Scoping Report I

will keep you informed of any developments in that regard

I trust this is acceptable to you

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]

Sent 10 May 2011 0855 AM

To Lea September

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

It has been noted that Casa Steel will source steel coils from various markets internationally and

in South Africa and the bulk of the plantrsquos production output will be exported to African countries

However there is no mention of logistic requirements

Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will

be used the scope of traffic impact assessment should also include the port

Regards

From Lea September [mailtoleailisocom]

Sent 04 May 2011 0747 AM

To Lea September

Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

Please find attached a letter announcing the EIA process underway for the proposed 80 000

tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as

a Background Information Document (BID) outlining the details of the project

Please contact me should you require any further information on this project

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

Elliot Motsoahole

Manager - Environment

Transnet National Ports Authority

Port of Nqqura

Port Control Building Klub Road Port Elizabeth 6212

PO Box 612054 Bluewater Bay 6212

+27 41 507 8450

+27 86 674 7729

Cell +27 83 542 5619

E-mail Elliotmotsoaholetransnetnet

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

DISCLAIMER The information contained in this communication is subject to copyright and

intended only for the use of leailisocom Unauthorised use disclosure or copying is

strictly prohibited Should a virus infection occur as a result of this communication the sender

will not be liable If you have received this communication in error please notify

elliotmotsoaholetransnetnet

From Lea September [mailtoleailisocom]

Sent 25 May 2011 1147 AM

To Jack Landile (ELS)

Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi

Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Landile

Thank you for your input

Contact has been made with the relevant Municipal Directorate and we will follow up with

them to obtain clarifications on all these issues

I have added both Lizna and yourself on the database and will keep you updated on

progress on this project

Best regards

Lea September

From Jack Landile (ELS) [mailtoJackLdwagovza]

Sent 24 May 2011 0524 PM

To Fourie Lizna (ELS)

Cc Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Hi Lizna

I missed you on this sorry

I linked Pieter twice Instead

Regards

Landile

From Jack Landile (ELS)

Sent 24 May 2011 0445 PM

To leailisocom

Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Lea

The e-mail you sent to Mr Kooverji dated 19 May 2011 refer

Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are

All steel sheets bathing unit must be under roof

The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project

Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal

Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer

Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality

Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines

Of note is the low volume of the proposed WWTW facility ie 250 cubmweek

And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles

generation

Regards

Landile

From Lea September [mailtoleailisocom]

Sent 19 May 2011 0947 AM

To Lea September

Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Stakeholder

Please find attached the remaining appendices to the draft Scoping report for the proposed

80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 June 2011 0411 PM

To Aphiwe Bewana

Subject RE Proposed 80 000 TPY Galvanizing plant in Coega

Dear Mr Bewana

Thank you for your input and apologies for the late reply

We have taken note of your comments and are will be taking them forward in the EIA phase

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Aphiwe Bewana [mailtoaphiwebewanagmailcom]

Sent 31 May 2011 1205 PM

To Lea September

Subject Re Proposed 80 000 TPY Galvanizing plant in Coega

Comment

Re Proposed 80 000 TPY Galvanizing plant in Coega

As SANParks we would like the EIA phase to investigate the potential effects of toxicity

andor influence of emissions waste and hazardous substances both in terrestrial and

marine fauna In the draft scoping report reference has been made with regards to the

terrestrial fauna but there is no attention to potential effects to marine fauna

Equally with regards to water usage where is the plant going to extract its waters used in

galvanization andor waste management process ie rainfall rivers or even from the sea)

and which avenues would be more environmental friendly and effective

Regards

Aphiwe Bewana

Marine Planner

South African National Parks

POBox 76693

NMMU

Port Elizabeth

6031

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 06 July 2011 1031 AM

To Lea September

Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Hi Lea

Irsquove reviewed the Final Scoping Report Herewith a few comments

1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the

Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a

revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the

NMBLP Please include only those in the IDZ as part of your IAP list

Regards

Andrea

From Lea September [mailtoleailisocom]

Sent Wednesday July 06 2011 859 AM

To Lea Septemberrsquo

Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Dear Stakeholder

The final scoping report for the above-mentioned project (attached) is available for comment

until 27 July 2011

The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic

commentaryrdquo tab

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 09 April 2012 1159 AM

To Lea September

Subject Comments on Galvanising Plant EIR Coega IDZ

Lea

Attached are my comments on the Draft EIR for the Coega IDZ galvanising

plant

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

Email attachment

COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ

Dr Paul Martin PO Box 61029

Bluewater Bay 6212 Tel 041 4665698

Email pmartinaxxesscoza

Compliance with CDC Permits amp Requirements

It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of

o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants

Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC

Air Emissions

Presumably permanent in stack monitoring will be required in terms of AEL permit requirements

Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions

Water

Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)

General

There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)

Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards

Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter

All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 11 April 2012 1245 PM

To Lea September

Subject Fw Comments on Galvanising Plant EIR Coega IDZ

Lea

One other comment on that I have on the Galvanising Plant Draft EIR

Hydrogen chloride is one of the main emissions There are no ambient air

quality guidelines for HCl and the EIR says concentrations will be well

within health parameters

However the main problem with HCl is its corrosive effect - there is

absolutely no mention of this in the draft EIR nor air specialist report

There needs to be some sort of comment assessment as to whether HCl

emissions are likely to impact on for example the adjacent Agni-Steel

Plant wrt corrosion - their factory structure will be made of steel

The EIR specialist rpt suggests monitoring HCl at ground level on the

property boundary and this is supported in case there are complaints from

neighbours

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Paul Martin ltpmartinaxxesscozagt

To Lea September ltleailisocomgt

Sent Monday April 09 2012 1158 AM

Subject Comments on Galvanising Plant EIR Coega IDZ

gt Lea

gt

gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising

gt plant

gt

gt

gt Dr Paul Martin

gt PO Box 61029

gt Bluewater Bay 6212

gt Tel 041 4665698

gt Cell 0732524111

gt email pmartinaxxesscoza

gt

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 12 April 2012 1139 AM

To Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Hi Lea

Hope yoursquore keeping well

I have requested comments from my colleagues and the CDC Casa team on the Draft EIR

Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report

Regards

Andrea

From Graham Taylor

Sent Thursday April 12 2012 838 AM

To Andrea Von Holdt Firhana Sam

Cc Johan Fourie Maria van Zyl Melikhaya Sihawu

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Andrea Firhana

Firhana if you could please ensure that the co-ordinates provided in the EIR correspond

with our records (pages 4-1 amp 4-2)

My comments are as follows

It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work

Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above

Regards

Graham Taylor

Spatial Development Manager - Infrastructure Development

Mobile 0832283055

Office 0414030454

Facsimile 0865185033

Email GrahamTaylorcoegacoza

Website wwwcoegacom

right PLACE | right TIME | right CHOICE

This email and all contents are subject to the following disclaimer

httpwwwcoegacomemaildisclaimerhtml

From Lea September [mailtoleailisocom]

Sent 04 May 2012 0411 PM

To Andrea Von Holdt

Cc Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Dear Andrea

We have taken note of the comments from the GIS Unit These issues have been rectified in

the final version of the EIR

Please can you forward to the relevant persons at the GIS Unit

Thank you

Best regards

Lea September

APPENDIX E

BACKGROUND INFORMATION

DOCUMENT

APPENDIX F

AIR QUALITY IMPACT ASSESSMENT

APPENDIX G

TRAFFIC IMPACT ASSESSMENT

APPENDIX H

WASTE MANAGEMENT AND HAZARDOUS

SUBSTANCES SPECIALIST STUDY

APPENDIX I

WATER QUALITY SPECIALIST STUDY

APPENDIX J

ENVIRONMENTAL MANAGEMENT

PROGRAMME

Page 11: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-1

1 INTRODUCTION

11 BACKGROUND

Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a

80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)

Nelson Mandela Bay Municipality Eastern Cape Province

The demand for galvanised steel products is high in South Africa and Africa and is

expected to increase in the foreseeable future From an economic point of view the

proposed project has therefore been found to be viable

Casa Steel will source the steel coils from various markets internationally and in

South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is

destined to be exported mainly to African countries

12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

An Environmental Impact Assessment (EIA) is required as the proposed project

involves several activities listed in terms of Section 24 of the National Environmental

Management Act (NEMA) No 107 of 1998 as amended and requires an

environmental authorisation

The following listed activities requiring environmental authorisation have been

identified

Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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 metres

Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped

land to industrial use greater than 1 ha but less than 20 ha in size outside an

urban area

Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any

process or activity requiring a license in terms of national or provincial legislation

governing the generation or release of emissions

Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5

hectares or more of vegetation where 75 or more of the vegetative cover

constitutes indigenous vegetation except where such removal of vegetation is

required for

(i) purposes of agriculture or afforestation inside areas identified in

spatial instruments adopted by the competent authority for

agriculture or afforestation purposes

(ii) the undertaking of a process or activity included in the list of waste

management activities published in terms of section 19 of the

National Environmental Management Waste Act 2008 (Act No 59

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-2

of 2008) in which case the activity is regarded to be excluded from

this list

(iii) the undertaking of a linear activity falling below the thresholds in

Notice 544 of 2010

Hot dip galvanizing is a listed activity in terms of section 21 of the National

Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires

an Atmospheric Emissions Licence (AEL)

In addition the treatment of wastewater with an annual throughput capacity of more

than 2000 m3 is a listed activity in terms of the National Environmental Management

Waste Act 59 of 2008 and requires a waste management licence

ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental

Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact

Assessment process in terms of section 24 of NEMA for the construction and

operation of the proposed galvanizing plant The EIA process covers all aspects of

the project and informs all three applications (for environmental authorisation waste

management licence and AEL)

13 PURPOSE OF THIS REPORT

This report builds on the scoping report submitted to the Eastern Cape Department of

Economic Development and Environmental Affairs (DEDEA) and the Nelson

Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It

describes the proposed project and presents the findings of the second phase of

investigations (EIA phase)

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT

PRACTITIONER (EAP)

The EIA was managed by Ms Terry Baker a certified Environmental Assessment

Practitioner with 20 years of working experience She has a MA in Environmental

Management and specialises in Environmental Impact Assessments and Project

Management She has been involved in a variety of different types of EIAs including

for water supply projects dams transmission lines roads and airports in South

Africa Botswana Uganda Lesotho and Mozambique She has been involved in

water resource management and public participation programmes on a number of

projects Terry has also been involved in the use of Geographic Information Systems

environmental status quo reports water quality assessments socio-economic and

institutional development projects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-3

15 PROJECT TEAM

In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen

(water quality specialist) and Lea September (EAP) with specialist input from Renee

von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous

substances) and Seniel Pillay (Traffic Impact Assessor)

The Business Unit Head of the ILISO Environmental Management Discipline Group

Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is

a Fellow of the South African Institution of Civil Engineers a member of the South

African Society of Aquatic Scientists of the Environmental Scientific Association of

the International Water Association of the Water Institute of South Africa and of the

Vaal River Catchment Association He is a certified Environmental Assessment

Practitioner with 30 years experience who specialises in project management

environmental impact assessments and water resource planning He specifically has

extensive experience in water quality especially water quality management water

quality monitoring and water quality assessment Martin has experience in managing

projects that involve multi-disciplinary teams and public consultation and

participation in South Africa and abroad

Lea September is an Environmental Assessment Practitioner with a Masters degree

in Environmental Management She has experience in impact assessment and

environmental management and has been responsible for drafting impact

assessment reports and Environmental Management Programmes and conducting

public participation processes as well as high level environmental screenings for a

variety of projects in the energy water transport and industrial sectors

Renee von Gruenewaldt has nine-years experience in the field of air pollution

impact assessment and air quality management Prior to becoming involved in air

quality consultation she was part of the Highveld Boundary Layer Wind Research

Group based at the University of Pretoria Since joining Environmental Management

Services (the company now Airshed Planning Professionals) she has undertaken

numerous air pollution impact studies and has provided extensive guidance to both

industry and government on air quality management practices

Pieter Smuts graduated as a Civil Engineer and became involved in the field of

municipal engineering and infrastructure construction He has specialized during the

last twelve years in solid waste management He has completed waste management

plans feasibility studies and final designs of waste management facilities in South

Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and

the review of the Mavoco hazardous waste landfill design in Maputo Mozambique

and completed a study on hazardous waste (textile factory sludge) management in

Maseru Lesotho

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-4

Seniel Pillay is a transportation engineer with over 16 years experience in

transportation planning and traffic engineering He has been involved in a wide

range of projects ranging from developing the Transport Operations Plan for the

FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System

for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller

traffic impact assessments for inter alia road improvement schemes Of particular

relevance to this project his experience includes Heavy Goods Vehicle Study for

eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact

Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash

Preliminary Transportation Assessment

16 STRUCTURE OF THIS REPORT

The proposed project and the alternatives considered are described in Chapter 2

Chapter 3 details the approach adopted for the EIA phase

The biophysical and socio-economic environment affected by the activity is described

in Chapter 4

The environmental impacts identified are discussed in Chapter 5

The EIA methodology is described in Chapter 6 and Chapter 7 presents the results

of the impact assessment

The environmental impact statement is presented in Chapter 8

Finally Chapter 9 spell out the conclusions and recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-1

2 DESCRIPTION OF THE PROPOSED PROJECT

21 TECHNICAL ASPECTS

211 The galvanizing process

Galvanizing consists of coating steel with zinc in order to protect it from corrosion

Before steel strips can be galvanized they undergo a pre-treatment in order to

ensure that the steel sheets are free from any surface oxides as they enter the

molten zinc coating Bath This is done by removing the oil from the steel sheets (in

the degreasing unit) and then removing the rust from the surface of the sheet (in the

pickling unit)

The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The

melting zinc on the strip surface will be cooled and solidified through air cooling in the

cooling tower

Finally the galvanised steel sheets are dipped into a water quenching tank in order to

further cool the sheets from about 150degC to 40degC

It is possible to make galvanised steel more durable by chromating it Approximately

50 of the galvanised steel production output will receive chromate passivation

treatment after quenching the galvanised steel sheets will be sprayed with a chrome

solution (3 kgcm2)

After galvanizing and chromating the steel sheets are cut to achieve the desired coil

size and weight and transported to the storage yard

The process flow diagram below (Figure 1) illustrates the main stages of the

galvanizing process and indicates the major inputs and outputs as well as the

resulting effluent and atmospheric emissions

Draft Environmenal Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-2

Figure 1 Process flow diagram for proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-3

212 Main inputs and outputs in operational phase

In view of the above the main inputs will be as follows

Steel coils 85 000 tonsyear

Zinc 870 tonsyear

Electricity 2500 kVA

Water 2000 m3month (of which 400 m3 will be potable water)

Liquid Natural Gas (LNG) 270 NM3hour

Sodium hydroxide (NaOH) 1000 m3year

Hydrochloric acid (HCl) 800 m3year

Chrome (Cr+3) 10 m3year

The main outputs will be

Galvanized steel 80 000 tonsyear

Scrap metal 20 tonsyear

General waste 65 tonsyear

Hazardous waste 2 m3month

Wastewater 012 Mlweek

Atmospheric emissions lt 5 ppm

213 Installations on site

The bulk of the operations involved in the galvanizing process occur along a

continuous galvanizing line (See Figure 2 below) which is the main piece of

machinery required for the proposed galvanising plant

Figure 2 Continuous Galvanizing Line

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-4

Water is one of the major inputs and is used throughout the galvanizing process notably

for rinsing and cooling purposes and as a mixing agent for the various chemical

solutions The plant will have a water treatment plant on site to treat the water used in

the various processes (approx 250 m3

of wastewater per week) The wastewater

treatment facility will be operated by a professional water treatment company as Casa

Steel does not have the required expertise in house to treat its process water Sulphuric

acid (H2SO4) is used as part of the treatment process to reduce caustic soda The

neutralised water is discharged to the sewer while any sludge is disposed of as

hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)

will be disposed of

Some critical areas of the galvanizing process such as the zinc pot require uninterrupted

power It is therefore proposed to install an LNG burner to maintain the zinc bath at a

temperature of between 450 and 460degC

22 LOCATION OF THE PROPOSED GALVANIZING PLANT

The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast

of Port Elizabeth in the Eastern Cape (Figure 3)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-5

Figure 3 Location of the proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-6

23 NEED AND DESIRABILITY

The profitability of the proposed project has been established by Casa Steel and a

pre-feasibility study has confirmed that the proposed project was feasible from a

technical and financial point of view The Coega IDZ is specifically designed to host

facilities such as a galvanizing plant and can provide the necessary infrastructure

and services to its investors It therefore constitutes a very suitable location for the

project

24 ALTERNATIVES IDENTIFIED

Zone 6 has been specifically earmarked for heavy ferrous metal industries and is

therefore a suitable location for the proposed galvanizing plant as such no site

alternatives have been provided for and assessed in this EIA However prior to the

commencement of the EIA process Casa Steel was presented with a number of

different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the

selection of the site were

(a) The dimensions of the land the site should be at least 200 m long and

50 m wide in order to accommodate the galvanizing line and adjacent lay

down area and additional land should be available next to the site for future

expansion

(b) The fiscal arrangements applying to the site the site should be located

within the future Custom Controlled Area (CCA) as the bulk of the

production output of the plant will be exported

The no-go alternative is assessed in this report

25 CONSTRUCTION ASPECTS

The construction phase of the project will take about 12 months and will essentially

consist of erecting a building to house the galvanizing line and other equipment and

preparing a concrete laydown area adjacent to the building

The CDC will provide an access point from the existing tarred road that will lead to

the site

Approximately 100 workers from the surrounding areas will be contracted for the

construction work

The requirements in terms of services during construction are listed below

Water 1000 m3month

Electricity 2500 kVA

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-7

The CDC will provide temporary services for the construction phase including a

conservancy tank for flush toilets Sewage infrastructure will only be provided for the

operational phase

26 OPERATION ASPECTS

Before the plant can become fully operational the equipment and machinery will be

tested for approximately 3 months The supplier will supervise these tests as part of

the transfer of know-how and training of staff on the plant

Casa Steel will start operating the plant at a reduced capacity (about 50 000

tonsyear) for a period of time (mostly determined by market aspects) before bringing

production to full capacity (80 000 tonsyear) This is done by operating the line for

longer hours

Approximately 50 to 60 people will be working on the plant Approximately 6-10 of

these will be unskilled 40-45 skilled and about 5 people in managerial positions

The requirements in terms of services during operation are as follows

Water 2000 m3month

Electricity 2500 kVA

Effluent discharge 24 m3day

The CDC has entered into agreements with the municipality to secure the provision

of services such as water and electricity to its tenants Tenants in the IDZ have their

own agreements with the NMBM for electricity while the agreements for water and

sewage are with the Facilities Unit of the CDC

Regarding discharge of wastewater to the sewer the municipality indicated that the

only requirement is that the water discharged complies with applicable municipal

discharge standards

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 3-1

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT

31 OBJECTIVES

The main objectives of the EIA phase are to

Assess the significance of the environmental issues and impacts identified in the

scoping phase focusing on key impacts

Recommend appropriate measures to mitigate negative impacts and enhance the

benefits and include them in the draft EMP

Undertake a public participation process that provides opportunities for all

interested and affected parties (IampAPs) to be involved

32 AUTHORITY CONSULTATION

The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental

Liaison Committeersquo (ELC) which comprises representatives of various authorities

including DEDEAT the Department of Environmental Affairs (DEA) and Department

of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the

Coega Development Corporation (CDC) and Transnet National Ports Authority

(TNPA) The ELC has been specifically formed to facilitate EIA applications in the

IDZ

Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to

the clearance of vegetation should be included in the application A formal request

was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the

application and all registered stakeholders were informed of the request in writing on

19 October 2011

33 PUBLIC PARTICIPATION PROCESS CONDUCTED

On-site notices were replaced by a notification displayed on the CDCrsquos digital notice

board at the business centre in Zone 1 of the IDZ The eNotice was placed on

13 April 2011 and will remain for the full duration of the EIA process

Registered stakeholders will be notified in writing of the availability of the draft EIA

report and EMP which will also be advertised in a local newspaper Stakeholders

including state departments and the public will have forty (40) days to comment on

the draft EIA report and EMP The draft EIA report and EMP will be sent by email

where possible and made available for download on the ILISO website

(wwwilisocom)

A summary of all issues and comments received during the stakeholder consultation

process as well as of correspondence in that regard will be captured in an Issues

and Responses Report that will form an Appendix to the EIA Report

The list of registered IampAPs is included in Appendix A

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 3-2

34 LEGISLATION AND GUIDELINES CONSIDERED

The following legislation and guidelines were considered in the preparation of this

report

National Environmental Management Act Act No 107 of 1998

NEMA EIA Regulations 2010

National Environmental Management Air Quality Act Act No 39 of 2004

National Environmental Management Waste Act Act No 59 of 2008

Hazardous Substances Act Act 15 of 1993

Occupational Health and Safety Act Act 85 of 1993

Hazardous Chemical Substances Regulations 1995 (GNR 1179)

Major Hazard Installation Regulations 2001 (GNR 692)

National Water Act Act 36 of 1998

National Heritage Resources Act Act 25 of 1999

DEAT Integrated Environmental Management Information Series 1-5 and 12-15

NEMA draft Implementation Guideline

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Public Participation (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Alternatives (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Draft Guideline for Determining the Scope of Specialist

Involvement in EIA Processes (2005)

IAIA guidelines

National air quality standard for thoracic particulates Government Gazette

No 32816

Listed activities and associated minimum standards identified in terms of section

21 of the National Environmental Management Air Quality Act Act No 39 of

2004 Government Notice 248 of 2009

Minimum Requirements for the Handling Classification and Disposal of

Hazardous Waste DWAF Waste Management Series (1998)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-1

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION

The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega

IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay

to the north of the N2 highway between Port Elizabeth and Grahamstown east of the

Coega River

The co-ordinates of the corners of the site are shown in Table 1

Table 1 Coordinates of site corners for the proposed galvanizing plant

Point Longitude Latitude

A 25deg411126E 33deg45587S

B 25deg411156E 33deg45499S

C 25deg411938E 33deg45131S

D 25deg412174E 33deg45481S

E 25deg412508E 33deg45979S

F 25deg412634E 33deg451160S

G 25deg411782E 33deg451560S

H 25deg411692E 33deg451428S

J 25deg411314E 33deg45868S

Figure 4 Zone layout in the Coega IDZ

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-2

Figure 5 Site location

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-3

42 SOCIO-ECONOMIC CHARACTERISTICS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the

NMBM There are no residents within the IDZ

As far as the broader NMBM and Eastern Cape Province are concerned the

following can be noted The NMBM is located within the Eastern Cape Province the

2nd largest Province in South Africa (3rd in terms of population) characterised by a

predominantly black population with low incomes and high levels of unemployment

(CES 2010)

The NMBM has a population of just above 11 million and covers an area of

1 950 km2 It is the main urban and industrial centre of the province and Port

Elizabeth in particular which forms part of the NMBM is the commercial capital of

the Eastern Cape 52 of the NMBM population is female and 37 is below the

age of 20 these two groups are particularly affected by unemployment

43 BIOPHYSICAL CHARACTERISTICS

431 Surface and ground water

No rivers occur in Zone 6 There is however a natural attenuation pond on the

southern most part of the site which will have to be avoided

The IDZ is underlain by calcrete sand and gravel deposits that overlie low

permeability clays These clays limit the vertical infiltration of rainwater and induce a

horizontal groundwater flow towards the Coega River channel which is the most

significant surface water feature in the Coega IDZ Consequently rapid run-off takes

place following precipitation (Jacobs 2008)

Groundwater levels at Coega are generally about 3 to 5 m below surface ie just

above the contact between the permeable sands and the underlying impermeable

clays The groundwater flow direction is to the southeast following the surface water

drainage direction (Jacobs 2008)

432 Climate and atmospheric conditions

Port Elizabeth has a warm temperate climate and the temperature ranges are not

extreme Exceptionally high temperatures may be experienced during berg wind

conditions which occur frequently during autumn and winter Extreme temperatures

also occur during summer with little accompanying wind

The wind regime for the area largely reflects the synoptic scale circulation with

dominant westerly and northwesterly flow fields representing the pre-frontal

conditions and south-westerly flow fields representing the frontal conditions The

south-easterly and south-westerly wind flow (land breeze) increases during daytime

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-4

conditions with westerly and north-westerly wind flow increasing during the night (sea

breeze)

The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of

Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15

km southwest) and Port Elizabeth (~23 km southwest)

An ambient air monitoring network has been established in the Coega IDZ which

consists of three monitors Saltworks Motherwell and Amsterdamplein Although

NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative

impacts due to the proposed Galvanising Plant is PM10 A maximum daily average

PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed

SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3

was exceeded on 17 days in 2007 and 26 days in 2008

Existing sources of emissions in the vicinity of the proposed galvanizing plant include

industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other

fugitive dust sources (von Gruenewaldt 2011b)

433 Geology and soils

Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel

and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly

limestone and conglomerate

434 Terrestrial ecology

This section draws from the EIA report compiled for the Agni Steel (formerly Afro-

Asia) steel processing facility which is adjacent to the proposed site for the

galvanizing plant (Jacobs 2008)

The area consists largely of grasses succulents and scrubby bush with alien

species making up the greater part of the more dense vegetation

Zone 6 falls within the inland vegetation and is characterised by a vegetation type

referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the

Coega IDZ and has been found to have three times the level of endemism of other

vegetation communities in the Coega IDZ Bontveld therefore has a high

conservation status Two Bontveld conservation areas have been identified within the

IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)

Bontveld that will be destroyed as a result of development in the IDZ will be given

conservation status in these two areas

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-5

Figure 6 Coega IDZ Open Space Management Plan (OSMP)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-6

Certain areas in the IDZ are invaded by alien plant species The most common

invader species is rooikrans (Acacia cyclops) which presently forms large

monospecific stands in areas throughout the Coega IDZ There are several other

aliens present that pose a threat to the flora of this area including the prickly pear

(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)

Loss of vegetation and alien plant invasion due to human activity has resulted in a

reduction in the diversity of terrestrial fauna

The majority of mammals present in the Coega IDZ are small or medium-sized Of

the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed

gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of

Algoa Bay however it is not considered threatened The gerbil is common in

foredune and dune thicket habitat in the Coega region and is therefore unlikely to

occur on the proposed site

A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird

species are resident or common to the area Most diversity occurs in the thicket

although the coastal area also supports specialised avifauna Two species of tern

the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well

as the Cape gannet (Morus capensis) and the African penguin (Spheniscus

demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne

caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant

(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser

flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns

are two of the most endangered coastal species in South Africa Other bird species

of conservation concern include the Whitefronted plover (Charadrius marginatus)

African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus

bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus

ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides

paradisea) Breeding pairs of Damara terns and African black oyster catchers have

been observed in the coastal dunes of the IDZ but should not be affected by

developments that fall outside the dune areas

The Eastern Cape supports nearly a third (approximately 133 species) of the reptile

species recorded in South Africa More than half of the Eastern Capersquos endemic

reptile species occur in the Algoa Bay area giving the region a high conservation

value A total of 63 reptile species are believed to occur within the Coega IDZ The

majority of these are found in Succulent Thicket and riverine habitats Only a few

reptile species occur in the coastal dunes and estuarine habitats More than a third of

the species are described as relatively tolerant of disturbed environments provided

that migration corridors of suitable habitat are maintained to link pristine habitats

Twenty two reptiles are of special concern including five endemic species (two of

which may also be endangered) four endangered sea turtles eight species listed

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-7

with CITES one rare species and four species at the periphery of their range

Fourteen of these species of special concern are confirmed as occurring on or within

2 km of the Coega IDZ

A total of 32 amphibian species and sub-species occur in the Eastern Cape

representing almost a third of the species recorded in South Africa However none of

the species are endemic or Red Data Book species Based on previous studies in the

area it is estimated that approximately 17 amphibian species occur within the Coega

IDZ Four species are listed as peripheral but none are threatened internationally

These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog

(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and

the bubbling kassina (Kassina senegalensis)

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated

vegetation has not been extensively studied One grasshopper species Acrotylos

hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue

(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis

pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in

four localities in the Eastern Cape one of which is within the Coega IDZ The Coega

copper Aloeides clarki is endemic to this particular region of the Eastern Cape and

is currently known to occur in three localities two of which are in the Coega IDZ The

localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the

Coega IDZ and their distributions were taken into account when defining Coegarsquos

open space system and Development Framework Plan

435 Land use and topography

The land is currently undeveloped and earmarked for industrial development The

site is relatively flat ranging from an elevation of 66 masl on the northern-most

corner to 59 masl at the southern-most corner

436 Heritage and archaeological survey

Extensive studies have been undertaken in Zone 6 with respect to heritage aspects

Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a

2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond

2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is

currently being finalised

Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing

Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha

in extent and was located next to the R102 road to Motherwell Kaplan conducted

HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi

Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will

now be located in Zone 5)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-8

The various archaeological investigations reached similar observations and

conclusions Stone tools of various densities and types were found throughout the

zone The majority of the stone tools were mainly of Earlier and Middle Stone Age

and occasional Later Stone Age origins (Figure 4)

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble

gravels exposed by tracks in Zone 6 (Source Binneman 2010)

The stone tools which comprised of quartzite flakes chunks flaked pebblecobble

and cores were randomly distributed across the landscape and are in secondary

context There were no lsquoconcentrationsrsquo of tools observed which suggested any

spatial patterning or activity areas although these may be present or covered by soil

and vegetation

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 5-1

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED

The following environmental issues and potential impacts were identified in the

Scoping phase

51 AIR QUALITY

The galvanizing process generates atmospheric emissions with particulates and

hydrogen chloride representing the main pollutants of concern The plant is fitted with

air extraction as well as scrubber systems which are designed to retain the bulk of

pollutants and particles for each of the processes in such a way that less than 5 ppm

of gases and particles will be released into the atmosphere after the fume scrubber

Other sources of impact on air quality include emissions from the LNG burner as well

as emissions and dust from the transport of steel and other materials in trucks

Construction activities will also create dust and gas emissions due to the clearing of

groundcover tipping of material to storage pile levelling of area wind erosion from

storage piles vehicle and construction equipment activity and tailpipe emissions

from vehicles and construction equipment such as graders scrapers and dozers

Overall the air quality impact assessment (Gruenewaldt 2011b) found that

The predicted particulate oxides of nitrogen carbon monoxide and sulphur

dioxide concentrations are all below the National Ambient Air Quality Standards

for all averaging periods

The predicted off-site concentrations of hydrogen chloride are well below the

most stringent effect screening levels

No odour threshold exceedances for hydrogen chloride were predicted to occur

due to routine operations at the Steel Galvanising Plant The South Wales

Environmental Protection Authority stipulates that an odour unit of 20 is

acceptable for urban areas The odour unit would be lt10 directly off-site for

hydrogen chloride

Abnormal emissions can occur in exceptional circumstances Start-up will not

cause abnormal emissions as the scrubbers will be commissioned first and will be

functioning once the plant starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions would be emitted as a

building fugitive

The hourly hydrogen chloride ground level concentrations (directly offsite) were

predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based

on the emission limits as stipulated for listed activities for galvanising processes)

using a screen model which assumes worst case meteorological conditions The

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-2

health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming

abnormal emissions emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset conditions will still

be well within the health effect screening levels

Similarly the hourly particulate emissions from the building fugitives during upset

conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for

listed activities for galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly

off-site

Therefore if emissions are 5 times higher normal they will still be within health effect

screening levels and the daily PM10 NAAQS levels

In the case of a fire a cocktail of gases and particulates could be emitted and could

be over the recommended levels This situation will however be dealt with as an

emergency and normalised as quickly as is possible

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS

The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of

its heritage potential and there are no proposed protected geosites in Zone 6

Should any artefacts be discovered during construction procedures stipulated in the

draft EMP will apply

53 BIODIVERSITY AND CONSERVATION

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

In terms of terrestrial fauna the CDCrsquos open space management plan provides for

the preservation of certain corridors The destruction of certain habitats as a result of

the development will therefore not automatically result in the loss of certain species

54 WATER QUALITY

There is a natural attenuation pond on the southern most part of the site which will be

avoided

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through

spills or leaks

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-3

This risk can however be minimized if not avoided altogether The floor of the factory

will be designed as a bunded area to contain any spills and the entire process will be

contained Potential spills or leaks will therefore be contained and will not impact on

water resources Storm water is therefore considered clean water under normal

operational conditions An oil trap will be placed at the exit of the site to ensure that

no grease from the laydown area enters the stormwater system

Spills and leaks can occur during the handling or the transport of hazardous

substances Best practice guidelines will be followed to ensure that this risk is

adequately managed

Wastewater discharged to sewer will be treated to comply with municipal discharge

standards and is not expected to have an impact on the chemical characteristics of

the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be

discharged from the plant is small in relation to the total volume received at the

Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works

(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently

operated at 61 of its capacity which is approximately 80 Mℓday Thus the

0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore

not have any significant impact on the WWTW

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES

The plant will generate a relatively small amount of solid waste in the form of scrap

metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)

The scrap metal may be sold to other steel processing facilities such as Agni Steel

which will be located next to the plant or collected and disposed of with the rest of

the solid waste by a licensed service provider

As mentioned previously there will be a wastewater treatment plant on site which will

neutralise process water (012 Mlweek) in order to ensure it is of a standard

acceptable for discharge to sewer Waste in the form of sludge from the

neutralization or spent acid must be disposed of as a hazardous waste Solid waste

from the filters used for air quality control is also in this category These wastes can

usually be tested and then delisted which means that it can be placed in a general

purpose landfill

Hazardous effluent from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-

site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored

and removed on a monthly basis is limited to 10 m3

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-4

A number of substances classified as hazardous are used in the galvanizing process

(Table 2) and the transport and handling of these is subject to certain rules and

guidelines In particular the material safety data sheets (cf Appendix H) should be

referred to for inter alia hazards identification accidental release measures

handling and storage precautions exposure controlpersonal protection ecological

information and transport information The Hazardous Chemical Substances

Regulations 1995 should also be adhered to in respect of the transport and storage

of hazardous chemical substances

Table 2 Hazardous materials to be used on site

Major Input Materials

Substance

listed in the

SABS 0228

Group II

hazardous

substances

Volumes to be

stored on site at

any one time

Diesel radic 2000 litres

Liquid petroleum radic 20 000 liters

Sodium hydroxide (NaOH)

(used for degreasing) 8 radic 1000m

3

Hydrochloric acid (HCI)

(used for pickling) 8 radic 800m

3

Zinc (used for galvanising) - TBD

Trivalent chromium (CR+3

)

(used for chromating) 8 radic 10m

3

Sulphuric acid (H2SO4) (used for

treatment of waste water on site) 8 radic TBD

Ammonium Hydroxide (NH4OH) 8 radic TBD

TBD ndash To be determined

Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one

time) and is classified as a flammable substance Specification for flammable storage

facilities in accordance with the requirements of the Nelson Mandela Bay

Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for

quantities between 5000 and 20 000 liters the substance must be kept in a

flammable liquid store which complies with the requirements of a specification

obtainable from the Department Some of the requirements are

Flammable liquid and solid storage facilities are only permitted on the ground

floor

Decanting of flammable liquids and solids are not permitted within any building

Due to the fact that there are flammable materials on site a certificate may be

required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and

Emergency Services Department to confirm that facilities for flammable storage

are in accordance with their requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-5

Because of the permanent installation and high quantity of liquid petroleum on site

the Major Hazard Installation Regulations 2001 promulgated under the Occupational

Health and Safety Act No 85 of 1993 applies A written application for approval of

the installation is required to be submitted to the chief inspector Department of

Labour provincial director Department of Labour and NMBM prior to construction

In addition a risk assessment should be formulated covering all hazardous materials

together with an emergency preparedness and response plan

56 HEALTH AND SAFETY

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling instructions as well as occupational exposure limits

are indicated in the material safety data sheets of the various substances used

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as

provide site supervision including executing tests (individual test cold run and hot

run) during 3 months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the

EMP

In addition the emergency preparedness and response plan will cover the health and

safety aspects related to emergency situations

57 TRAFFIC

The volumes of traffic at the IDZ are currently relatively low and variable depending

on the different zones in the IDZ however these volumes will increase as more

developments are implemented

The construction phase of the Casa Steel development will take about 12 months

and will essentially consist of erecting a building to house the galvanizing line and

other equipment and preparing a concrete laydown area adjacent to the building

The traffic that would be generated during the construction phase can be expected to

be less than the traffic that would be generated by the Casa Steel development when

it is fully operational

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-6

In the operation phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and

from the Port of Ngqura

The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the

Casa Steel development would be off Ring Road 1 The other roads of significance

for the Casa Steel development are the N2 Neptune Road MR435 and MR450

Access to the port is given by Neptune Road Road Link NEP-03 has not yet been

built

Figure 8 Coega IDZ road network identification

(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-7

Figure 9 Coega IDZ road network

Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No

01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-8

The distribution of freight trips is fixed as the majority of trips will be made between

the Port of Ngqura and the Casa Steel site With regard to personnel trips there are

various points of origins (the surrounding residential areas) that could be used by

staff going to the Casa Steel site The distribution of personnel trips is based on

existing traffic count information and is shown in Figure 10

Figure 10 Trip distribution for freight and personnel trips

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The resultant expected Casa Steel traffic assignment is shown in Figure 11

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-9

Figure 11 Morning peak hour Casa Steel development traffic

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The traffic that is expected to be generated by the Casa Steel development is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low

and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)

Consultation has taken place with Transnet Port Authority (TPA) to establish the

impact of the galvanizing plant operations on traffic inside the port The additional

ships entering and exiting the port of Ngqura as a result of the proposed development

will have a negligible impact on port traffic and TPA indicated that it would be well

within the portrsquos capacity

58 NOISE

Noise is not foreseen to be a significant issue insofar as the noise levels inside the

plant and at the boundary of the site will not exceed the limits prescribed by the CDC

Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels

during the day and 60 decibels at night

Mitigation of noise impacts will be addressed in the design of the noise-emitting

components of the plant and their enclosures

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-10

59 SOCIO-ECONOMIC ASPECTS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of

NMBM There are no residents within the IDZ

The direct socio-economic impacts of the proposed project are thus limited to the

employment generated by the project during construction and operation Job creation

remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)

and the IDZ and Port of Ngqura are expected to become a significant catalyst to the

economic growth of the Municipality and the region with current investments at

Coega creating more jobs and stimulating the economy

In this context the proposed galvanizing plant will make a positive contribution

towards the achievement of these goals

There will be 50 to 60 employees during operation phase distributed as follows

Figure 12 Casa Steel organisation chart

Even though a large part of the inputs will be imported and the bulk of the production

output will be exported there will be some positive impacts for the economy of the

region and of South Africa in general Notably the requirements of the plant for

water electricity waste collection and disposal waste water treatment and transport

for example will create business for the various service providers and have an

indirect impact on employment and fiscal revenues as a result

From a visual impact point of view it can be anticipated that the landscape in the IDZ

will be significantly affected over time by developments related to the establishment

of the port and various industries

HEAD ( WORKS )

MGR ( COMM) MGR ( ADMNHR ) Manager marketing

MANAGER OPERATION MANAGER MANAGER MANAGER Q C

AC FIN PUR ampSTORE

PPC SH-GALV SH-tech

SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF

1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO

JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF

2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO

WORKERS WORKERS 7NOS

15 7

RAW MAT amp

DESP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 6-1

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY

A description of the nature of the impact any specific legal requirements and the

stage (constructiondecommissioning or operation) will be given Impacts are

considered to be the same during construction and decommissioning The

significance of the potential impacts will be considered before and after identified

mitigation is implemented

The following criteria will be used to evaluate significance

Nature The nature of the impact will be classified as positive or negative and

direct or indirect

Extent and location Magnitude of the impact and is classified as

Local the impacted area is only at the site ndash the actual extent of the activity

Regional the impacted area extends to the surrounding immediate and

neighbouring properties

National the impact can be considered to be of national importance

Duration This measures the lifetime of the impact and is classified as

o Short term the impact will be for 0 ndash 3 years or only last for the period of

construction

o Medium term three to ten years

o Long term longer than 10 years or the impact will continue for the entire

operational lifetime of the project

o Permanent this applies to the impact that will remain after the operational

lifetime of the project

Intensity This is the degree to which the project affects or changes the

environment and is classified as

o Low the change is slight and often not noticeable and the natural functioning

of the environment is not affected

o Medium The environment is remarkably altered but still functions in a

modified way

o High Functioning of the affected environment is disturbed and can cease

Probability This is the likelihood or the chances that the impact will occur and

is classified as

o Low during the normal operation of the project no impacts are expected

o Medium the impact is likely to occur if extra care is not taken to mitigate

them

o High the environment will be affected irrespectively in some cases such

impact can be reduced

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 6-2

Confidence This is the level knowledgeinformation the environmental impact

practitioner or a specialist had in hisher judgement and is rated as

o Low the judgement is based on intuition and not on knowledge or

information

o Medium common sense and general knowledge informs the decision

o High Scientific and or proven information has been used to give such a

judgment

Significance Based on the above criteria the significance of issues will be

determined This is the importance of the impact in terms of physical extent and

time scale and is rated as

o Low the impacts are less important

o Medium the impacts are important and require attention mitigation is

required to reduce the negative impacts

o High the impacts are of great importance Mitigation is therefore crucial

Cumulative Impacts The possible cumulative impacts will also be considered

Mitigation Mitigation for significant issues is incorporated into the EMP for

construction

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 7-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS

71 IMPACTS DURING CONSTRUCTION

711 Air quality

Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris

handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine

particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural

operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks

and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)

Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Fugitive particulate emissions (dust)

related to construction activities Regional

Short

term Medium High High Medium Regional

Short

term Low High High Low

Construction vehicle gas emissions Regional Short

term Medium High High Medium Regional

Short

term Low High High Low

712 Heritage and archaeological resources

Naturedescription of impact excavation activities may impact on unidentified heritage resources

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-2

Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based

on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments

Heritage and archaeological

resources Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on unidentified heritage

resources Local

Short

term

Medium -

high Low High Low

713 Biodiversity and conservation

Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation

importance and cause soil contamination

Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species

Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan

and has compiled a list of protected species to be rescued (see draft EMP)

Biodiversity and conservation Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Loss of fauna and flora Local Perma

nent

Medium -

high High High High Local

Permanen

t Medium High High Medium

Soil contamination Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-3

714 Water related impacts

Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater

runoff spills and leaks Soil erosion

Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of

spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste

disposal Stormwater quality monitoring (see draft EMP)

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Soil erosion Local Short

term Medium Medium High Medium Local

Short

term Medium Low High Low

715 Waste management

Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed

Commentmitigation see draft EMP and waste management plan

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-4

Waste management Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Local

Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

716 Health and safety

Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Short

term

Medium -

high

Medium -

high High High Local

Short

term

Medium -

high Low High Low

717 Traffic

Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and

construction workers from surrounding areas and transport of equipment from the port

Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low

Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and

accurate estimates of quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-5

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Increased traffic on N2 and within the

IDZ Regional

Short

term Low High High Low

718 Noise

Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Short

term

Medium-

high High High Medium Local

Short

term Medium High High Medium

719 Socio-economic

Naturedescription of impact temporary employment will be created during the construction phase

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-6

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Temporary employment Regional Short

term Medium High High Medium

72 IMPACTS DURING OPERATION

721 Air quality

NatureDescription of impact gas and particulate emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning

Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local

sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and

veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute

to background fine particulate concentrations (von Gruenewaldt 2011b)

Assumptions and limitations Potential release of CR6+

As no emission factors are available for trivalent chromium processing the

potential impacts due to these activities could not be quantified

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Dust emitted from traffic on paved roads Regional Long Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-7

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

term

Hydrogen chloride emissions from

pickling process Local

Long

term Low High High Low

Particulate emissions (smoke) from

galvanizing process (due to the

volatilization of flux)

Local Long

term Low High High Low

Particulate oxides of nitrogen carbon

monoxide and sulphur dioxide emissions

from LNG burner

Local Long

term Low High High Low

Nuisance related to odour Local Long

term Low Low High Low

Abnormally high hydrogen chloride and

particulate emissions due to scrubber

malfunction

Local Short

term Medium Low High Medium

Gases (eg SOx NOx CO etc) and

smoke emitted in case of a fire Local

Short

term High Low High Medium

722 Water quality

NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks

Commentmitigation see draft EMP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-8

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Stormwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

723 Waste management and hazardous substances

NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous

waste both can affect environmental quality and human health

Commentmitigation see draft EMP and waste management plan

Waste management and hazardous

substances Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Regional

Long

term High

Medium -

high High High Regional Long term High Low High Low

Soilwaterair pollution due to improper

transport storage and handling of

hazardous substances

Regional Long

term High

Medium -

high High High Regional Long term High Low High Low

Health hazard Local Long

term High

Medium -

high High High Local Long term High Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-9

724 Health and safety

Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Long

term

Medium-

high

Medium-

high High High Local Long term

Medium-

high Low High Low

725 Traffic

Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on

the road network

Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak

hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road

network within Zone 6 of the IDZ (Iliso 2011)

Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)

Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of

quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-10

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on traffic and capacity of the N2 Regional Long

term Low High High Low

Impact on traffic and capacity of ring

road 1 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR435 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR450 Local

Long

term Low High High Low

Impact on traffic and capacity of

Neptune road Local

Long

term Low High High Low

726 Noise

Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Long

term Medium High High Medium Local Long term Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-11

727 Socio-economic

Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate

revenue for the municipality and the region as a whole

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Employment and economic growth Regional Short

term Medium High High Medium

73 COMPARATIVE ASSESSMENT OF IMPACTS

During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as

low during operation after mitigation

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 8-1

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

As a tenant operating in the IDZ Casa Steel will be required to comply with all

current and future CDC requirements as well as with the relevant conditions of

permits licences issued to CDC (eg Integrated Stormwater Masterplan for the

eastern side of the Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)

In particular the CDC has its own requirements regarding the monitoring of certain

aspects of the project such as the quality of the effluent and the noise levels These

have been incorporated into the EMP

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 9-1

9 ENVIRONMENTAL IMPACT STATEMENT

All predicted negative impacts can be mitigated to a low significance The only

exceptions are biodiversity as the construction of the plant will result in the

destruction of habitat and loss of fauna and flora and noise impacts inherent to

construction activities Mitigation measures have been included in the EMP for these

impacts and they have a medium significance post-mitigation

Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium to

long term similar impacts are likely to occur due to ongoing developments in the IDZ

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 10-1

10 CONCLUSION AND RECOMMENDATIONS

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as

other infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified

and assessed No fatal flaws have been identified

It is recommended that the project be approved subject to the conditions listed in

chapter 9 and adherence to the EMP requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 11-1

11 REFERENCES

Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ

Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants

Bennie JS (2010) The historical component (built environment) of the Heritage

Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port

Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report

compiled for Eastern Cape Heritage Consultants

Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater

Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay

Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage

Consultants

BKS (2006) Coega Industrial Development Zone Transport Study Volume 3

Demand Modelling Report Final Draft

Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I

Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6

Report compiled for SRK Consulting

Coastal amp Environmental Services (2010) Environmental Impact Assessment for the

Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone

Volume 3 Environmental Impact Assessment Report CES Grahamstown

Coega Development Corporation (2008) Industry Waste Management Plan -

Strategic Master Plan Report

Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants

Report No CDCSHE 03 8122

Department of Water Affairs and Forestry (1998) Waste Management Series

ldquoMinimum Requirements For The Handling Classification And Disposal Of

Hazardous Wasterdquo Second Edition

Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising

Plant in the Coega Industrial Development Zone

Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the

Coega Industrial Development Zone (IDZ) Specialist Water Study

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 11-2

Jacobs E (2008) Final Environmental Impact Report and Draft Environmental

Management Plan Proposed Steel Recycling and Processing Facility within the

Coega IDZ Report compiled for SRK Consulting

Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY

Galvanising Plant in the Coega Industrial Development Zone Waste Management

and Hazardous Substances Report compiled for ILISO Consulting

RSA National air quality standard for thoracic particulates (PM10) SA standards

(Government Gazette No 32816)

von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed

Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape

Report compiled for ILISO Consulting

von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel

Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report

compiled for ILISO Consulting

Additional sources

Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed

Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared

for Coastal Environmental Services

Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed

Kalagadi Manganese smelter in the Coega Industrial Development Zone Port

Elizabeth Eastern Cape Province Report prepared for Coastal Environmental

Services

Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia

steel recycling facility at the Coega Industrial Development Area Port Elizabeth

Prepared for SRK Consulting Port Elizabeth

APPENDIX A

LIST OF INTERESTED AND

AFFECTED PARTIES

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

DEDEARegional Manager

and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza

DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza

DEA Ocean and

CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza

DEA Ocean and

Coast

Oceanographer land-

based sources of

marine pollution

Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza

DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza

CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza

CDCEnvironmental

Project

Manager

Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza

TNPAPort of Ngqura

Environmental

Manager

Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet

NMBMEnvironmental

ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza

NMBMEnvironmental

ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza

DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza

DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza

WESSASenior Conservation

Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza

Zwartkops

ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700

hughlauegmailcom

zwartkopstrustiafricacom

SANParksNational Marine

CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza

Department Of

LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza

NMBM Air Quality

Division

Assistant

DirectorAir

Pollution and Noise

Templeton Titima 079 490 0574 Ttitimamandelametrogovza

NMBM Air Quality

DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza

NUMSARegional

RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

Department of

HealthNadiema

van der

Bergh083 378 2103

nadiemavanderberghimpiloecprovgov

za

DWA Chief Services

Officer

Joseph Jacobs 041 586 4884 jjacobsdwafgovza

EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza

NUMSecretary of union

officesZandile Xhentsa 043 743 6597 zxhentsanumorgza

DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza

Dynamic

CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom

EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza

Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza

UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom

lprincezago2uticom

Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza

Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza

Absa Mr Johann Steyn 082 3775820 johannstabsacoza

Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza

PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza

Universal

EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza

Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza

GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom

Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza

NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom

DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza

DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza

TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet

DWA Mr Landile Jack JackLdwagovza

DWA Ms Lizna Fourie FourieL4dwagovza

APPENDIX B

NOTICE OF ATMOSPHERIC

EMISSIONS LICENCE APPLICATION

AND ADVERTISEMENT

APPENDIX C

NOTICE OF COMMENT PERIOD FOR

DRAFT SCOPING REPORT

APPENDIX D

SUMMARY OF ISSUES RAISED AND

RESPONSES THERETO

April 2012

1

PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL

DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))

IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt

AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt

This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses

provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process

conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the

Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

2

IssueCommentQuestion Date

received Origin Response

1 Please provide more information with respect to the potential

dangers including the toxicity of the proposed project

07032011

By email

Wayne Poulton

(Bosun Brick

tenant at the

IDZ)

An Environmental Impact Assessment (EIA) was undertaken

which assessed the potential toxicity of the emissions and

effluent Mitigation measures were also recommended in the draft

Environmental Management Programme (EMP) to avoid

minimise or compensate any significant impacts The Draft

Environmental Impact Report and draft EMP were made available

to stakeholders for comment in March 2012

2 Do you have a Background Information Document (BID) or

similar that provides more information on the project

27032011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The BID was sent to all registered IampAPs on 4 May 2011

3 The RoD issued to the CDC on 632007 for the change in

land use for the remaining area of the Coega IDZ includes a

number of requirements with respect to

atmospheric emissions that should be considered in the

Atmospheric Emissions Licence (AEL) application such as

prohibiting and monitoring where possible visible emission

plumes to the atmosphere In particular the

recommendations on pp87-91 of the final revised Scoping

Report dated Nov 2006 must be implemented (clause 421)

04042011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

We have obtained copies of the documents referred to and ensure

that these requirements were taken into account in the

environmental assessment and AEL application

4 If the Port of Ngqura is used for import and export the scope

of the traffic impact assessment (TIA) should also include the

port

10052011

By email

Elliot

Motsoahole

(TNPA Port of

Ngqura)

The scope of the TIA was extended to include port related traffic

The TNPA at the Port of Ngqura was consulted and does not

have any objection to the project TNPA has indicated that the

development would require a minimum number of vessels per

year which would have minimal impact on the Port operations

However due notice would have to be given to the Port of Ngqura

before a vessel is scheduled to arrive so that the vessel can be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

3

IssueCommentQuestion Date

received Origin Response

accommodated at an available berth

5 Concerns with respect to potential stormwater pollution

draining into the Coega catchment and the port of Ngqura

The port needs to be dredged and heavy metals present a

risk in that regard

16052011

By

telephone

Andrew Lucas

(Department of

Water Affairs)

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination by effluent waste or

hazardousdangerous substances is very low

Thus no metals oils or other contaminants are expected to be

present in the stormwater

However stormwater pollution can occur in exceptional

circumstances such as accidents and emergencies The

emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

6 All steel sheets bathing unit must be under roof

7 The sludge out of the decreasing bath will be high in Na and

pH Therefore handling and disposal must be clarified up front

in this project

8 Per se the wastewater from decreasing bath will have high

ph and the component from the pickling unit will have low ph

Then it may be assumed that both streams will neutralize

each other Please then clarify proposed sewer discharge

with Nelson Mandela Bay Municipality up-front for acceptance

of influent as per the documented proposal

9 Pickling may result in dissolved metals How does your team

expect to deal with this As it is planned for discharge into

24052011

By email

Landile Jack

(Department of

Water Affairs)

All bathing units will be under roof

Effluent from the degreasing and pickling baths will be discharged

to the wastewater treatment plant The respectively alkaline and

acidic effluents will mix and neutralise each other in the

wastewater treatment plant Calcium or gypsum will be added if

required to complete the neutralisation process Effluent from the

treatment plant will be discharged to sewer Contact has been

made with the relevant officials and the Municipalityrsquos

requirements have been obtained The effluent discharged to

sewer will notably comply with the applicable discharge standards

Traces of metals (eg iron) may be present but will not exceed

prescribed thresholds The necessary authorisation will be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

4

IssueCommentQuestion Date

received Origin Response

sewer Clarity and acceptance needs to be agreed with

Nelson Mandela Bay Municipality Who owns the sewer

10 Quenching unit will results to Zinc particles How will this

affect sewer discharge This again must be dealt with within

the negotiations with the Municipality

11 Once all has been agreed with the Municipality and at the

same time due negotiations must be done with hazardous

waste courier and disposal facility to accept the hazardous

waste identified in all production lines

12 Of note is the low volume of the proposed WWTW facility ie

250 cubmweek And the no discharge of the quenching

water ie over-flow and cooling only Hence Zinc particles

generation

obtained from the municipality

The sludge from the treatment plant will be collected by a licensed

service provider and disposed of at a permitted site

The quenching bath will be periodically emptied (every 6 months)

and the water discharged will go to the water treatment plant Zinc

particles will settle in the sludge which will be disposed of at a

permitted site

Contact has been made with EnviroServ who manages the

Aloes II HH waste site regarding collection and disposal of

hazardous waste (See waste management report)

13 Investigate the potential effects of toxicity andor influence of

emissions waste and hazardous substances both in

terrestrial and marine fauna

14 With regards to water usage where is the plant going to

extract its waters used in galvanization andor waste

management process ie rainfall rivers or even from the

sea) and which avenues would be more environmental

friendly and effective

31052011

By email

A Bewana

(SANPARKS)

Emissions waste and hazardous substances are not expected to

affect terrestrial or marine ecosystems The air quality study

concluded that atmospheric emissions would not be harmful to

human health and by extension terrestrial fauna There are no

standards for air quality for defining faunal impacts therefore by

ensuring that standards for humans are complied with the impact

on fauna is deemed to be acceptable In this case the impact of

emissions on terrestrial and marine fauna are thus not significant

Solid and liquid wastes both general and hazardous as well as

hazardous substances will be stored handled and disposed of

appropriately to as not to cause harm to terrestrial or marine

fauna

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

5

IssueCommentQuestion Date

received Origin Response

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination and hence land-based

marine pollution by effluent waste or hazardousdangerous

substances is very low

The risk of emissions waste and hazardous substances to

terrestrial and marine fauna is thus very low

However pollution of terrestrial and marine ecosystems can occur

in exceptional circumstances such as accidents and emergencies

The emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

The CDC has an agreement with the NMBM to supply potable

water to the Coega IDZ Currently the infrastructure to supply

return effluent (RE) to the IDZ is not in place therefore Casa Steel

will be supplied with potable water up until such time as the

following 2 options of RE are available

1) Upgrading of the existing Fishwater Flats waste water

treatment works (between IDZ amp PE) including RE plant

and infrastructure to pipe RE to the IDZ (EIA for the

upgrade is underway)

2) Construction of a new waste water treatment works

including RE plant in Zone 9 of the Coega IDZ

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option should be investigated further between Agni and Casa The

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

6

IssueCommentQuestion Date

received Origin Response

CDC can facilitate discussions between the 2 investors

Compliance with CDC Permits amp Requirements

15 It should be made clear that tenants will be required to

comply with CDC requirements and the relevant conditions of

permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water

Licence for its Storm Water Systems on the

East Side of the Coega River that tenants will

need to take cognizance of The contents of the

ldquoIntegrated Stormwater Masterplan for the

eastern side of the Coega IDZ Oct 2010rdquo

especially the Table of best practice p53

onwards may need to be taken cognizance of

o CDC is developing an Operations

Environmental Management Plan that will place

certain obligations on tenants

16 Environmental audits and data collected during monitoring

(eg stack emissions stormwater) will need to be shared with

CDC

Air Emissions

17 Presumably permanent in stack monitoring will be required in

terms of AEL permit requirements

18 Abnormal operating conditions resulting in air emissions ndash I

could find nothing in the EIR to indicate under what

circumstances these could occur (eg start-up) potential

frequency and duration and the impact on ambient air quality

ndash these events usually result in the most problems wrt air

emissions

09042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

15 Compliance with the CDCrsquos Permits amp Requirements has

been included explicitly as a requirement in the EIR (p8-1) and

EMP (pp18 and 25) in the following terms

ldquoAs a tenant operating in the IDZ Casa Steel will be required to

comply with all current and future CDC requirements as well as

with the relevant conditions of permits licences issued to CDC

(eg Integrated Stormwater Masterplan for the eastern side of the

Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)rdquo

16 The need to communicate with the CDC on monitoring and

auditing activities was emphasised in Chapter 8 of the EMP The

following paragraphs were added

ldquoDuring construction the environmental officer will be responsible

for monitoring compliance with the EMP and authorisation

conditions and keeping records as required in the EMP andor

authorisation conditions

The ECO will conduct site inspections every two weeks audit the

records kept by the environmental officer and submit an

environmental compliance report every two months to the

authorities and the CDC (via the Environmental Monitoring

Committeersquos ECO)

During operation the health and safety officer will monitor

compliance with the EMP and the conditions of the Environmental

Authorisation Data collected during monitoring activities and any

environmental audits conducted will be shared with authorities

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

7

IssueCommentQuestion Date

received Origin Response

Water

19 Large volumes of (2000 m3mth) of water are required of

which only 400m3 needs to be potable The NMBM return

effluent system will provide non-potable water once it is

constructed What other water recycling initiatives can be

utilized to reduce potable water requirements (the ISWMP for

the eastern side of the Coega IDZ has some best practice

guidelines collecting rainwater from the roof etc)

General

20 There is no mention of how the CDC Architectural Guidelines

will be incorporated into the development (eg to prevent a

stark uniform warehouse type development)

21 Does NMBM have adequate fire services to cover this

development Apart from the large petroleum store are there

any other large fire hazards

22 Reports from the tenantrsquos ECO during construction and from

the SHE Officer during operations should be channeled to the

Coega Environmental Monitoring Committee This can be

directly or preferably via the EMCrsquos ECO (this will be while

the EMC and ECO are in place) A precedent has been set

for this in the Environmental Authorisations for Agni-Steel and

Kalagadi Manganese Smelter

23 All mitigation actions emanating from the EIR should be

summarized (preferably in a table) If compliance with them is

to be part of the Environmental Authorization from DEDEAT

then they (or the ones that DEDEAT deems to be applicable)

and the CDC (via the Environmental Monitoring Committeersquos

ECO)

The ECO (during construction) and the health and safety officer

(during operation) will report to the Coega Environmental

Monitoring Committee (EMC) via the EMCrsquos ECO (this will be

while the EMC and ECO are in place)rdquo

17 The draft EMP recommends regular monitoring of emissions

from the scrubbers and from the chromating process Additional

emissions monitoring requirements will be confirmed once the

AEL is issued Mention has been made in the EMP (pp11 and 19)

that all AEL conditions including monitoring and reporting

requirements should be adhered to

18 Abnormal emissions can occur in exceptional circumstances

Start-up will not cause abnormal emissions as the scrubbers

will be commissioned first and will be functioning once the plant

starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions

would be emitted as a building fugitive

The hourly hydrogen chloride ground level concentrations

(directly offsite) were predicted to be 239 microgmsup3 (based on the

emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits

as stipulated for listed activities for galvanising processes) using a

screen model which assumes worst case meteorological

conditions The health effect screening level for hourly HCl

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

8

IssueCommentQuestion Date

received Origin Response

should be attached to the EA as an Appendix (otherwise no

one knows about them or takes cognizance of them)

concentrations is 2100 microgmsup3 Assuming abnormal emissions

emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset

conditions will still be well within the health effect screening

levels

Similarly the hourly particulate emissions from the building

fugitives during upset conditions would amount to 293 microgmsup3

(based on the emission limits as stipulated for listed activities for

galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1

January 2015) directly off-site

Therefore if emissions are 5 times higher normal they will still be

within health effect screening levels and the daily PM10 NAAQS

levels

In the case of a fire a cocktail of gases and particulates could be

emitted and could be over the recommended levels This

situation will however be dealt with as an emergency and

normalised as quickly as is possible

The above has been added to the impact identificationdescription

and assessment sections of the EIR

19 The CDC has an agreement with the NMBM to supply

potable water to the Coega IDZ Currently the infrastructure to

supply return effluent to the IDZ is not in place therefore Casa

Steel will be supplied with potable water up until such time as the

infrastructure is in place

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

9

IssueCommentQuestion Date

received Origin Response

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option will be investigated further between Agni and Casa The

CDC has come forward to facilitate discussions between the two

investors

Other water recycling initiatives such as rainwater harvesting

have been considered but are not practical

20 The CDCrsquos Architectural and Landscape Design guidelines

contain requirements pertaining to such aspects as the height

orientation and mass and form of buildings as well as guidelines

for landscaping and signage in order to ensure an attractive

development and achieve an architectural integrity within the

Coega IDZ The plans for the proposed galvanizing plant will be

submitted to the Design Review Committee for approval as

required by the CDC

21 Casa Steel will be required to install fire hydrants according

to the NMBMrsquos standardsrequirements The CDC will provide

potable water (up until such time as return effluent is available)

and a connection to the boundary of the site which will be

connected to the fire hydrants The installation of the fire hydrants

will require approval by the Metrorsquos Fire Chief as was done for

Agni-Steel one of the investors in Zone 6

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

10

IssueCommentQuestion Date

received Origin Response

The Coega IDZ falls within the NMBM and therefore the rates and

taxes paid by the CDC covers the fire services for which the Metro

is responsible Currently the Metro has sufficient capacity to

provide fire services to the tenants within the IDZ This was

confirmed in discussion with the CDCrsquos Infrastructure

Development Unit It is however unknown at which point the

Metrorsquos Disaster Management Plan would not be able to

accommodate servicing tenants in the IDZ

The LNG burner is the only major fire hazard on the plant

22 See response to item 16 above

23 Key mitigation and management measures emanating from

the EIR were recapitulated in Chapter 9 of the EIR to form part of

the conditions attached to the Environmental Authorization from

DEDEAT All mitigation measures recommended as a result of the

impact assessment are presented in a table in the draft EMP

which is appended to the EIR (Appendix J)

24 Hydrogen chloride is one of the main emissions There are no

ambient air quality guidelines for HCl and the EIR says

concentrations will be well within health parameters

However the main problem with HCl is its corrosive effect -

there is absolutely no mention of this in the draft EIR nor air

specialist report

There needs to be some sort of comment assessment as to

whether HCl emissions are likely to impact on for example

the adjacent Agni-Steel Plant wrt corrosion - their factory

structure will be made of steel

11042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The atmospheric corrosion of metals is a complex process with

both the extent of deterioration and the mechanisms varying

considerably depending on the metal Depending on the way

pollutants are transported from the atmosphere to the corroding

surface two types of deposition processes are recognized in

atmospheric corrosion ndash dry deposition and wet deposition Wet

deposition refers to precipitation whereas dry deposition refers to

the remaining processes including gas phase deposition and

particle deposition The most important pollutants acting as

corrosive agents are sulphur and nitrogen compounds including

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

11

IssueCommentQuestion Date

received Origin Response

The EIR specialist rpt suggests monitoring HCl at ground

level on the property boundary and this is supported in case

there are complaints from neighbours

secondary pollutants and particulates Pollutants can contribute to

corrosivity individually however there may be a synergistic effect

when more than one of these pollutants is present in the

environment being affected In the field of atmospheric corrosion

sulphur dioxide is the single most investigated gaseous pollutant

and the quantification of the direct contribution of sulphur dioxide

to the corrosion process of metallic materials is comparatively well

understood (Tidblad amp Kucera 1998)

Very little work has reported on the effect of HCl on the

degradation of materials in the environment with no local dose-

response thresholds developed for corrosion occurring due to HCl

exposures This is probably because HCl which is present

outdoors in markedly reduced concentrations when compared

with SO2 has not been considered to contribute to significant

degradation of materials (Syed 2006) For this reason the

incremental corrosion due to HCl from the Coega Galvanising

Plant cannot be quantified

25 It is unacceptable for ILISO to be using CDC maps (see

figure 9 ndash pg5-6) without these maps being referenced

accordingly particularly when it appears that a CDC map has

been used and then overlaid with features by an unknown

author (ie CASA steel site Port (where the boundaries

depicted are incorrect) and a North legend which is out of

keeping with the overall cartographic intent of the original

work

26 Figure 10 is not referenced appropriately and I believe that I

commented previously in respect to references to roads not

12042012

By email

Graham Taylor

(Spatial

Development

Manager -

Infrastructure

Development

CDC)

This has been rectified in the final version of the report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

12

IssueCommentQuestion Date

received Origin Response

yet built As a result Figure 10 is confusing and clarity needs

to be provided in terms of referencing In addition the Port

shape is irregular and similar to the comment above

27 I acknowledge the emergency preparedness and response

plan but please confirm that this includes pro-active routine

monitoring of storm water leaving your premises to verify that

your assumptions of clean storm water are correct

13042012

By post

Andrew Lucas

(Director

WRampU

Department of

Water Affairs)

Pro-active routine monitoring of stormwater leaving the premises

will be undertaken This has been explicitly emphasised in

chapter 8 of the draft EMP

28 Will portablechemical toilets be used during construction

29 What provisions have been made for storm water drainage

during construction

18042012

By

telephone

Department of

Water Affairs

Port Elizabeth

Chemical toilets will be used during construction

The Casa Steel site will be located at the corner of two roads

drainage of stormwater from the site will take place through the

roadsrsquo drainage system

From Lea September [mailtoleailisocom]

Sent 11 March 2011 0935 AM

To Wayne Poulton

Cc Terry Baker

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Wayne

An Environmental Impact Assessment (EIA) will be undertaken for this project during the

next 10 to 12 months

We foresee that some of the key environmental impacts of the project will be in terms of air

quality water quality waste and hazardous substances

At this stage I am not able to give you any details regarding the potential toxicity of the

emissions andor effluent However specialist studies will be conducted as part of the EIA

that will determine the key impacts of the project Mitigation measures will also be identified

to avoid minimise or compensate any significant impacts

You are registered on the stakeholder database and you will be kept informed of progress in

the EIA process you will notably get the opportunity to access the reports produced and

provide any feedback on them

Please feel free to contact me should you need any further information

Best regards

Lea September

From Wayne Poulton [mailtowaynepbosuncoza]

Sent 07 March 2011 1257 PM

To Lea September

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

Please can you provide me with some more information as to the potential dangers including

the toxicity of this

Kind regards

Wayne

From Lea September [mailtoleailisocom]

Sent 04 March 2011 1123

To Lea September

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 March 2011 0745 AM

To Paul Martin

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 05 April 2011 0847 AM

To Paul Martin

Cc Terry Baker Renee von Gruenewaldt

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Thank you Paul for this information

I have downloaded a copy of the RoD and Scoping report you referred to and will make sure

these requirements are taken into account in the environmental assessment

Best regards

Lea September

From Paul Martin [mailtopmartinaxxesscoza]

Sent 04 April 2011 0955 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Further to my comments on 27311

Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in

the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega

IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised

scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions

including prohibiting and monitoring where possible visible emission plumes to the atmosphere

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Paul Martin

Sent Monday March 28 2011 745 AM

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 10 May 2011 0327 PM

To ElliotMotsoaholetransnetnet

Cc Terry Baker

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Mr Motsoahole

Thank you for your input on this issue

The Port of Ngqura will indeed be used for import and export At the moment the scope of

the traffic impact assessment only covers road traffic I have however relayed the matter to

our traffic specialist and we will consider this issue in the finalization of the Scoping Report I

will keep you informed of any developments in that regard

I trust this is acceptable to you

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]

Sent 10 May 2011 0855 AM

To Lea September

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

It has been noted that Casa Steel will source steel coils from various markets internationally and

in South Africa and the bulk of the plantrsquos production output will be exported to African countries

However there is no mention of logistic requirements

Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will

be used the scope of traffic impact assessment should also include the port

Regards

From Lea September [mailtoleailisocom]

Sent 04 May 2011 0747 AM

To Lea September

Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

Please find attached a letter announcing the EIA process underway for the proposed 80 000

tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as

a Background Information Document (BID) outlining the details of the project

Please contact me should you require any further information on this project

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

Elliot Motsoahole

Manager - Environment

Transnet National Ports Authority

Port of Nqqura

Port Control Building Klub Road Port Elizabeth 6212

PO Box 612054 Bluewater Bay 6212

+27 41 507 8450

+27 86 674 7729

Cell +27 83 542 5619

E-mail Elliotmotsoaholetransnetnet

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

DISCLAIMER The information contained in this communication is subject to copyright and

intended only for the use of leailisocom Unauthorised use disclosure or copying is

strictly prohibited Should a virus infection occur as a result of this communication the sender

will not be liable If you have received this communication in error please notify

elliotmotsoaholetransnetnet

From Lea September [mailtoleailisocom]

Sent 25 May 2011 1147 AM

To Jack Landile (ELS)

Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi

Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Landile

Thank you for your input

Contact has been made with the relevant Municipal Directorate and we will follow up with

them to obtain clarifications on all these issues

I have added both Lizna and yourself on the database and will keep you updated on

progress on this project

Best regards

Lea September

From Jack Landile (ELS) [mailtoJackLdwagovza]

Sent 24 May 2011 0524 PM

To Fourie Lizna (ELS)

Cc Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Hi Lizna

I missed you on this sorry

I linked Pieter twice Instead

Regards

Landile

From Jack Landile (ELS)

Sent 24 May 2011 0445 PM

To leailisocom

Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Lea

The e-mail you sent to Mr Kooverji dated 19 May 2011 refer

Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are

All steel sheets bathing unit must be under roof

The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project

Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal

Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer

Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality

Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines

Of note is the low volume of the proposed WWTW facility ie 250 cubmweek

And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles

generation

Regards

Landile

From Lea September [mailtoleailisocom]

Sent 19 May 2011 0947 AM

To Lea September

Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Stakeholder

Please find attached the remaining appendices to the draft Scoping report for the proposed

80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 June 2011 0411 PM

To Aphiwe Bewana

Subject RE Proposed 80 000 TPY Galvanizing plant in Coega

Dear Mr Bewana

Thank you for your input and apologies for the late reply

We have taken note of your comments and are will be taking them forward in the EIA phase

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Aphiwe Bewana [mailtoaphiwebewanagmailcom]

Sent 31 May 2011 1205 PM

To Lea September

Subject Re Proposed 80 000 TPY Galvanizing plant in Coega

Comment

Re Proposed 80 000 TPY Galvanizing plant in Coega

As SANParks we would like the EIA phase to investigate the potential effects of toxicity

andor influence of emissions waste and hazardous substances both in terrestrial and

marine fauna In the draft scoping report reference has been made with regards to the

terrestrial fauna but there is no attention to potential effects to marine fauna

Equally with regards to water usage where is the plant going to extract its waters used in

galvanization andor waste management process ie rainfall rivers or even from the sea)

and which avenues would be more environmental friendly and effective

Regards

Aphiwe Bewana

Marine Planner

South African National Parks

POBox 76693

NMMU

Port Elizabeth

6031

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 06 July 2011 1031 AM

To Lea September

Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Hi Lea

Irsquove reviewed the Final Scoping Report Herewith a few comments

1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the

Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a

revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the

NMBLP Please include only those in the IDZ as part of your IAP list

Regards

Andrea

From Lea September [mailtoleailisocom]

Sent Wednesday July 06 2011 859 AM

To Lea Septemberrsquo

Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Dear Stakeholder

The final scoping report for the above-mentioned project (attached) is available for comment

until 27 July 2011

The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic

commentaryrdquo tab

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 09 April 2012 1159 AM

To Lea September

Subject Comments on Galvanising Plant EIR Coega IDZ

Lea

Attached are my comments on the Draft EIR for the Coega IDZ galvanising

plant

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

Email attachment

COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ

Dr Paul Martin PO Box 61029

Bluewater Bay 6212 Tel 041 4665698

Email pmartinaxxesscoza

Compliance with CDC Permits amp Requirements

It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of

o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants

Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC

Air Emissions

Presumably permanent in stack monitoring will be required in terms of AEL permit requirements

Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions

Water

Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)

General

There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)

Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards

Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter

All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 11 April 2012 1245 PM

To Lea September

Subject Fw Comments on Galvanising Plant EIR Coega IDZ

Lea

One other comment on that I have on the Galvanising Plant Draft EIR

Hydrogen chloride is one of the main emissions There are no ambient air

quality guidelines for HCl and the EIR says concentrations will be well

within health parameters

However the main problem with HCl is its corrosive effect - there is

absolutely no mention of this in the draft EIR nor air specialist report

There needs to be some sort of comment assessment as to whether HCl

emissions are likely to impact on for example the adjacent Agni-Steel

Plant wrt corrosion - their factory structure will be made of steel

The EIR specialist rpt suggests monitoring HCl at ground level on the

property boundary and this is supported in case there are complaints from

neighbours

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Paul Martin ltpmartinaxxesscozagt

To Lea September ltleailisocomgt

Sent Monday April 09 2012 1158 AM

Subject Comments on Galvanising Plant EIR Coega IDZ

gt Lea

gt

gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising

gt plant

gt

gt

gt Dr Paul Martin

gt PO Box 61029

gt Bluewater Bay 6212

gt Tel 041 4665698

gt Cell 0732524111

gt email pmartinaxxesscoza

gt

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 12 April 2012 1139 AM

To Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Hi Lea

Hope yoursquore keeping well

I have requested comments from my colleagues and the CDC Casa team on the Draft EIR

Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report

Regards

Andrea

From Graham Taylor

Sent Thursday April 12 2012 838 AM

To Andrea Von Holdt Firhana Sam

Cc Johan Fourie Maria van Zyl Melikhaya Sihawu

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Andrea Firhana

Firhana if you could please ensure that the co-ordinates provided in the EIR correspond

with our records (pages 4-1 amp 4-2)

My comments are as follows

It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work

Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above

Regards

Graham Taylor

Spatial Development Manager - Infrastructure Development

Mobile 0832283055

Office 0414030454

Facsimile 0865185033

Email GrahamTaylorcoegacoza

Website wwwcoegacom

right PLACE | right TIME | right CHOICE

This email and all contents are subject to the following disclaimer

httpwwwcoegacomemaildisclaimerhtml

From Lea September [mailtoleailisocom]

Sent 04 May 2012 0411 PM

To Andrea Von Holdt

Cc Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Dear Andrea

We have taken note of the comments from the GIS Unit These issues have been rectified in

the final version of the EIR

Please can you forward to the relevant persons at the GIS Unit

Thank you

Best regards

Lea September

APPENDIX E

BACKGROUND INFORMATION

DOCUMENT

APPENDIX F

AIR QUALITY IMPACT ASSESSMENT

APPENDIX G

TRAFFIC IMPACT ASSESSMENT

APPENDIX H

WASTE MANAGEMENT AND HAZARDOUS

SUBSTANCES SPECIALIST STUDY

APPENDIX I

WATER QUALITY SPECIALIST STUDY

APPENDIX J

ENVIRONMENTAL MANAGEMENT

PROGRAMME

Page 12: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-2

of 2008) in which case the activity is regarded to be excluded from

this list

(iii) the undertaking of a linear activity falling below the thresholds in

Notice 544 of 2010

Hot dip galvanizing is a listed activity in terms of section 21 of the National

Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires

an Atmospheric Emissions Licence (AEL)

In addition the treatment of wastewater with an annual throughput capacity of more

than 2000 m3 is a listed activity in terms of the National Environmental Management

Waste Act 59 of 2008 and requires a waste management licence

ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental

Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact

Assessment process in terms of section 24 of NEMA for the construction and

operation of the proposed galvanizing plant The EIA process covers all aspects of

the project and informs all three applications (for environmental authorisation waste

management licence and AEL)

13 PURPOSE OF THIS REPORT

This report builds on the scoping report submitted to the Eastern Cape Department of

Economic Development and Environmental Affairs (DEDEA) and the Nelson

Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It

describes the proposed project and presents the findings of the second phase of

investigations (EIA phase)

14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT

PRACTITIONER (EAP)

The EIA was managed by Ms Terry Baker a certified Environmental Assessment

Practitioner with 20 years of working experience She has a MA in Environmental

Management and specialises in Environmental Impact Assessments and Project

Management She has been involved in a variety of different types of EIAs including

for water supply projects dams transmission lines roads and airports in South

Africa Botswana Uganda Lesotho and Mozambique She has been involved in

water resource management and public participation programmes on a number of

projects Terry has also been involved in the use of Geographic Information Systems

environmental status quo reports water quality assessments socio-economic and

institutional development projects

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-3

15 PROJECT TEAM

In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen

(water quality specialist) and Lea September (EAP) with specialist input from Renee

von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous

substances) and Seniel Pillay (Traffic Impact Assessor)

The Business Unit Head of the ILISO Environmental Management Discipline Group

Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is

a Fellow of the South African Institution of Civil Engineers a member of the South

African Society of Aquatic Scientists of the Environmental Scientific Association of

the International Water Association of the Water Institute of South Africa and of the

Vaal River Catchment Association He is a certified Environmental Assessment

Practitioner with 30 years experience who specialises in project management

environmental impact assessments and water resource planning He specifically has

extensive experience in water quality especially water quality management water

quality monitoring and water quality assessment Martin has experience in managing

projects that involve multi-disciplinary teams and public consultation and

participation in South Africa and abroad

Lea September is an Environmental Assessment Practitioner with a Masters degree

in Environmental Management She has experience in impact assessment and

environmental management and has been responsible for drafting impact

assessment reports and Environmental Management Programmes and conducting

public participation processes as well as high level environmental screenings for a

variety of projects in the energy water transport and industrial sectors

Renee von Gruenewaldt has nine-years experience in the field of air pollution

impact assessment and air quality management Prior to becoming involved in air

quality consultation she was part of the Highveld Boundary Layer Wind Research

Group based at the University of Pretoria Since joining Environmental Management

Services (the company now Airshed Planning Professionals) she has undertaken

numerous air pollution impact studies and has provided extensive guidance to both

industry and government on air quality management practices

Pieter Smuts graduated as a Civil Engineer and became involved in the field of

municipal engineering and infrastructure construction He has specialized during the

last twelve years in solid waste management He has completed waste management

plans feasibility studies and final designs of waste management facilities in South

Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and

the review of the Mavoco hazardous waste landfill design in Maputo Mozambique

and completed a study on hazardous waste (textile factory sludge) management in

Maseru Lesotho

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-4

Seniel Pillay is a transportation engineer with over 16 years experience in

transportation planning and traffic engineering He has been involved in a wide

range of projects ranging from developing the Transport Operations Plan for the

FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System

for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller

traffic impact assessments for inter alia road improvement schemes Of particular

relevance to this project his experience includes Heavy Goods Vehicle Study for

eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact

Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash

Preliminary Transportation Assessment

16 STRUCTURE OF THIS REPORT

The proposed project and the alternatives considered are described in Chapter 2

Chapter 3 details the approach adopted for the EIA phase

The biophysical and socio-economic environment affected by the activity is described

in Chapter 4

The environmental impacts identified are discussed in Chapter 5

The EIA methodology is described in Chapter 6 and Chapter 7 presents the results

of the impact assessment

The environmental impact statement is presented in Chapter 8

Finally Chapter 9 spell out the conclusions and recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-1

2 DESCRIPTION OF THE PROPOSED PROJECT

21 TECHNICAL ASPECTS

211 The galvanizing process

Galvanizing consists of coating steel with zinc in order to protect it from corrosion

Before steel strips can be galvanized they undergo a pre-treatment in order to

ensure that the steel sheets are free from any surface oxides as they enter the

molten zinc coating Bath This is done by removing the oil from the steel sheets (in

the degreasing unit) and then removing the rust from the surface of the sheet (in the

pickling unit)

The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The

melting zinc on the strip surface will be cooled and solidified through air cooling in the

cooling tower

Finally the galvanised steel sheets are dipped into a water quenching tank in order to

further cool the sheets from about 150degC to 40degC

It is possible to make galvanised steel more durable by chromating it Approximately

50 of the galvanised steel production output will receive chromate passivation

treatment after quenching the galvanised steel sheets will be sprayed with a chrome

solution (3 kgcm2)

After galvanizing and chromating the steel sheets are cut to achieve the desired coil

size and weight and transported to the storage yard

The process flow diagram below (Figure 1) illustrates the main stages of the

galvanizing process and indicates the major inputs and outputs as well as the

resulting effluent and atmospheric emissions

Draft Environmenal Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-2

Figure 1 Process flow diagram for proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-3

212 Main inputs and outputs in operational phase

In view of the above the main inputs will be as follows

Steel coils 85 000 tonsyear

Zinc 870 tonsyear

Electricity 2500 kVA

Water 2000 m3month (of which 400 m3 will be potable water)

Liquid Natural Gas (LNG) 270 NM3hour

Sodium hydroxide (NaOH) 1000 m3year

Hydrochloric acid (HCl) 800 m3year

Chrome (Cr+3) 10 m3year

The main outputs will be

Galvanized steel 80 000 tonsyear

Scrap metal 20 tonsyear

General waste 65 tonsyear

Hazardous waste 2 m3month

Wastewater 012 Mlweek

Atmospheric emissions lt 5 ppm

213 Installations on site

The bulk of the operations involved in the galvanizing process occur along a

continuous galvanizing line (See Figure 2 below) which is the main piece of

machinery required for the proposed galvanising plant

Figure 2 Continuous Galvanizing Line

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-4

Water is one of the major inputs and is used throughout the galvanizing process notably

for rinsing and cooling purposes and as a mixing agent for the various chemical

solutions The plant will have a water treatment plant on site to treat the water used in

the various processes (approx 250 m3

of wastewater per week) The wastewater

treatment facility will be operated by a professional water treatment company as Casa

Steel does not have the required expertise in house to treat its process water Sulphuric

acid (H2SO4) is used as part of the treatment process to reduce caustic soda The

neutralised water is discharged to the sewer while any sludge is disposed of as

hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)

will be disposed of

Some critical areas of the galvanizing process such as the zinc pot require uninterrupted

power It is therefore proposed to install an LNG burner to maintain the zinc bath at a

temperature of between 450 and 460degC

22 LOCATION OF THE PROPOSED GALVANIZING PLANT

The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast

of Port Elizabeth in the Eastern Cape (Figure 3)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-5

Figure 3 Location of the proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-6

23 NEED AND DESIRABILITY

The profitability of the proposed project has been established by Casa Steel and a

pre-feasibility study has confirmed that the proposed project was feasible from a

technical and financial point of view The Coega IDZ is specifically designed to host

facilities such as a galvanizing plant and can provide the necessary infrastructure

and services to its investors It therefore constitutes a very suitable location for the

project

24 ALTERNATIVES IDENTIFIED

Zone 6 has been specifically earmarked for heavy ferrous metal industries and is

therefore a suitable location for the proposed galvanizing plant as such no site

alternatives have been provided for and assessed in this EIA However prior to the

commencement of the EIA process Casa Steel was presented with a number of

different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the

selection of the site were

(a) The dimensions of the land the site should be at least 200 m long and

50 m wide in order to accommodate the galvanizing line and adjacent lay

down area and additional land should be available next to the site for future

expansion

(b) The fiscal arrangements applying to the site the site should be located

within the future Custom Controlled Area (CCA) as the bulk of the

production output of the plant will be exported

The no-go alternative is assessed in this report

25 CONSTRUCTION ASPECTS

The construction phase of the project will take about 12 months and will essentially

consist of erecting a building to house the galvanizing line and other equipment and

preparing a concrete laydown area adjacent to the building

The CDC will provide an access point from the existing tarred road that will lead to

the site

Approximately 100 workers from the surrounding areas will be contracted for the

construction work

The requirements in terms of services during construction are listed below

Water 1000 m3month

Electricity 2500 kVA

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-7

The CDC will provide temporary services for the construction phase including a

conservancy tank for flush toilets Sewage infrastructure will only be provided for the

operational phase

26 OPERATION ASPECTS

Before the plant can become fully operational the equipment and machinery will be

tested for approximately 3 months The supplier will supervise these tests as part of

the transfer of know-how and training of staff on the plant

Casa Steel will start operating the plant at a reduced capacity (about 50 000

tonsyear) for a period of time (mostly determined by market aspects) before bringing

production to full capacity (80 000 tonsyear) This is done by operating the line for

longer hours

Approximately 50 to 60 people will be working on the plant Approximately 6-10 of

these will be unskilled 40-45 skilled and about 5 people in managerial positions

The requirements in terms of services during operation are as follows

Water 2000 m3month

Electricity 2500 kVA

Effluent discharge 24 m3day

The CDC has entered into agreements with the municipality to secure the provision

of services such as water and electricity to its tenants Tenants in the IDZ have their

own agreements with the NMBM for electricity while the agreements for water and

sewage are with the Facilities Unit of the CDC

Regarding discharge of wastewater to the sewer the municipality indicated that the

only requirement is that the water discharged complies with applicable municipal

discharge standards

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 3-1

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT

31 OBJECTIVES

The main objectives of the EIA phase are to

Assess the significance of the environmental issues and impacts identified in the

scoping phase focusing on key impacts

Recommend appropriate measures to mitigate negative impacts and enhance the

benefits and include them in the draft EMP

Undertake a public participation process that provides opportunities for all

interested and affected parties (IampAPs) to be involved

32 AUTHORITY CONSULTATION

The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental

Liaison Committeersquo (ELC) which comprises representatives of various authorities

including DEDEAT the Department of Environmental Affairs (DEA) and Department

of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the

Coega Development Corporation (CDC) and Transnet National Ports Authority

(TNPA) The ELC has been specifically formed to facilitate EIA applications in the

IDZ

Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to

the clearance of vegetation should be included in the application A formal request

was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the

application and all registered stakeholders were informed of the request in writing on

19 October 2011

33 PUBLIC PARTICIPATION PROCESS CONDUCTED

On-site notices were replaced by a notification displayed on the CDCrsquos digital notice

board at the business centre in Zone 1 of the IDZ The eNotice was placed on

13 April 2011 and will remain for the full duration of the EIA process

Registered stakeholders will be notified in writing of the availability of the draft EIA

report and EMP which will also be advertised in a local newspaper Stakeholders

including state departments and the public will have forty (40) days to comment on

the draft EIA report and EMP The draft EIA report and EMP will be sent by email

where possible and made available for download on the ILISO website

(wwwilisocom)

A summary of all issues and comments received during the stakeholder consultation

process as well as of correspondence in that regard will be captured in an Issues

and Responses Report that will form an Appendix to the EIA Report

The list of registered IampAPs is included in Appendix A

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 3-2

34 LEGISLATION AND GUIDELINES CONSIDERED

The following legislation and guidelines were considered in the preparation of this

report

National Environmental Management Act Act No 107 of 1998

NEMA EIA Regulations 2010

National Environmental Management Air Quality Act Act No 39 of 2004

National Environmental Management Waste Act Act No 59 of 2008

Hazardous Substances Act Act 15 of 1993

Occupational Health and Safety Act Act 85 of 1993

Hazardous Chemical Substances Regulations 1995 (GNR 1179)

Major Hazard Installation Regulations 2001 (GNR 692)

National Water Act Act 36 of 1998

National Heritage Resources Act Act 25 of 1999

DEAT Integrated Environmental Management Information Series 1-5 and 12-15

NEMA draft Implementation Guideline

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Public Participation (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Alternatives (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Draft Guideline for Determining the Scope of Specialist

Involvement in EIA Processes (2005)

IAIA guidelines

National air quality standard for thoracic particulates Government Gazette

No 32816

Listed activities and associated minimum standards identified in terms of section

21 of the National Environmental Management Air Quality Act Act No 39 of

2004 Government Notice 248 of 2009

Minimum Requirements for the Handling Classification and Disposal of

Hazardous Waste DWAF Waste Management Series (1998)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-1

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION

The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega

IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay

to the north of the N2 highway between Port Elizabeth and Grahamstown east of the

Coega River

The co-ordinates of the corners of the site are shown in Table 1

Table 1 Coordinates of site corners for the proposed galvanizing plant

Point Longitude Latitude

A 25deg411126E 33deg45587S

B 25deg411156E 33deg45499S

C 25deg411938E 33deg45131S

D 25deg412174E 33deg45481S

E 25deg412508E 33deg45979S

F 25deg412634E 33deg451160S

G 25deg411782E 33deg451560S

H 25deg411692E 33deg451428S

J 25deg411314E 33deg45868S

Figure 4 Zone layout in the Coega IDZ

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-2

Figure 5 Site location

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-3

42 SOCIO-ECONOMIC CHARACTERISTICS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the

NMBM There are no residents within the IDZ

As far as the broader NMBM and Eastern Cape Province are concerned the

following can be noted The NMBM is located within the Eastern Cape Province the

2nd largest Province in South Africa (3rd in terms of population) characterised by a

predominantly black population with low incomes and high levels of unemployment

(CES 2010)

The NMBM has a population of just above 11 million and covers an area of

1 950 km2 It is the main urban and industrial centre of the province and Port

Elizabeth in particular which forms part of the NMBM is the commercial capital of

the Eastern Cape 52 of the NMBM population is female and 37 is below the

age of 20 these two groups are particularly affected by unemployment

43 BIOPHYSICAL CHARACTERISTICS

431 Surface and ground water

No rivers occur in Zone 6 There is however a natural attenuation pond on the

southern most part of the site which will have to be avoided

The IDZ is underlain by calcrete sand and gravel deposits that overlie low

permeability clays These clays limit the vertical infiltration of rainwater and induce a

horizontal groundwater flow towards the Coega River channel which is the most

significant surface water feature in the Coega IDZ Consequently rapid run-off takes

place following precipitation (Jacobs 2008)

Groundwater levels at Coega are generally about 3 to 5 m below surface ie just

above the contact between the permeable sands and the underlying impermeable

clays The groundwater flow direction is to the southeast following the surface water

drainage direction (Jacobs 2008)

432 Climate and atmospheric conditions

Port Elizabeth has a warm temperate climate and the temperature ranges are not

extreme Exceptionally high temperatures may be experienced during berg wind

conditions which occur frequently during autumn and winter Extreme temperatures

also occur during summer with little accompanying wind

The wind regime for the area largely reflects the synoptic scale circulation with

dominant westerly and northwesterly flow fields representing the pre-frontal

conditions and south-westerly flow fields representing the frontal conditions The

south-easterly and south-westerly wind flow (land breeze) increases during daytime

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-4

conditions with westerly and north-westerly wind flow increasing during the night (sea

breeze)

The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of

Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15

km southwest) and Port Elizabeth (~23 km southwest)

An ambient air monitoring network has been established in the Coega IDZ which

consists of three monitors Saltworks Motherwell and Amsterdamplein Although

NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative

impacts due to the proposed Galvanising Plant is PM10 A maximum daily average

PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed

SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3

was exceeded on 17 days in 2007 and 26 days in 2008

Existing sources of emissions in the vicinity of the proposed galvanizing plant include

industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other

fugitive dust sources (von Gruenewaldt 2011b)

433 Geology and soils

Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel

and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly

limestone and conglomerate

434 Terrestrial ecology

This section draws from the EIA report compiled for the Agni Steel (formerly Afro-

Asia) steel processing facility which is adjacent to the proposed site for the

galvanizing plant (Jacobs 2008)

The area consists largely of grasses succulents and scrubby bush with alien

species making up the greater part of the more dense vegetation

Zone 6 falls within the inland vegetation and is characterised by a vegetation type

referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the

Coega IDZ and has been found to have three times the level of endemism of other

vegetation communities in the Coega IDZ Bontveld therefore has a high

conservation status Two Bontveld conservation areas have been identified within the

IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)

Bontveld that will be destroyed as a result of development in the IDZ will be given

conservation status in these two areas

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-5

Figure 6 Coega IDZ Open Space Management Plan (OSMP)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-6

Certain areas in the IDZ are invaded by alien plant species The most common

invader species is rooikrans (Acacia cyclops) which presently forms large

monospecific stands in areas throughout the Coega IDZ There are several other

aliens present that pose a threat to the flora of this area including the prickly pear

(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)

Loss of vegetation and alien plant invasion due to human activity has resulted in a

reduction in the diversity of terrestrial fauna

The majority of mammals present in the Coega IDZ are small or medium-sized Of

the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed

gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of

Algoa Bay however it is not considered threatened The gerbil is common in

foredune and dune thicket habitat in the Coega region and is therefore unlikely to

occur on the proposed site

A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird

species are resident or common to the area Most diversity occurs in the thicket

although the coastal area also supports specialised avifauna Two species of tern

the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well

as the Cape gannet (Morus capensis) and the African penguin (Spheniscus

demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne

caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant

(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser

flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns

are two of the most endangered coastal species in South Africa Other bird species

of conservation concern include the Whitefronted plover (Charadrius marginatus)

African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus

bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus

ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides

paradisea) Breeding pairs of Damara terns and African black oyster catchers have

been observed in the coastal dunes of the IDZ but should not be affected by

developments that fall outside the dune areas

The Eastern Cape supports nearly a third (approximately 133 species) of the reptile

species recorded in South Africa More than half of the Eastern Capersquos endemic

reptile species occur in the Algoa Bay area giving the region a high conservation

value A total of 63 reptile species are believed to occur within the Coega IDZ The

majority of these are found in Succulent Thicket and riverine habitats Only a few

reptile species occur in the coastal dunes and estuarine habitats More than a third of

the species are described as relatively tolerant of disturbed environments provided

that migration corridors of suitable habitat are maintained to link pristine habitats

Twenty two reptiles are of special concern including five endemic species (two of

which may also be endangered) four endangered sea turtles eight species listed

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-7

with CITES one rare species and four species at the periphery of their range

Fourteen of these species of special concern are confirmed as occurring on or within

2 km of the Coega IDZ

A total of 32 amphibian species and sub-species occur in the Eastern Cape

representing almost a third of the species recorded in South Africa However none of

the species are endemic or Red Data Book species Based on previous studies in the

area it is estimated that approximately 17 amphibian species occur within the Coega

IDZ Four species are listed as peripheral but none are threatened internationally

These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog

(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and

the bubbling kassina (Kassina senegalensis)

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated

vegetation has not been extensively studied One grasshopper species Acrotylos

hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue

(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis

pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in

four localities in the Eastern Cape one of which is within the Coega IDZ The Coega

copper Aloeides clarki is endemic to this particular region of the Eastern Cape and

is currently known to occur in three localities two of which are in the Coega IDZ The

localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the

Coega IDZ and their distributions were taken into account when defining Coegarsquos

open space system and Development Framework Plan

435 Land use and topography

The land is currently undeveloped and earmarked for industrial development The

site is relatively flat ranging from an elevation of 66 masl on the northern-most

corner to 59 masl at the southern-most corner

436 Heritage and archaeological survey

Extensive studies have been undertaken in Zone 6 with respect to heritage aspects

Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a

2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond

2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is

currently being finalised

Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing

Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha

in extent and was located next to the R102 road to Motherwell Kaplan conducted

HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi

Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will

now be located in Zone 5)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-8

The various archaeological investigations reached similar observations and

conclusions Stone tools of various densities and types were found throughout the

zone The majority of the stone tools were mainly of Earlier and Middle Stone Age

and occasional Later Stone Age origins (Figure 4)

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble

gravels exposed by tracks in Zone 6 (Source Binneman 2010)

The stone tools which comprised of quartzite flakes chunks flaked pebblecobble

and cores were randomly distributed across the landscape and are in secondary

context There were no lsquoconcentrationsrsquo of tools observed which suggested any

spatial patterning or activity areas although these may be present or covered by soil

and vegetation

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 5-1

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED

The following environmental issues and potential impacts were identified in the

Scoping phase

51 AIR QUALITY

The galvanizing process generates atmospheric emissions with particulates and

hydrogen chloride representing the main pollutants of concern The plant is fitted with

air extraction as well as scrubber systems which are designed to retain the bulk of

pollutants and particles for each of the processes in such a way that less than 5 ppm

of gases and particles will be released into the atmosphere after the fume scrubber

Other sources of impact on air quality include emissions from the LNG burner as well

as emissions and dust from the transport of steel and other materials in trucks

Construction activities will also create dust and gas emissions due to the clearing of

groundcover tipping of material to storage pile levelling of area wind erosion from

storage piles vehicle and construction equipment activity and tailpipe emissions

from vehicles and construction equipment such as graders scrapers and dozers

Overall the air quality impact assessment (Gruenewaldt 2011b) found that

The predicted particulate oxides of nitrogen carbon monoxide and sulphur

dioxide concentrations are all below the National Ambient Air Quality Standards

for all averaging periods

The predicted off-site concentrations of hydrogen chloride are well below the

most stringent effect screening levels

No odour threshold exceedances for hydrogen chloride were predicted to occur

due to routine operations at the Steel Galvanising Plant The South Wales

Environmental Protection Authority stipulates that an odour unit of 20 is

acceptable for urban areas The odour unit would be lt10 directly off-site for

hydrogen chloride

Abnormal emissions can occur in exceptional circumstances Start-up will not

cause abnormal emissions as the scrubbers will be commissioned first and will be

functioning once the plant starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions would be emitted as a

building fugitive

The hourly hydrogen chloride ground level concentrations (directly offsite) were

predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based

on the emission limits as stipulated for listed activities for galvanising processes)

using a screen model which assumes worst case meteorological conditions The

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-2

health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming

abnormal emissions emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset conditions will still

be well within the health effect screening levels

Similarly the hourly particulate emissions from the building fugitives during upset

conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for

listed activities for galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly

off-site

Therefore if emissions are 5 times higher normal they will still be within health effect

screening levels and the daily PM10 NAAQS levels

In the case of a fire a cocktail of gases and particulates could be emitted and could

be over the recommended levels This situation will however be dealt with as an

emergency and normalised as quickly as is possible

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS

The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of

its heritage potential and there are no proposed protected geosites in Zone 6

Should any artefacts be discovered during construction procedures stipulated in the

draft EMP will apply

53 BIODIVERSITY AND CONSERVATION

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

In terms of terrestrial fauna the CDCrsquos open space management plan provides for

the preservation of certain corridors The destruction of certain habitats as a result of

the development will therefore not automatically result in the loss of certain species

54 WATER QUALITY

There is a natural attenuation pond on the southern most part of the site which will be

avoided

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through

spills or leaks

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-3

This risk can however be minimized if not avoided altogether The floor of the factory

will be designed as a bunded area to contain any spills and the entire process will be

contained Potential spills or leaks will therefore be contained and will not impact on

water resources Storm water is therefore considered clean water under normal

operational conditions An oil trap will be placed at the exit of the site to ensure that

no grease from the laydown area enters the stormwater system

Spills and leaks can occur during the handling or the transport of hazardous

substances Best practice guidelines will be followed to ensure that this risk is

adequately managed

Wastewater discharged to sewer will be treated to comply with municipal discharge

standards and is not expected to have an impact on the chemical characteristics of

the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be

discharged from the plant is small in relation to the total volume received at the

Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works

(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently

operated at 61 of its capacity which is approximately 80 Mℓday Thus the

0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore

not have any significant impact on the WWTW

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES

The plant will generate a relatively small amount of solid waste in the form of scrap

metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)

The scrap metal may be sold to other steel processing facilities such as Agni Steel

which will be located next to the plant or collected and disposed of with the rest of

the solid waste by a licensed service provider

As mentioned previously there will be a wastewater treatment plant on site which will

neutralise process water (012 Mlweek) in order to ensure it is of a standard

acceptable for discharge to sewer Waste in the form of sludge from the

neutralization or spent acid must be disposed of as a hazardous waste Solid waste

from the filters used for air quality control is also in this category These wastes can

usually be tested and then delisted which means that it can be placed in a general

purpose landfill

Hazardous effluent from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-

site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored

and removed on a monthly basis is limited to 10 m3

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-4

A number of substances classified as hazardous are used in the galvanizing process

(Table 2) and the transport and handling of these is subject to certain rules and

guidelines In particular the material safety data sheets (cf Appendix H) should be

referred to for inter alia hazards identification accidental release measures

handling and storage precautions exposure controlpersonal protection ecological

information and transport information The Hazardous Chemical Substances

Regulations 1995 should also be adhered to in respect of the transport and storage

of hazardous chemical substances

Table 2 Hazardous materials to be used on site

Major Input Materials

Substance

listed in the

SABS 0228

Group II

hazardous

substances

Volumes to be

stored on site at

any one time

Diesel radic 2000 litres

Liquid petroleum radic 20 000 liters

Sodium hydroxide (NaOH)

(used for degreasing) 8 radic 1000m

3

Hydrochloric acid (HCI)

(used for pickling) 8 radic 800m

3

Zinc (used for galvanising) - TBD

Trivalent chromium (CR+3

)

(used for chromating) 8 radic 10m

3

Sulphuric acid (H2SO4) (used for

treatment of waste water on site) 8 radic TBD

Ammonium Hydroxide (NH4OH) 8 radic TBD

TBD ndash To be determined

Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one

time) and is classified as a flammable substance Specification for flammable storage

facilities in accordance with the requirements of the Nelson Mandela Bay

Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for

quantities between 5000 and 20 000 liters the substance must be kept in a

flammable liquid store which complies with the requirements of a specification

obtainable from the Department Some of the requirements are

Flammable liquid and solid storage facilities are only permitted on the ground

floor

Decanting of flammable liquids and solids are not permitted within any building

Due to the fact that there are flammable materials on site a certificate may be

required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and

Emergency Services Department to confirm that facilities for flammable storage

are in accordance with their requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-5

Because of the permanent installation and high quantity of liquid petroleum on site

the Major Hazard Installation Regulations 2001 promulgated under the Occupational

Health and Safety Act No 85 of 1993 applies A written application for approval of

the installation is required to be submitted to the chief inspector Department of

Labour provincial director Department of Labour and NMBM prior to construction

In addition a risk assessment should be formulated covering all hazardous materials

together with an emergency preparedness and response plan

56 HEALTH AND SAFETY

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling instructions as well as occupational exposure limits

are indicated in the material safety data sheets of the various substances used

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as

provide site supervision including executing tests (individual test cold run and hot

run) during 3 months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the

EMP

In addition the emergency preparedness and response plan will cover the health and

safety aspects related to emergency situations

57 TRAFFIC

The volumes of traffic at the IDZ are currently relatively low and variable depending

on the different zones in the IDZ however these volumes will increase as more

developments are implemented

The construction phase of the Casa Steel development will take about 12 months

and will essentially consist of erecting a building to house the galvanizing line and

other equipment and preparing a concrete laydown area adjacent to the building

The traffic that would be generated during the construction phase can be expected to

be less than the traffic that would be generated by the Casa Steel development when

it is fully operational

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-6

In the operation phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and

from the Port of Ngqura

The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the

Casa Steel development would be off Ring Road 1 The other roads of significance

for the Casa Steel development are the N2 Neptune Road MR435 and MR450

Access to the port is given by Neptune Road Road Link NEP-03 has not yet been

built

Figure 8 Coega IDZ road network identification

(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-7

Figure 9 Coega IDZ road network

Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No

01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-8

The distribution of freight trips is fixed as the majority of trips will be made between

the Port of Ngqura and the Casa Steel site With regard to personnel trips there are

various points of origins (the surrounding residential areas) that could be used by

staff going to the Casa Steel site The distribution of personnel trips is based on

existing traffic count information and is shown in Figure 10

Figure 10 Trip distribution for freight and personnel trips

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The resultant expected Casa Steel traffic assignment is shown in Figure 11

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-9

Figure 11 Morning peak hour Casa Steel development traffic

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The traffic that is expected to be generated by the Casa Steel development is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low

and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)

Consultation has taken place with Transnet Port Authority (TPA) to establish the

impact of the galvanizing plant operations on traffic inside the port The additional

ships entering and exiting the port of Ngqura as a result of the proposed development

will have a negligible impact on port traffic and TPA indicated that it would be well

within the portrsquos capacity

58 NOISE

Noise is not foreseen to be a significant issue insofar as the noise levels inside the

plant and at the boundary of the site will not exceed the limits prescribed by the CDC

Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels

during the day and 60 decibels at night

Mitigation of noise impacts will be addressed in the design of the noise-emitting

components of the plant and their enclosures

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-10

59 SOCIO-ECONOMIC ASPECTS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of

NMBM There are no residents within the IDZ

The direct socio-economic impacts of the proposed project are thus limited to the

employment generated by the project during construction and operation Job creation

remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)

and the IDZ and Port of Ngqura are expected to become a significant catalyst to the

economic growth of the Municipality and the region with current investments at

Coega creating more jobs and stimulating the economy

In this context the proposed galvanizing plant will make a positive contribution

towards the achievement of these goals

There will be 50 to 60 employees during operation phase distributed as follows

Figure 12 Casa Steel organisation chart

Even though a large part of the inputs will be imported and the bulk of the production

output will be exported there will be some positive impacts for the economy of the

region and of South Africa in general Notably the requirements of the plant for

water electricity waste collection and disposal waste water treatment and transport

for example will create business for the various service providers and have an

indirect impact on employment and fiscal revenues as a result

From a visual impact point of view it can be anticipated that the landscape in the IDZ

will be significantly affected over time by developments related to the establishment

of the port and various industries

HEAD ( WORKS )

MGR ( COMM) MGR ( ADMNHR ) Manager marketing

MANAGER OPERATION MANAGER MANAGER MANAGER Q C

AC FIN PUR ampSTORE

PPC SH-GALV SH-tech

SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF

1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO

JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF

2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO

WORKERS WORKERS 7NOS

15 7

RAW MAT amp

DESP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 6-1

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY

A description of the nature of the impact any specific legal requirements and the

stage (constructiondecommissioning or operation) will be given Impacts are

considered to be the same during construction and decommissioning The

significance of the potential impacts will be considered before and after identified

mitigation is implemented

The following criteria will be used to evaluate significance

Nature The nature of the impact will be classified as positive or negative and

direct or indirect

Extent and location Magnitude of the impact and is classified as

Local the impacted area is only at the site ndash the actual extent of the activity

Regional the impacted area extends to the surrounding immediate and

neighbouring properties

National the impact can be considered to be of national importance

Duration This measures the lifetime of the impact and is classified as

o Short term the impact will be for 0 ndash 3 years or only last for the period of

construction

o Medium term three to ten years

o Long term longer than 10 years or the impact will continue for the entire

operational lifetime of the project

o Permanent this applies to the impact that will remain after the operational

lifetime of the project

Intensity This is the degree to which the project affects or changes the

environment and is classified as

o Low the change is slight and often not noticeable and the natural functioning

of the environment is not affected

o Medium The environment is remarkably altered but still functions in a

modified way

o High Functioning of the affected environment is disturbed and can cease

Probability This is the likelihood or the chances that the impact will occur and

is classified as

o Low during the normal operation of the project no impacts are expected

o Medium the impact is likely to occur if extra care is not taken to mitigate

them

o High the environment will be affected irrespectively in some cases such

impact can be reduced

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 6-2

Confidence This is the level knowledgeinformation the environmental impact

practitioner or a specialist had in hisher judgement and is rated as

o Low the judgement is based on intuition and not on knowledge or

information

o Medium common sense and general knowledge informs the decision

o High Scientific and or proven information has been used to give such a

judgment

Significance Based on the above criteria the significance of issues will be

determined This is the importance of the impact in terms of physical extent and

time scale and is rated as

o Low the impacts are less important

o Medium the impacts are important and require attention mitigation is

required to reduce the negative impacts

o High the impacts are of great importance Mitigation is therefore crucial

Cumulative Impacts The possible cumulative impacts will also be considered

Mitigation Mitigation for significant issues is incorporated into the EMP for

construction

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 7-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS

71 IMPACTS DURING CONSTRUCTION

711 Air quality

Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris

handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine

particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural

operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks

and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)

Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Fugitive particulate emissions (dust)

related to construction activities Regional

Short

term Medium High High Medium Regional

Short

term Low High High Low

Construction vehicle gas emissions Regional Short

term Medium High High Medium Regional

Short

term Low High High Low

712 Heritage and archaeological resources

Naturedescription of impact excavation activities may impact on unidentified heritage resources

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-2

Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based

on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments

Heritage and archaeological

resources Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on unidentified heritage

resources Local

Short

term

Medium -

high Low High Low

713 Biodiversity and conservation

Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation

importance and cause soil contamination

Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species

Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan

and has compiled a list of protected species to be rescued (see draft EMP)

Biodiversity and conservation Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Loss of fauna and flora Local Perma

nent

Medium -

high High High High Local

Permanen

t Medium High High Medium

Soil contamination Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-3

714 Water related impacts

Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater

runoff spills and leaks Soil erosion

Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of

spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste

disposal Stormwater quality monitoring (see draft EMP)

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Soil erosion Local Short

term Medium Medium High Medium Local

Short

term Medium Low High Low

715 Waste management

Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed

Commentmitigation see draft EMP and waste management plan

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-4

Waste management Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Local

Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

716 Health and safety

Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Short

term

Medium -

high

Medium -

high High High Local

Short

term

Medium -

high Low High Low

717 Traffic

Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and

construction workers from surrounding areas and transport of equipment from the port

Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low

Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and

accurate estimates of quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-5

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Increased traffic on N2 and within the

IDZ Regional

Short

term Low High High Low

718 Noise

Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Short

term

Medium-

high High High Medium Local

Short

term Medium High High Medium

719 Socio-economic

Naturedescription of impact temporary employment will be created during the construction phase

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-6

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Temporary employment Regional Short

term Medium High High Medium

72 IMPACTS DURING OPERATION

721 Air quality

NatureDescription of impact gas and particulate emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning

Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local

sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and

veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute

to background fine particulate concentrations (von Gruenewaldt 2011b)

Assumptions and limitations Potential release of CR6+

As no emission factors are available for trivalent chromium processing the

potential impacts due to these activities could not be quantified

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Dust emitted from traffic on paved roads Regional Long Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-7

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

term

Hydrogen chloride emissions from

pickling process Local

Long

term Low High High Low

Particulate emissions (smoke) from

galvanizing process (due to the

volatilization of flux)

Local Long

term Low High High Low

Particulate oxides of nitrogen carbon

monoxide and sulphur dioxide emissions

from LNG burner

Local Long

term Low High High Low

Nuisance related to odour Local Long

term Low Low High Low

Abnormally high hydrogen chloride and

particulate emissions due to scrubber

malfunction

Local Short

term Medium Low High Medium

Gases (eg SOx NOx CO etc) and

smoke emitted in case of a fire Local

Short

term High Low High Medium

722 Water quality

NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks

Commentmitigation see draft EMP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-8

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Stormwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

723 Waste management and hazardous substances

NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous

waste both can affect environmental quality and human health

Commentmitigation see draft EMP and waste management plan

Waste management and hazardous

substances Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Regional

Long

term High

Medium -

high High High Regional Long term High Low High Low

Soilwaterair pollution due to improper

transport storage and handling of

hazardous substances

Regional Long

term High

Medium -

high High High Regional Long term High Low High Low

Health hazard Local Long

term High

Medium -

high High High Local Long term High Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-9

724 Health and safety

Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Long

term

Medium-

high

Medium-

high High High Local Long term

Medium-

high Low High Low

725 Traffic

Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on

the road network

Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak

hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road

network within Zone 6 of the IDZ (Iliso 2011)

Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)

Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of

quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-10

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on traffic and capacity of the N2 Regional Long

term Low High High Low

Impact on traffic and capacity of ring

road 1 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR435 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR450 Local

Long

term Low High High Low

Impact on traffic and capacity of

Neptune road Local

Long

term Low High High Low

726 Noise

Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Long

term Medium High High Medium Local Long term Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-11

727 Socio-economic

Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate

revenue for the municipality and the region as a whole

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Employment and economic growth Regional Short

term Medium High High Medium

73 COMPARATIVE ASSESSMENT OF IMPACTS

During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as

low during operation after mitigation

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 8-1

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

As a tenant operating in the IDZ Casa Steel will be required to comply with all

current and future CDC requirements as well as with the relevant conditions of

permits licences issued to CDC (eg Integrated Stormwater Masterplan for the

eastern side of the Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)

In particular the CDC has its own requirements regarding the monitoring of certain

aspects of the project such as the quality of the effluent and the noise levels These

have been incorporated into the EMP

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 9-1

9 ENVIRONMENTAL IMPACT STATEMENT

All predicted negative impacts can be mitigated to a low significance The only

exceptions are biodiversity as the construction of the plant will result in the

destruction of habitat and loss of fauna and flora and noise impacts inherent to

construction activities Mitigation measures have been included in the EMP for these

impacts and they have a medium significance post-mitigation

Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium to

long term similar impacts are likely to occur due to ongoing developments in the IDZ

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 10-1

10 CONCLUSION AND RECOMMENDATIONS

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as

other infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified

and assessed No fatal flaws have been identified

It is recommended that the project be approved subject to the conditions listed in

chapter 9 and adherence to the EMP requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 11-1

11 REFERENCES

Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ

Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants

Bennie JS (2010) The historical component (built environment) of the Heritage

Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port

Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report

compiled for Eastern Cape Heritage Consultants

Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater

Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay

Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage

Consultants

BKS (2006) Coega Industrial Development Zone Transport Study Volume 3

Demand Modelling Report Final Draft

Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I

Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6

Report compiled for SRK Consulting

Coastal amp Environmental Services (2010) Environmental Impact Assessment for the

Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone

Volume 3 Environmental Impact Assessment Report CES Grahamstown

Coega Development Corporation (2008) Industry Waste Management Plan -

Strategic Master Plan Report

Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants

Report No CDCSHE 03 8122

Department of Water Affairs and Forestry (1998) Waste Management Series

ldquoMinimum Requirements For The Handling Classification And Disposal Of

Hazardous Wasterdquo Second Edition

Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising

Plant in the Coega Industrial Development Zone

Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the

Coega Industrial Development Zone (IDZ) Specialist Water Study

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 11-2

Jacobs E (2008) Final Environmental Impact Report and Draft Environmental

Management Plan Proposed Steel Recycling and Processing Facility within the

Coega IDZ Report compiled for SRK Consulting

Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY

Galvanising Plant in the Coega Industrial Development Zone Waste Management

and Hazardous Substances Report compiled for ILISO Consulting

RSA National air quality standard for thoracic particulates (PM10) SA standards

(Government Gazette No 32816)

von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed

Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape

Report compiled for ILISO Consulting

von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel

Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report

compiled for ILISO Consulting

Additional sources

Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed

Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared

for Coastal Environmental Services

Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed

Kalagadi Manganese smelter in the Coega Industrial Development Zone Port

Elizabeth Eastern Cape Province Report prepared for Coastal Environmental

Services

Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia

steel recycling facility at the Coega Industrial Development Area Port Elizabeth

Prepared for SRK Consulting Port Elizabeth

APPENDIX A

LIST OF INTERESTED AND

AFFECTED PARTIES

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

DEDEARegional Manager

and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza

DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza

DEA Ocean and

CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza

DEA Ocean and

Coast

Oceanographer land-

based sources of

marine pollution

Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza

DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza

CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza

CDCEnvironmental

Project

Manager

Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza

TNPAPort of Ngqura

Environmental

Manager

Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet

NMBMEnvironmental

ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza

NMBMEnvironmental

ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza

DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza

DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza

WESSASenior Conservation

Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza

Zwartkops

ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700

hughlauegmailcom

zwartkopstrustiafricacom

SANParksNational Marine

CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza

Department Of

LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza

NMBM Air Quality

Division

Assistant

DirectorAir

Pollution and Noise

Templeton Titima 079 490 0574 Ttitimamandelametrogovza

NMBM Air Quality

DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza

NUMSARegional

RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

Department of

HealthNadiema

van der

Bergh083 378 2103

nadiemavanderberghimpiloecprovgov

za

DWA Chief Services

Officer

Joseph Jacobs 041 586 4884 jjacobsdwafgovza

EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza

NUMSecretary of union

officesZandile Xhentsa 043 743 6597 zxhentsanumorgza

DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza

Dynamic

CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom

EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza

Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza

UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom

lprincezago2uticom

Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza

Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza

Absa Mr Johann Steyn 082 3775820 johannstabsacoza

Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza

PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza

Universal

EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza

Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza

GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom

Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza

NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom

DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza

DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza

TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet

DWA Mr Landile Jack JackLdwagovza

DWA Ms Lizna Fourie FourieL4dwagovza

APPENDIX B

NOTICE OF ATMOSPHERIC

EMISSIONS LICENCE APPLICATION

AND ADVERTISEMENT

APPENDIX C

NOTICE OF COMMENT PERIOD FOR

DRAFT SCOPING REPORT

APPENDIX D

SUMMARY OF ISSUES RAISED AND

RESPONSES THERETO

April 2012

1

PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL

DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))

IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt

AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt

This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses

provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process

conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the

Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

2

IssueCommentQuestion Date

received Origin Response

1 Please provide more information with respect to the potential

dangers including the toxicity of the proposed project

07032011

By email

Wayne Poulton

(Bosun Brick

tenant at the

IDZ)

An Environmental Impact Assessment (EIA) was undertaken

which assessed the potential toxicity of the emissions and

effluent Mitigation measures were also recommended in the draft

Environmental Management Programme (EMP) to avoid

minimise or compensate any significant impacts The Draft

Environmental Impact Report and draft EMP were made available

to stakeholders for comment in March 2012

2 Do you have a Background Information Document (BID) or

similar that provides more information on the project

27032011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The BID was sent to all registered IampAPs on 4 May 2011

3 The RoD issued to the CDC on 632007 for the change in

land use for the remaining area of the Coega IDZ includes a

number of requirements with respect to

atmospheric emissions that should be considered in the

Atmospheric Emissions Licence (AEL) application such as

prohibiting and monitoring where possible visible emission

plumes to the atmosphere In particular the

recommendations on pp87-91 of the final revised Scoping

Report dated Nov 2006 must be implemented (clause 421)

04042011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

We have obtained copies of the documents referred to and ensure

that these requirements were taken into account in the

environmental assessment and AEL application

4 If the Port of Ngqura is used for import and export the scope

of the traffic impact assessment (TIA) should also include the

port

10052011

By email

Elliot

Motsoahole

(TNPA Port of

Ngqura)

The scope of the TIA was extended to include port related traffic

The TNPA at the Port of Ngqura was consulted and does not

have any objection to the project TNPA has indicated that the

development would require a minimum number of vessels per

year which would have minimal impact on the Port operations

However due notice would have to be given to the Port of Ngqura

before a vessel is scheduled to arrive so that the vessel can be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

3

IssueCommentQuestion Date

received Origin Response

accommodated at an available berth

5 Concerns with respect to potential stormwater pollution

draining into the Coega catchment and the port of Ngqura

The port needs to be dredged and heavy metals present a

risk in that regard

16052011

By

telephone

Andrew Lucas

(Department of

Water Affairs)

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination by effluent waste or

hazardousdangerous substances is very low

Thus no metals oils or other contaminants are expected to be

present in the stormwater

However stormwater pollution can occur in exceptional

circumstances such as accidents and emergencies The

emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

6 All steel sheets bathing unit must be under roof

7 The sludge out of the decreasing bath will be high in Na and

pH Therefore handling and disposal must be clarified up front

in this project

8 Per se the wastewater from decreasing bath will have high

ph and the component from the pickling unit will have low ph

Then it may be assumed that both streams will neutralize

each other Please then clarify proposed sewer discharge

with Nelson Mandela Bay Municipality up-front for acceptance

of influent as per the documented proposal

9 Pickling may result in dissolved metals How does your team

expect to deal with this As it is planned for discharge into

24052011

By email

Landile Jack

(Department of

Water Affairs)

All bathing units will be under roof

Effluent from the degreasing and pickling baths will be discharged

to the wastewater treatment plant The respectively alkaline and

acidic effluents will mix and neutralise each other in the

wastewater treatment plant Calcium or gypsum will be added if

required to complete the neutralisation process Effluent from the

treatment plant will be discharged to sewer Contact has been

made with the relevant officials and the Municipalityrsquos

requirements have been obtained The effluent discharged to

sewer will notably comply with the applicable discharge standards

Traces of metals (eg iron) may be present but will not exceed

prescribed thresholds The necessary authorisation will be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

4

IssueCommentQuestion Date

received Origin Response

sewer Clarity and acceptance needs to be agreed with

Nelson Mandela Bay Municipality Who owns the sewer

10 Quenching unit will results to Zinc particles How will this

affect sewer discharge This again must be dealt with within

the negotiations with the Municipality

11 Once all has been agreed with the Municipality and at the

same time due negotiations must be done with hazardous

waste courier and disposal facility to accept the hazardous

waste identified in all production lines

12 Of note is the low volume of the proposed WWTW facility ie

250 cubmweek And the no discharge of the quenching

water ie over-flow and cooling only Hence Zinc particles

generation

obtained from the municipality

The sludge from the treatment plant will be collected by a licensed

service provider and disposed of at a permitted site

The quenching bath will be periodically emptied (every 6 months)

and the water discharged will go to the water treatment plant Zinc

particles will settle in the sludge which will be disposed of at a

permitted site

Contact has been made with EnviroServ who manages the

Aloes II HH waste site regarding collection and disposal of

hazardous waste (See waste management report)

13 Investigate the potential effects of toxicity andor influence of

emissions waste and hazardous substances both in

terrestrial and marine fauna

14 With regards to water usage where is the plant going to

extract its waters used in galvanization andor waste

management process ie rainfall rivers or even from the

sea) and which avenues would be more environmental

friendly and effective

31052011

By email

A Bewana

(SANPARKS)

Emissions waste and hazardous substances are not expected to

affect terrestrial or marine ecosystems The air quality study

concluded that atmospheric emissions would not be harmful to

human health and by extension terrestrial fauna There are no

standards for air quality for defining faunal impacts therefore by

ensuring that standards for humans are complied with the impact

on fauna is deemed to be acceptable In this case the impact of

emissions on terrestrial and marine fauna are thus not significant

Solid and liquid wastes both general and hazardous as well as

hazardous substances will be stored handled and disposed of

appropriately to as not to cause harm to terrestrial or marine

fauna

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

5

IssueCommentQuestion Date

received Origin Response

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination and hence land-based

marine pollution by effluent waste or hazardousdangerous

substances is very low

The risk of emissions waste and hazardous substances to

terrestrial and marine fauna is thus very low

However pollution of terrestrial and marine ecosystems can occur

in exceptional circumstances such as accidents and emergencies

The emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

The CDC has an agreement with the NMBM to supply potable

water to the Coega IDZ Currently the infrastructure to supply

return effluent (RE) to the IDZ is not in place therefore Casa Steel

will be supplied with potable water up until such time as the

following 2 options of RE are available

1) Upgrading of the existing Fishwater Flats waste water

treatment works (between IDZ amp PE) including RE plant

and infrastructure to pipe RE to the IDZ (EIA for the

upgrade is underway)

2) Construction of a new waste water treatment works

including RE plant in Zone 9 of the Coega IDZ

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option should be investigated further between Agni and Casa The

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

6

IssueCommentQuestion Date

received Origin Response

CDC can facilitate discussions between the 2 investors

Compliance with CDC Permits amp Requirements

15 It should be made clear that tenants will be required to

comply with CDC requirements and the relevant conditions of

permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water

Licence for its Storm Water Systems on the

East Side of the Coega River that tenants will

need to take cognizance of The contents of the

ldquoIntegrated Stormwater Masterplan for the

eastern side of the Coega IDZ Oct 2010rdquo

especially the Table of best practice p53

onwards may need to be taken cognizance of

o CDC is developing an Operations

Environmental Management Plan that will place

certain obligations on tenants

16 Environmental audits and data collected during monitoring

(eg stack emissions stormwater) will need to be shared with

CDC

Air Emissions

17 Presumably permanent in stack monitoring will be required in

terms of AEL permit requirements

18 Abnormal operating conditions resulting in air emissions ndash I

could find nothing in the EIR to indicate under what

circumstances these could occur (eg start-up) potential

frequency and duration and the impact on ambient air quality

ndash these events usually result in the most problems wrt air

emissions

09042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

15 Compliance with the CDCrsquos Permits amp Requirements has

been included explicitly as a requirement in the EIR (p8-1) and

EMP (pp18 and 25) in the following terms

ldquoAs a tenant operating in the IDZ Casa Steel will be required to

comply with all current and future CDC requirements as well as

with the relevant conditions of permits licences issued to CDC

(eg Integrated Stormwater Masterplan for the eastern side of the

Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)rdquo

16 The need to communicate with the CDC on monitoring and

auditing activities was emphasised in Chapter 8 of the EMP The

following paragraphs were added

ldquoDuring construction the environmental officer will be responsible

for monitoring compliance with the EMP and authorisation

conditions and keeping records as required in the EMP andor

authorisation conditions

The ECO will conduct site inspections every two weeks audit the

records kept by the environmental officer and submit an

environmental compliance report every two months to the

authorities and the CDC (via the Environmental Monitoring

Committeersquos ECO)

During operation the health and safety officer will monitor

compliance with the EMP and the conditions of the Environmental

Authorisation Data collected during monitoring activities and any

environmental audits conducted will be shared with authorities

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

7

IssueCommentQuestion Date

received Origin Response

Water

19 Large volumes of (2000 m3mth) of water are required of

which only 400m3 needs to be potable The NMBM return

effluent system will provide non-potable water once it is

constructed What other water recycling initiatives can be

utilized to reduce potable water requirements (the ISWMP for

the eastern side of the Coega IDZ has some best practice

guidelines collecting rainwater from the roof etc)

General

20 There is no mention of how the CDC Architectural Guidelines

will be incorporated into the development (eg to prevent a

stark uniform warehouse type development)

21 Does NMBM have adequate fire services to cover this

development Apart from the large petroleum store are there

any other large fire hazards

22 Reports from the tenantrsquos ECO during construction and from

the SHE Officer during operations should be channeled to the

Coega Environmental Monitoring Committee This can be

directly or preferably via the EMCrsquos ECO (this will be while

the EMC and ECO are in place) A precedent has been set

for this in the Environmental Authorisations for Agni-Steel and

Kalagadi Manganese Smelter

23 All mitigation actions emanating from the EIR should be

summarized (preferably in a table) If compliance with them is

to be part of the Environmental Authorization from DEDEAT

then they (or the ones that DEDEAT deems to be applicable)

and the CDC (via the Environmental Monitoring Committeersquos

ECO)

The ECO (during construction) and the health and safety officer

(during operation) will report to the Coega Environmental

Monitoring Committee (EMC) via the EMCrsquos ECO (this will be

while the EMC and ECO are in place)rdquo

17 The draft EMP recommends regular monitoring of emissions

from the scrubbers and from the chromating process Additional

emissions monitoring requirements will be confirmed once the

AEL is issued Mention has been made in the EMP (pp11 and 19)

that all AEL conditions including monitoring and reporting

requirements should be adhered to

18 Abnormal emissions can occur in exceptional circumstances

Start-up will not cause abnormal emissions as the scrubbers

will be commissioned first and will be functioning once the plant

starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions

would be emitted as a building fugitive

The hourly hydrogen chloride ground level concentrations

(directly offsite) were predicted to be 239 microgmsup3 (based on the

emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits

as stipulated for listed activities for galvanising processes) using a

screen model which assumes worst case meteorological

conditions The health effect screening level for hourly HCl

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

8

IssueCommentQuestion Date

received Origin Response

should be attached to the EA as an Appendix (otherwise no

one knows about them or takes cognizance of them)

concentrations is 2100 microgmsup3 Assuming abnormal emissions

emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset

conditions will still be well within the health effect screening

levels

Similarly the hourly particulate emissions from the building

fugitives during upset conditions would amount to 293 microgmsup3

(based on the emission limits as stipulated for listed activities for

galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1

January 2015) directly off-site

Therefore if emissions are 5 times higher normal they will still be

within health effect screening levels and the daily PM10 NAAQS

levels

In the case of a fire a cocktail of gases and particulates could be

emitted and could be over the recommended levels This

situation will however be dealt with as an emergency and

normalised as quickly as is possible

The above has been added to the impact identificationdescription

and assessment sections of the EIR

19 The CDC has an agreement with the NMBM to supply

potable water to the Coega IDZ Currently the infrastructure to

supply return effluent to the IDZ is not in place therefore Casa

Steel will be supplied with potable water up until such time as the

infrastructure is in place

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

9

IssueCommentQuestion Date

received Origin Response

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option will be investigated further between Agni and Casa The

CDC has come forward to facilitate discussions between the two

investors

Other water recycling initiatives such as rainwater harvesting

have been considered but are not practical

20 The CDCrsquos Architectural and Landscape Design guidelines

contain requirements pertaining to such aspects as the height

orientation and mass and form of buildings as well as guidelines

for landscaping and signage in order to ensure an attractive

development and achieve an architectural integrity within the

Coega IDZ The plans for the proposed galvanizing plant will be

submitted to the Design Review Committee for approval as

required by the CDC

21 Casa Steel will be required to install fire hydrants according

to the NMBMrsquos standardsrequirements The CDC will provide

potable water (up until such time as return effluent is available)

and a connection to the boundary of the site which will be

connected to the fire hydrants The installation of the fire hydrants

will require approval by the Metrorsquos Fire Chief as was done for

Agni-Steel one of the investors in Zone 6

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

10

IssueCommentQuestion Date

received Origin Response

The Coega IDZ falls within the NMBM and therefore the rates and

taxes paid by the CDC covers the fire services for which the Metro

is responsible Currently the Metro has sufficient capacity to

provide fire services to the tenants within the IDZ This was

confirmed in discussion with the CDCrsquos Infrastructure

Development Unit It is however unknown at which point the

Metrorsquos Disaster Management Plan would not be able to

accommodate servicing tenants in the IDZ

The LNG burner is the only major fire hazard on the plant

22 See response to item 16 above

23 Key mitigation and management measures emanating from

the EIR were recapitulated in Chapter 9 of the EIR to form part of

the conditions attached to the Environmental Authorization from

DEDEAT All mitigation measures recommended as a result of the

impact assessment are presented in a table in the draft EMP

which is appended to the EIR (Appendix J)

24 Hydrogen chloride is one of the main emissions There are no

ambient air quality guidelines for HCl and the EIR says

concentrations will be well within health parameters

However the main problem with HCl is its corrosive effect -

there is absolutely no mention of this in the draft EIR nor air

specialist report

There needs to be some sort of comment assessment as to

whether HCl emissions are likely to impact on for example

the adjacent Agni-Steel Plant wrt corrosion - their factory

structure will be made of steel

11042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The atmospheric corrosion of metals is a complex process with

both the extent of deterioration and the mechanisms varying

considerably depending on the metal Depending on the way

pollutants are transported from the atmosphere to the corroding

surface two types of deposition processes are recognized in

atmospheric corrosion ndash dry deposition and wet deposition Wet

deposition refers to precipitation whereas dry deposition refers to

the remaining processes including gas phase deposition and

particle deposition The most important pollutants acting as

corrosive agents are sulphur and nitrogen compounds including

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

11

IssueCommentQuestion Date

received Origin Response

The EIR specialist rpt suggests monitoring HCl at ground

level on the property boundary and this is supported in case

there are complaints from neighbours

secondary pollutants and particulates Pollutants can contribute to

corrosivity individually however there may be a synergistic effect

when more than one of these pollutants is present in the

environment being affected In the field of atmospheric corrosion

sulphur dioxide is the single most investigated gaseous pollutant

and the quantification of the direct contribution of sulphur dioxide

to the corrosion process of metallic materials is comparatively well

understood (Tidblad amp Kucera 1998)

Very little work has reported on the effect of HCl on the

degradation of materials in the environment with no local dose-

response thresholds developed for corrosion occurring due to HCl

exposures This is probably because HCl which is present

outdoors in markedly reduced concentrations when compared

with SO2 has not been considered to contribute to significant

degradation of materials (Syed 2006) For this reason the

incremental corrosion due to HCl from the Coega Galvanising

Plant cannot be quantified

25 It is unacceptable for ILISO to be using CDC maps (see

figure 9 ndash pg5-6) without these maps being referenced

accordingly particularly when it appears that a CDC map has

been used and then overlaid with features by an unknown

author (ie CASA steel site Port (where the boundaries

depicted are incorrect) and a North legend which is out of

keeping with the overall cartographic intent of the original

work

26 Figure 10 is not referenced appropriately and I believe that I

commented previously in respect to references to roads not

12042012

By email

Graham Taylor

(Spatial

Development

Manager -

Infrastructure

Development

CDC)

This has been rectified in the final version of the report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

12

IssueCommentQuestion Date

received Origin Response

yet built As a result Figure 10 is confusing and clarity needs

to be provided in terms of referencing In addition the Port

shape is irregular and similar to the comment above

27 I acknowledge the emergency preparedness and response

plan but please confirm that this includes pro-active routine

monitoring of storm water leaving your premises to verify that

your assumptions of clean storm water are correct

13042012

By post

Andrew Lucas

(Director

WRampU

Department of

Water Affairs)

Pro-active routine monitoring of stormwater leaving the premises

will be undertaken This has been explicitly emphasised in

chapter 8 of the draft EMP

28 Will portablechemical toilets be used during construction

29 What provisions have been made for storm water drainage

during construction

18042012

By

telephone

Department of

Water Affairs

Port Elizabeth

Chemical toilets will be used during construction

The Casa Steel site will be located at the corner of two roads

drainage of stormwater from the site will take place through the

roadsrsquo drainage system

From Lea September [mailtoleailisocom]

Sent 11 March 2011 0935 AM

To Wayne Poulton

Cc Terry Baker

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Wayne

An Environmental Impact Assessment (EIA) will be undertaken for this project during the

next 10 to 12 months

We foresee that some of the key environmental impacts of the project will be in terms of air

quality water quality waste and hazardous substances

At this stage I am not able to give you any details regarding the potential toxicity of the

emissions andor effluent However specialist studies will be conducted as part of the EIA

that will determine the key impacts of the project Mitigation measures will also be identified

to avoid minimise or compensate any significant impacts

You are registered on the stakeholder database and you will be kept informed of progress in

the EIA process you will notably get the opportunity to access the reports produced and

provide any feedback on them

Please feel free to contact me should you need any further information

Best regards

Lea September

From Wayne Poulton [mailtowaynepbosuncoza]

Sent 07 March 2011 1257 PM

To Lea September

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

Please can you provide me with some more information as to the potential dangers including

the toxicity of this

Kind regards

Wayne

From Lea September [mailtoleailisocom]

Sent 04 March 2011 1123

To Lea September

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 March 2011 0745 AM

To Paul Martin

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 05 April 2011 0847 AM

To Paul Martin

Cc Terry Baker Renee von Gruenewaldt

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Thank you Paul for this information

I have downloaded a copy of the RoD and Scoping report you referred to and will make sure

these requirements are taken into account in the environmental assessment

Best regards

Lea September

From Paul Martin [mailtopmartinaxxesscoza]

Sent 04 April 2011 0955 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Further to my comments on 27311

Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in

the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega

IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised

scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions

including prohibiting and monitoring where possible visible emission plumes to the atmosphere

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Paul Martin

Sent Monday March 28 2011 745 AM

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 10 May 2011 0327 PM

To ElliotMotsoaholetransnetnet

Cc Terry Baker

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Mr Motsoahole

Thank you for your input on this issue

The Port of Ngqura will indeed be used for import and export At the moment the scope of

the traffic impact assessment only covers road traffic I have however relayed the matter to

our traffic specialist and we will consider this issue in the finalization of the Scoping Report I

will keep you informed of any developments in that regard

I trust this is acceptable to you

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]

Sent 10 May 2011 0855 AM

To Lea September

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

It has been noted that Casa Steel will source steel coils from various markets internationally and

in South Africa and the bulk of the plantrsquos production output will be exported to African countries

However there is no mention of logistic requirements

Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will

be used the scope of traffic impact assessment should also include the port

Regards

From Lea September [mailtoleailisocom]

Sent 04 May 2011 0747 AM

To Lea September

Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

Please find attached a letter announcing the EIA process underway for the proposed 80 000

tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as

a Background Information Document (BID) outlining the details of the project

Please contact me should you require any further information on this project

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

Elliot Motsoahole

Manager - Environment

Transnet National Ports Authority

Port of Nqqura

Port Control Building Klub Road Port Elizabeth 6212

PO Box 612054 Bluewater Bay 6212

+27 41 507 8450

+27 86 674 7729

Cell +27 83 542 5619

E-mail Elliotmotsoaholetransnetnet

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

DISCLAIMER The information contained in this communication is subject to copyright and

intended only for the use of leailisocom Unauthorised use disclosure or copying is

strictly prohibited Should a virus infection occur as a result of this communication the sender

will not be liable If you have received this communication in error please notify

elliotmotsoaholetransnetnet

From Lea September [mailtoleailisocom]

Sent 25 May 2011 1147 AM

To Jack Landile (ELS)

Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi

Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Landile

Thank you for your input

Contact has been made with the relevant Municipal Directorate and we will follow up with

them to obtain clarifications on all these issues

I have added both Lizna and yourself on the database and will keep you updated on

progress on this project

Best regards

Lea September

From Jack Landile (ELS) [mailtoJackLdwagovza]

Sent 24 May 2011 0524 PM

To Fourie Lizna (ELS)

Cc Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Hi Lizna

I missed you on this sorry

I linked Pieter twice Instead

Regards

Landile

From Jack Landile (ELS)

Sent 24 May 2011 0445 PM

To leailisocom

Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Lea

The e-mail you sent to Mr Kooverji dated 19 May 2011 refer

Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are

All steel sheets bathing unit must be under roof

The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project

Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal

Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer

Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality

Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines

Of note is the low volume of the proposed WWTW facility ie 250 cubmweek

And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles

generation

Regards

Landile

From Lea September [mailtoleailisocom]

Sent 19 May 2011 0947 AM

To Lea September

Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Stakeholder

Please find attached the remaining appendices to the draft Scoping report for the proposed

80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 June 2011 0411 PM

To Aphiwe Bewana

Subject RE Proposed 80 000 TPY Galvanizing plant in Coega

Dear Mr Bewana

Thank you for your input and apologies for the late reply

We have taken note of your comments and are will be taking them forward in the EIA phase

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Aphiwe Bewana [mailtoaphiwebewanagmailcom]

Sent 31 May 2011 1205 PM

To Lea September

Subject Re Proposed 80 000 TPY Galvanizing plant in Coega

Comment

Re Proposed 80 000 TPY Galvanizing plant in Coega

As SANParks we would like the EIA phase to investigate the potential effects of toxicity

andor influence of emissions waste and hazardous substances both in terrestrial and

marine fauna In the draft scoping report reference has been made with regards to the

terrestrial fauna but there is no attention to potential effects to marine fauna

Equally with regards to water usage where is the plant going to extract its waters used in

galvanization andor waste management process ie rainfall rivers or even from the sea)

and which avenues would be more environmental friendly and effective

Regards

Aphiwe Bewana

Marine Planner

South African National Parks

POBox 76693

NMMU

Port Elizabeth

6031

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 06 July 2011 1031 AM

To Lea September

Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Hi Lea

Irsquove reviewed the Final Scoping Report Herewith a few comments

1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the

Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a

revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the

NMBLP Please include only those in the IDZ as part of your IAP list

Regards

Andrea

From Lea September [mailtoleailisocom]

Sent Wednesday July 06 2011 859 AM

To Lea Septemberrsquo

Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Dear Stakeholder

The final scoping report for the above-mentioned project (attached) is available for comment

until 27 July 2011

The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic

commentaryrdquo tab

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 09 April 2012 1159 AM

To Lea September

Subject Comments on Galvanising Plant EIR Coega IDZ

Lea

Attached are my comments on the Draft EIR for the Coega IDZ galvanising

plant

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

Email attachment

COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ

Dr Paul Martin PO Box 61029

Bluewater Bay 6212 Tel 041 4665698

Email pmartinaxxesscoza

Compliance with CDC Permits amp Requirements

It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of

o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants

Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC

Air Emissions

Presumably permanent in stack monitoring will be required in terms of AEL permit requirements

Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions

Water

Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)

General

There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)

Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards

Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter

All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 11 April 2012 1245 PM

To Lea September

Subject Fw Comments on Galvanising Plant EIR Coega IDZ

Lea

One other comment on that I have on the Galvanising Plant Draft EIR

Hydrogen chloride is one of the main emissions There are no ambient air

quality guidelines for HCl and the EIR says concentrations will be well

within health parameters

However the main problem with HCl is its corrosive effect - there is

absolutely no mention of this in the draft EIR nor air specialist report

There needs to be some sort of comment assessment as to whether HCl

emissions are likely to impact on for example the adjacent Agni-Steel

Plant wrt corrosion - their factory structure will be made of steel

The EIR specialist rpt suggests monitoring HCl at ground level on the

property boundary and this is supported in case there are complaints from

neighbours

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Paul Martin ltpmartinaxxesscozagt

To Lea September ltleailisocomgt

Sent Monday April 09 2012 1158 AM

Subject Comments on Galvanising Plant EIR Coega IDZ

gt Lea

gt

gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising

gt plant

gt

gt

gt Dr Paul Martin

gt PO Box 61029

gt Bluewater Bay 6212

gt Tel 041 4665698

gt Cell 0732524111

gt email pmartinaxxesscoza

gt

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 12 April 2012 1139 AM

To Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Hi Lea

Hope yoursquore keeping well

I have requested comments from my colleagues and the CDC Casa team on the Draft EIR

Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report

Regards

Andrea

From Graham Taylor

Sent Thursday April 12 2012 838 AM

To Andrea Von Holdt Firhana Sam

Cc Johan Fourie Maria van Zyl Melikhaya Sihawu

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Andrea Firhana

Firhana if you could please ensure that the co-ordinates provided in the EIR correspond

with our records (pages 4-1 amp 4-2)

My comments are as follows

It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work

Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above

Regards

Graham Taylor

Spatial Development Manager - Infrastructure Development

Mobile 0832283055

Office 0414030454

Facsimile 0865185033

Email GrahamTaylorcoegacoza

Website wwwcoegacom

right PLACE | right TIME | right CHOICE

This email and all contents are subject to the following disclaimer

httpwwwcoegacomemaildisclaimerhtml

From Lea September [mailtoleailisocom]

Sent 04 May 2012 0411 PM

To Andrea Von Holdt

Cc Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Dear Andrea

We have taken note of the comments from the GIS Unit These issues have been rectified in

the final version of the EIR

Please can you forward to the relevant persons at the GIS Unit

Thank you

Best regards

Lea September

APPENDIX E

BACKGROUND INFORMATION

DOCUMENT

APPENDIX F

AIR QUALITY IMPACT ASSESSMENT

APPENDIX G

TRAFFIC IMPACT ASSESSMENT

APPENDIX H

WASTE MANAGEMENT AND HAZARDOUS

SUBSTANCES SPECIALIST STUDY

APPENDIX I

WATER QUALITY SPECIALIST STUDY

APPENDIX J

ENVIRONMENTAL MANAGEMENT

PROGRAMME

Page 13: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-3

15 PROJECT TEAM

In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen

(water quality specialist) and Lea September (EAP) with specialist input from Renee

von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous

substances) and Seniel Pillay (Traffic Impact Assessor)

The Business Unit Head of the ILISO Environmental Management Discipline Group

Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is

a Fellow of the South African Institution of Civil Engineers a member of the South

African Society of Aquatic Scientists of the Environmental Scientific Association of

the International Water Association of the Water Institute of South Africa and of the

Vaal River Catchment Association He is a certified Environmental Assessment

Practitioner with 30 years experience who specialises in project management

environmental impact assessments and water resource planning He specifically has

extensive experience in water quality especially water quality management water

quality monitoring and water quality assessment Martin has experience in managing

projects that involve multi-disciplinary teams and public consultation and

participation in South Africa and abroad

Lea September is an Environmental Assessment Practitioner with a Masters degree

in Environmental Management She has experience in impact assessment and

environmental management and has been responsible for drafting impact

assessment reports and Environmental Management Programmes and conducting

public participation processes as well as high level environmental screenings for a

variety of projects in the energy water transport and industrial sectors

Renee von Gruenewaldt has nine-years experience in the field of air pollution

impact assessment and air quality management Prior to becoming involved in air

quality consultation she was part of the Highveld Boundary Layer Wind Research

Group based at the University of Pretoria Since joining Environmental Management

Services (the company now Airshed Planning Professionals) she has undertaken

numerous air pollution impact studies and has provided extensive guidance to both

industry and government on air quality management practices

Pieter Smuts graduated as a Civil Engineer and became involved in the field of

municipal engineering and infrastructure construction He has specialized during the

last twelve years in solid waste management He has completed waste management

plans feasibility studies and final designs of waste management facilities in South

Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and

the review of the Mavoco hazardous waste landfill design in Maputo Mozambique

and completed a study on hazardous waste (textile factory sludge) management in

Maseru Lesotho

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 1-4

Seniel Pillay is a transportation engineer with over 16 years experience in

transportation planning and traffic engineering He has been involved in a wide

range of projects ranging from developing the Transport Operations Plan for the

FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System

for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller

traffic impact assessments for inter alia road improvement schemes Of particular

relevance to this project his experience includes Heavy Goods Vehicle Study for

eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact

Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash

Preliminary Transportation Assessment

16 STRUCTURE OF THIS REPORT

The proposed project and the alternatives considered are described in Chapter 2

Chapter 3 details the approach adopted for the EIA phase

The biophysical and socio-economic environment affected by the activity is described

in Chapter 4

The environmental impacts identified are discussed in Chapter 5

The EIA methodology is described in Chapter 6 and Chapter 7 presents the results

of the impact assessment

The environmental impact statement is presented in Chapter 8

Finally Chapter 9 spell out the conclusions and recommendations

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-1

2 DESCRIPTION OF THE PROPOSED PROJECT

21 TECHNICAL ASPECTS

211 The galvanizing process

Galvanizing consists of coating steel with zinc in order to protect it from corrosion

Before steel strips can be galvanized they undergo a pre-treatment in order to

ensure that the steel sheets are free from any surface oxides as they enter the

molten zinc coating Bath This is done by removing the oil from the steel sheets (in

the degreasing unit) and then removing the rust from the surface of the sheet (in the

pickling unit)

The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The

melting zinc on the strip surface will be cooled and solidified through air cooling in the

cooling tower

Finally the galvanised steel sheets are dipped into a water quenching tank in order to

further cool the sheets from about 150degC to 40degC

It is possible to make galvanised steel more durable by chromating it Approximately

50 of the galvanised steel production output will receive chromate passivation

treatment after quenching the galvanised steel sheets will be sprayed with a chrome

solution (3 kgcm2)

After galvanizing and chromating the steel sheets are cut to achieve the desired coil

size and weight and transported to the storage yard

The process flow diagram below (Figure 1) illustrates the main stages of the

galvanizing process and indicates the major inputs and outputs as well as the

resulting effluent and atmospheric emissions

Draft Environmenal Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-2

Figure 1 Process flow diagram for proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 2-3

212 Main inputs and outputs in operational phase

In view of the above the main inputs will be as follows

Steel coils 85 000 tonsyear

Zinc 870 tonsyear

Electricity 2500 kVA

Water 2000 m3month (of which 400 m3 will be potable water)

Liquid Natural Gas (LNG) 270 NM3hour

Sodium hydroxide (NaOH) 1000 m3year

Hydrochloric acid (HCl) 800 m3year

Chrome (Cr+3) 10 m3year

The main outputs will be

Galvanized steel 80 000 tonsyear

Scrap metal 20 tonsyear

General waste 65 tonsyear

Hazardous waste 2 m3month

Wastewater 012 Mlweek

Atmospheric emissions lt 5 ppm

213 Installations on site

The bulk of the operations involved in the galvanizing process occur along a

continuous galvanizing line (See Figure 2 below) which is the main piece of

machinery required for the proposed galvanising plant

Figure 2 Continuous Galvanizing Line

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-4

Water is one of the major inputs and is used throughout the galvanizing process notably

for rinsing and cooling purposes and as a mixing agent for the various chemical

solutions The plant will have a water treatment plant on site to treat the water used in

the various processes (approx 250 m3

of wastewater per week) The wastewater

treatment facility will be operated by a professional water treatment company as Casa

Steel does not have the required expertise in house to treat its process water Sulphuric

acid (H2SO4) is used as part of the treatment process to reduce caustic soda The

neutralised water is discharged to the sewer while any sludge is disposed of as

hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)

will be disposed of

Some critical areas of the galvanizing process such as the zinc pot require uninterrupted

power It is therefore proposed to install an LNG burner to maintain the zinc bath at a

temperature of between 450 and 460degC

22 LOCATION OF THE PROPOSED GALVANIZING PLANT

The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast

of Port Elizabeth in the Eastern Cape (Figure 3)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-5

Figure 3 Location of the proposed galvanizing plant

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-6

23 NEED AND DESIRABILITY

The profitability of the proposed project has been established by Casa Steel and a

pre-feasibility study has confirmed that the proposed project was feasible from a

technical and financial point of view The Coega IDZ is specifically designed to host

facilities such as a galvanizing plant and can provide the necessary infrastructure

and services to its investors It therefore constitutes a very suitable location for the

project

24 ALTERNATIVES IDENTIFIED

Zone 6 has been specifically earmarked for heavy ferrous metal industries and is

therefore a suitable location for the proposed galvanizing plant as such no site

alternatives have been provided for and assessed in this EIA However prior to the

commencement of the EIA process Casa Steel was presented with a number of

different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the

selection of the site were

(a) The dimensions of the land the site should be at least 200 m long and

50 m wide in order to accommodate the galvanizing line and adjacent lay

down area and additional land should be available next to the site for future

expansion

(b) The fiscal arrangements applying to the site the site should be located

within the future Custom Controlled Area (CCA) as the bulk of the

production output of the plant will be exported

The no-go alternative is assessed in this report

25 CONSTRUCTION ASPECTS

The construction phase of the project will take about 12 months and will essentially

consist of erecting a building to house the galvanizing line and other equipment and

preparing a concrete laydown area adjacent to the building

The CDC will provide an access point from the existing tarred road that will lead to

the site

Approximately 100 workers from the surrounding areas will be contracted for the

construction work

The requirements in terms of services during construction are listed below

Water 1000 m3month

Electricity 2500 kVA

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 2-7

The CDC will provide temporary services for the construction phase including a

conservancy tank for flush toilets Sewage infrastructure will only be provided for the

operational phase

26 OPERATION ASPECTS

Before the plant can become fully operational the equipment and machinery will be

tested for approximately 3 months The supplier will supervise these tests as part of

the transfer of know-how and training of staff on the plant

Casa Steel will start operating the plant at a reduced capacity (about 50 000

tonsyear) for a period of time (mostly determined by market aspects) before bringing

production to full capacity (80 000 tonsyear) This is done by operating the line for

longer hours

Approximately 50 to 60 people will be working on the plant Approximately 6-10 of

these will be unskilled 40-45 skilled and about 5 people in managerial positions

The requirements in terms of services during operation are as follows

Water 2000 m3month

Electricity 2500 kVA

Effluent discharge 24 m3day

The CDC has entered into agreements with the municipality to secure the provision

of services such as water and electricity to its tenants Tenants in the IDZ have their

own agreements with the NMBM for electricity while the agreements for water and

sewage are with the Facilities Unit of the CDC

Regarding discharge of wastewater to the sewer the municipality indicated that the

only requirement is that the water discharged complies with applicable municipal

discharge standards

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 3-1

3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT

31 OBJECTIVES

The main objectives of the EIA phase are to

Assess the significance of the environmental issues and impacts identified in the

scoping phase focusing on key impacts

Recommend appropriate measures to mitigate negative impacts and enhance the

benefits and include them in the draft EMP

Undertake a public participation process that provides opportunities for all

interested and affected parties (IampAPs) to be involved

32 AUTHORITY CONSULTATION

The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental

Liaison Committeersquo (ELC) which comprises representatives of various authorities

including DEDEAT the Department of Environmental Affairs (DEA) and Department

of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the

Coega Development Corporation (CDC) and Transnet National Ports Authority

(TNPA) The ELC has been specifically formed to facilitate EIA applications in the

IDZ

Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to

the clearance of vegetation should be included in the application A formal request

was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the

application and all registered stakeholders were informed of the request in writing on

19 October 2011

33 PUBLIC PARTICIPATION PROCESS CONDUCTED

On-site notices were replaced by a notification displayed on the CDCrsquos digital notice

board at the business centre in Zone 1 of the IDZ The eNotice was placed on

13 April 2011 and will remain for the full duration of the EIA process

Registered stakeholders will be notified in writing of the availability of the draft EIA

report and EMP which will also be advertised in a local newspaper Stakeholders

including state departments and the public will have forty (40) days to comment on

the draft EIA report and EMP The draft EIA report and EMP will be sent by email

where possible and made available for download on the ILISO website

(wwwilisocom)

A summary of all issues and comments received during the stakeholder consultation

process as well as of correspondence in that regard will be captured in an Issues

and Responses Report that will form an Appendix to the EIA Report

The list of registered IampAPs is included in Appendix A

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 3-2

34 LEGISLATION AND GUIDELINES CONSIDERED

The following legislation and guidelines were considered in the preparation of this

report

National Environmental Management Act Act No 107 of 1998

NEMA EIA Regulations 2010

National Environmental Management Air Quality Act Act No 39 of 2004

National Environmental Management Waste Act Act No 59 of 2008

Hazardous Substances Act Act 15 of 1993

Occupational Health and Safety Act Act 85 of 1993

Hazardous Chemical Substances Regulations 1995 (GNR 1179)

Major Hazard Installation Regulations 2001 (GNR 692)

National Water Act Act 36 of 1998

National Heritage Resources Act Act 25 of 1999

DEAT Integrated Environmental Management Information Series 1-5 and 12-15

NEMA draft Implementation Guideline

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Public Participation (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Guideline on Alternatives (2007)

Western Cape Department of Environmental Affairs and Development Planning

NEMA Environmental Impact Assessment Regulations Guideline and Information

Document Series ndash Draft Guideline for Determining the Scope of Specialist

Involvement in EIA Processes (2005)

IAIA guidelines

National air quality standard for thoracic particulates Government Gazette

No 32816

Listed activities and associated minimum standards identified in terms of section

21 of the National Environmental Management Air Quality Act Act No 39 of

2004 Government Notice 248 of 2009

Minimum Requirements for the Handling Classification and Disposal of

Hazardous Waste DWAF Waste Management Series (1998)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-1

4 DESCRIPTION OF THE AFFECTED ENVIRONMENT

41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION

The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega

IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay

to the north of the N2 highway between Port Elizabeth and Grahamstown east of the

Coega River

The co-ordinates of the corners of the site are shown in Table 1

Table 1 Coordinates of site corners for the proposed galvanizing plant

Point Longitude Latitude

A 25deg411126E 33deg45587S

B 25deg411156E 33deg45499S

C 25deg411938E 33deg45131S

D 25deg412174E 33deg45481S

E 25deg412508E 33deg45979S

F 25deg412634E 33deg451160S

G 25deg411782E 33deg451560S

H 25deg411692E 33deg451428S

J 25deg411314E 33deg45868S

Figure 4 Zone layout in the Coega IDZ

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-2

Figure 5 Site location

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-3

42 SOCIO-ECONOMIC CHARACTERISTICS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the

NMBM There are no residents within the IDZ

As far as the broader NMBM and Eastern Cape Province are concerned the

following can be noted The NMBM is located within the Eastern Cape Province the

2nd largest Province in South Africa (3rd in terms of population) characterised by a

predominantly black population with low incomes and high levels of unemployment

(CES 2010)

The NMBM has a population of just above 11 million and covers an area of

1 950 km2 It is the main urban and industrial centre of the province and Port

Elizabeth in particular which forms part of the NMBM is the commercial capital of

the Eastern Cape 52 of the NMBM population is female and 37 is below the

age of 20 these two groups are particularly affected by unemployment

43 BIOPHYSICAL CHARACTERISTICS

431 Surface and ground water

No rivers occur in Zone 6 There is however a natural attenuation pond on the

southern most part of the site which will have to be avoided

The IDZ is underlain by calcrete sand and gravel deposits that overlie low

permeability clays These clays limit the vertical infiltration of rainwater and induce a

horizontal groundwater flow towards the Coega River channel which is the most

significant surface water feature in the Coega IDZ Consequently rapid run-off takes

place following precipitation (Jacobs 2008)

Groundwater levels at Coega are generally about 3 to 5 m below surface ie just

above the contact between the permeable sands and the underlying impermeable

clays The groundwater flow direction is to the southeast following the surface water

drainage direction (Jacobs 2008)

432 Climate and atmospheric conditions

Port Elizabeth has a warm temperate climate and the temperature ranges are not

extreme Exceptionally high temperatures may be experienced during berg wind

conditions which occur frequently during autumn and winter Extreme temperatures

also occur during summer with little accompanying wind

The wind regime for the area largely reflects the synoptic scale circulation with

dominant westerly and northwesterly flow fields representing the pre-frontal

conditions and south-westerly flow fields representing the frontal conditions The

south-easterly and south-westerly wind flow (land breeze) increases during daytime

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-4

conditions with westerly and north-westerly wind flow increasing during the night (sea

breeze)

The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of

Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15

km southwest) and Port Elizabeth (~23 km southwest)

An ambient air monitoring network has been established in the Coega IDZ which

consists of three monitors Saltworks Motherwell and Amsterdamplein Although

NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative

impacts due to the proposed Galvanising Plant is PM10 A maximum daily average

PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed

SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3

was exceeded on 17 days in 2007 and 26 days in 2008

Existing sources of emissions in the vicinity of the proposed galvanizing plant include

industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other

fugitive dust sources (von Gruenewaldt 2011b)

433 Geology and soils

Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel

and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly

limestone and conglomerate

434 Terrestrial ecology

This section draws from the EIA report compiled for the Agni Steel (formerly Afro-

Asia) steel processing facility which is adjacent to the proposed site for the

galvanizing plant (Jacobs 2008)

The area consists largely of grasses succulents and scrubby bush with alien

species making up the greater part of the more dense vegetation

Zone 6 falls within the inland vegetation and is characterised by a vegetation type

referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the

Coega IDZ and has been found to have three times the level of endemism of other

vegetation communities in the Coega IDZ Bontveld therefore has a high

conservation status Two Bontveld conservation areas have been identified within the

IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)

Bontveld that will be destroyed as a result of development in the IDZ will be given

conservation status in these two areas

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-5

Figure 6 Coega IDZ Open Space Management Plan (OSMP)

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 4-6

Certain areas in the IDZ are invaded by alien plant species The most common

invader species is rooikrans (Acacia cyclops) which presently forms large

monospecific stands in areas throughout the Coega IDZ There are several other

aliens present that pose a threat to the flora of this area including the prickly pear

(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)

Loss of vegetation and alien plant invasion due to human activity has resulted in a

reduction in the diversity of terrestrial fauna

The majority of mammals present in the Coega IDZ are small or medium-sized Of

the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed

gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of

Algoa Bay however it is not considered threatened The gerbil is common in

foredune and dune thicket habitat in the Coega region and is therefore unlikely to

occur on the proposed site

A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird

species are resident or common to the area Most diversity occurs in the thicket

although the coastal area also supports specialised avifauna Two species of tern

the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well

as the Cape gannet (Morus capensis) and the African penguin (Spheniscus

demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne

caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant

(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser

flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns

are two of the most endangered coastal species in South Africa Other bird species

of conservation concern include the Whitefronted plover (Charadrius marginatus)

African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus

bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus

ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides

paradisea) Breeding pairs of Damara terns and African black oyster catchers have

been observed in the coastal dunes of the IDZ but should not be affected by

developments that fall outside the dune areas

The Eastern Cape supports nearly a third (approximately 133 species) of the reptile

species recorded in South Africa More than half of the Eastern Capersquos endemic

reptile species occur in the Algoa Bay area giving the region a high conservation

value A total of 63 reptile species are believed to occur within the Coega IDZ The

majority of these are found in Succulent Thicket and riverine habitats Only a few

reptile species occur in the coastal dunes and estuarine habitats More than a third of

the species are described as relatively tolerant of disturbed environments provided

that migration corridors of suitable habitat are maintained to link pristine habitats

Twenty two reptiles are of special concern including five endemic species (two of

which may also be endangered) four endangered sea turtles eight species listed

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-7

with CITES one rare species and four species at the periphery of their range

Fourteen of these species of special concern are confirmed as occurring on or within

2 km of the Coega IDZ

A total of 32 amphibian species and sub-species occur in the Eastern Cape

representing almost a third of the species recorded in South Africa However none of

the species are endemic or Red Data Book species Based on previous studies in the

area it is estimated that approximately 17 amphibian species occur within the Coega

IDZ Four species are listed as peripheral but none are threatened internationally

These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog

(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and

the bubbling kassina (Kassina senegalensis)

The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated

vegetation has not been extensively studied One grasshopper species Acrotylos

hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue

(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis

pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in

four localities in the Eastern Cape one of which is within the Coega IDZ The Coega

copper Aloeides clarki is endemic to this particular region of the Eastern Cape and

is currently known to occur in three localities two of which are in the Coega IDZ The

localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the

Coega IDZ and their distributions were taken into account when defining Coegarsquos

open space system and Development Framework Plan

435 Land use and topography

The land is currently undeveloped and earmarked for industrial development The

site is relatively flat ranging from an elevation of 66 masl on the northern-most

corner to 59 masl at the southern-most corner

436 Heritage and archaeological survey

Extensive studies have been undertaken in Zone 6 with respect to heritage aspects

Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a

2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond

2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is

currently being finalised

Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing

Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha

in extent and was located next to the R102 road to Motherwell Kaplan conducted

HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi

Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will

now be located in Zone 5)

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 4-8

The various archaeological investigations reached similar observations and

conclusions Stone tools of various densities and types were found throughout the

zone The majority of the stone tools were mainly of Earlier and Middle Stone Age

and occasional Later Stone Age origins (Figure 4)

Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble

gravels exposed by tracks in Zone 6 (Source Binneman 2010)

The stone tools which comprised of quartzite flakes chunks flaked pebblecobble

and cores were randomly distributed across the landscape and are in secondary

context There were no lsquoconcentrationsrsquo of tools observed which suggested any

spatial patterning or activity areas although these may be present or covered by soil

and vegetation

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 5-1

5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED

The following environmental issues and potential impacts were identified in the

Scoping phase

51 AIR QUALITY

The galvanizing process generates atmospheric emissions with particulates and

hydrogen chloride representing the main pollutants of concern The plant is fitted with

air extraction as well as scrubber systems which are designed to retain the bulk of

pollutants and particles for each of the processes in such a way that less than 5 ppm

of gases and particles will be released into the atmosphere after the fume scrubber

Other sources of impact on air quality include emissions from the LNG burner as well

as emissions and dust from the transport of steel and other materials in trucks

Construction activities will also create dust and gas emissions due to the clearing of

groundcover tipping of material to storage pile levelling of area wind erosion from

storage piles vehicle and construction equipment activity and tailpipe emissions

from vehicles and construction equipment such as graders scrapers and dozers

Overall the air quality impact assessment (Gruenewaldt 2011b) found that

The predicted particulate oxides of nitrogen carbon monoxide and sulphur

dioxide concentrations are all below the National Ambient Air Quality Standards

for all averaging periods

The predicted off-site concentrations of hydrogen chloride are well below the

most stringent effect screening levels

No odour threshold exceedances for hydrogen chloride were predicted to occur

due to routine operations at the Steel Galvanising Plant The South Wales

Environmental Protection Authority stipulates that an odour unit of 20 is

acceptable for urban areas The odour unit would be lt10 directly off-site for

hydrogen chloride

Abnormal emissions can occur in exceptional circumstances Start-up will not

cause abnormal emissions as the scrubbers will be commissioned first and will be

functioning once the plant starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions would be emitted as a

building fugitive

The hourly hydrogen chloride ground level concentrations (directly offsite) were

predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based

on the emission limits as stipulated for listed activities for galvanising processes)

using a screen model which assumes worst case meteorological conditions The

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-2

health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming

abnormal emissions emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset conditions will still

be well within the health effect screening levels

Similarly the hourly particulate emissions from the building fugitives during upset

conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for

listed activities for galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly

off-site

Therefore if emissions are 5 times higher normal they will still be within health effect

screening levels and the daily PM10 NAAQS levels

In the case of a fire a cocktail of gases and particulates could be emitted and could

be over the recommended levels This situation will however be dealt with as an

emergency and normalised as quickly as is possible

52 HERITAGE AND ARCHAEOLOGICAL ASPECTS

The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of

its heritage potential and there are no proposed protected geosites in Zone 6

Should any artefacts be discovered during construction procedures stipulated in the

draft EMP will apply

53 BIODIVERSITY AND CONSERVATION

Certain types of vegetation in the IDZ are of high conservation importance and the

CDC has compiled a list of protected species to be rescued

In terms of terrestrial fauna the CDCrsquos open space management plan provides for

the preservation of certain corridors The destruction of certain habitats as a result of

the development will therefore not automatically result in the loss of certain species

54 WATER QUALITY

There is a natural attenuation pond on the southern most part of the site which will be

avoided

The substances used in the galvanizing process and the effluent resulting from it are

potentially hazardous and can cause the contamination of water resources through

spills or leaks

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-3

This risk can however be minimized if not avoided altogether The floor of the factory

will be designed as a bunded area to contain any spills and the entire process will be

contained Potential spills or leaks will therefore be contained and will not impact on

water resources Storm water is therefore considered clean water under normal

operational conditions An oil trap will be placed at the exit of the site to ensure that

no grease from the laydown area enters the stormwater system

Spills and leaks can occur during the handling or the transport of hazardous

substances Best practice guidelines will be followed to ensure that this risk is

adequately managed

Wastewater discharged to sewer will be treated to comply with municipal discharge

standards and is not expected to have an impact on the chemical characteristics of

the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be

discharged from the plant is small in relation to the total volume received at the

Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works

(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently

operated at 61 of its capacity which is approximately 80 Mℓday Thus the

0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore

not have any significant impact on the WWTW

Periodic effluent and stormwater quality monitoring will be undertaken to ensure

compliance with the applicable standards

55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES

The plant will generate a relatively small amount of solid waste in the form of scrap

metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)

The scrap metal may be sold to other steel processing facilities such as Agni Steel

which will be located next to the plant or collected and disposed of with the rest of

the solid waste by a licensed service provider

As mentioned previously there will be a wastewater treatment plant on site which will

neutralise process water (012 Mlweek) in order to ensure it is of a standard

acceptable for discharge to sewer Waste in the form of sludge from the

neutralization or spent acid must be disposed of as a hazardous waste Solid waste

from the filters used for air quality control is also in this category These wastes can

usually be tested and then delisted which means that it can be placed in a general

purpose landfill

Hazardous effluent from the galvanizing and chromating processes (approx

10 tonsmonth) will be collected by a licensed service provider to be disposed of off-

site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored

and removed on a monthly basis is limited to 10 m3

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-4

A number of substances classified as hazardous are used in the galvanizing process

(Table 2) and the transport and handling of these is subject to certain rules and

guidelines In particular the material safety data sheets (cf Appendix H) should be

referred to for inter alia hazards identification accidental release measures

handling and storage precautions exposure controlpersonal protection ecological

information and transport information The Hazardous Chemical Substances

Regulations 1995 should also be adhered to in respect of the transport and storage

of hazardous chemical substances

Table 2 Hazardous materials to be used on site

Major Input Materials

Substance

listed in the

SABS 0228

Group II

hazardous

substances

Volumes to be

stored on site at

any one time

Diesel radic 2000 litres

Liquid petroleum radic 20 000 liters

Sodium hydroxide (NaOH)

(used for degreasing) 8 radic 1000m

3

Hydrochloric acid (HCI)

(used for pickling) 8 radic 800m

3

Zinc (used for galvanising) - TBD

Trivalent chromium (CR+3

)

(used for chromating) 8 radic 10m

3

Sulphuric acid (H2SO4) (used for

treatment of waste water on site) 8 radic TBD

Ammonium Hydroxide (NH4OH) 8 radic TBD

TBD ndash To be determined

Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one

time) and is classified as a flammable substance Specification for flammable storage

facilities in accordance with the requirements of the Nelson Mandela Bay

Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for

quantities between 5000 and 20 000 liters the substance must be kept in a

flammable liquid store which complies with the requirements of a specification

obtainable from the Department Some of the requirements are

Flammable liquid and solid storage facilities are only permitted on the ground

floor

Decanting of flammable liquids and solids are not permitted within any building

Due to the fact that there are flammable materials on site a certificate may be

required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and

Emergency Services Department to confirm that facilities for flammable storage

are in accordance with their requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-5

Because of the permanent installation and high quantity of liquid petroleum on site

the Major Hazard Installation Regulations 2001 promulgated under the Occupational

Health and Safety Act No 85 of 1993 applies A written application for approval of

the installation is required to be submitted to the chief inspector Department of

Labour provincial director Department of Labour and NMBM prior to construction

In addition a risk assessment should be formulated covering all hazardous materials

together with an emergency preparedness and response plan

56 HEALTH AND SAFETY

Several aspects of the galvanizing process present potential risks for the health and

safety of workers on site The handling of dangerous substances and the operation of

the equipment of the plant for instance present risks that should be prevented and

managed adequately in order to ensure the health and safety of workers on site

Storage transport and handling instructions as well as occupational exposure limits

are indicated in the material safety data sheets of the various substances used

Insofar as the operation of plant equipment and machinery is concerned the supplier

will provide quality control methods and standard operating procedures prepare

operation and maintenance manuals and train the staff in that regard as well as

provide site supervision including executing tests (individual test cold run and hot

run) during 3 months

New staff members will undergo induction and awareness training to sensitize them

about the environmental health and safety risks on site and the contents of the

EMP

In addition the emergency preparedness and response plan will cover the health and

safety aspects related to emergency situations

57 TRAFFIC

The volumes of traffic at the IDZ are currently relatively low and variable depending

on the different zones in the IDZ however these volumes will increase as more

developments are implemented

The construction phase of the Casa Steel development will take about 12 months

and will essentially consist of erecting a building to house the galvanizing line and

other equipment and preparing a concrete laydown area adjacent to the building

The traffic that would be generated during the construction phase can be expected to

be less than the traffic that would be generated by the Casa Steel development when

it is fully operational

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-6

In the operation phase the main sources of traffic will be the transport of personnel

and the transport of steel products (raw materials and galvanized steel coils) to and

from the Port of Ngqura

The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the

Casa Steel development would be off Ring Road 1 The other roads of significance

for the Casa Steel development are the N2 Neptune Road MR435 and MR450

Access to the port is given by Neptune Road Road Link NEP-03 has not yet been

built

Figure 8 Coega IDZ road network identification

(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-7

Figure 9 Coega IDZ road network

Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No

01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-8

The distribution of freight trips is fixed as the majority of trips will be made between

the Port of Ngqura and the Casa Steel site With regard to personnel trips there are

various points of origins (the surrounding residential areas) that could be used by

staff going to the Casa Steel site The distribution of personnel trips is based on

existing traffic count information and is shown in Figure 10

Figure 10 Trip distribution for freight and personnel trips

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The resultant expected Casa Steel traffic assignment is shown in Figure 11

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-9

Figure 11 Morning peak hour Casa Steel development traffic

Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007

The traffic that is expected to be generated by the Casa Steel development is

expected to have a negligible impact on the road network (N2 Ring Road 1 MR435

MR450 and Neptune road) in terms of capacity since current traffic volumes are low

and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)

Consultation has taken place with Transnet Port Authority (TPA) to establish the

impact of the galvanizing plant operations on traffic inside the port The additional

ships entering and exiting the port of Ngqura as a result of the proposed development

will have a negligible impact on port traffic and TPA indicated that it would be well

within the portrsquos capacity

58 NOISE

Noise is not foreseen to be a significant issue insofar as the noise levels inside the

plant and at the boundary of the site will not exceed the limits prescribed by the CDC

Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels

during the day and 60 decibels at night

Mitigation of noise impacts will be addressed in the design of the noise-emitting

components of the plant and their enclosures

N

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 5-10

59 SOCIO-ECONOMIC ASPECTS

The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of

NMBM There are no residents within the IDZ

The direct socio-economic impacts of the proposed project are thus limited to the

employment generated by the project during construction and operation Job creation

remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)

and the IDZ and Port of Ngqura are expected to become a significant catalyst to the

economic growth of the Municipality and the region with current investments at

Coega creating more jobs and stimulating the economy

In this context the proposed galvanizing plant will make a positive contribution

towards the achievement of these goals

There will be 50 to 60 employees during operation phase distributed as follows

Figure 12 Casa Steel organisation chart

Even though a large part of the inputs will be imported and the bulk of the production

output will be exported there will be some positive impacts for the economy of the

region and of South Africa in general Notably the requirements of the plant for

water electricity waste collection and disposal waste water treatment and transport

for example will create business for the various service providers and have an

indirect impact on employment and fiscal revenues as a result

From a visual impact point of view it can be anticipated that the landscape in the IDZ

will be significantly affected over time by developments related to the establishment

of the port and various industries

HEAD ( WORKS )

MGR ( COMM) MGR ( ADMNHR ) Manager marketing

MANAGER OPERATION MANAGER MANAGER MANAGER Q C

AC FIN PUR ampSTORE

PPC SH-GALV SH-tech

SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF

1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO

JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF

2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO

WORKERS WORKERS 7NOS

15 7

RAW MAT amp

DESP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 6-1

6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY

A description of the nature of the impact any specific legal requirements and the

stage (constructiondecommissioning or operation) will be given Impacts are

considered to be the same during construction and decommissioning The

significance of the potential impacts will be considered before and after identified

mitigation is implemented

The following criteria will be used to evaluate significance

Nature The nature of the impact will be classified as positive or negative and

direct or indirect

Extent and location Magnitude of the impact and is classified as

Local the impacted area is only at the site ndash the actual extent of the activity

Regional the impacted area extends to the surrounding immediate and

neighbouring properties

National the impact can be considered to be of national importance

Duration This measures the lifetime of the impact and is classified as

o Short term the impact will be for 0 ndash 3 years or only last for the period of

construction

o Medium term three to ten years

o Long term longer than 10 years or the impact will continue for the entire

operational lifetime of the project

o Permanent this applies to the impact that will remain after the operational

lifetime of the project

Intensity This is the degree to which the project affects or changes the

environment and is classified as

o Low the change is slight and often not noticeable and the natural functioning

of the environment is not affected

o Medium The environment is remarkably altered but still functions in a

modified way

o High Functioning of the affected environment is disturbed and can cease

Probability This is the likelihood or the chances that the impact will occur and

is classified as

o Low during the normal operation of the project no impacts are expected

o Medium the impact is likely to occur if extra care is not taken to mitigate

them

o High the environment will be affected irrespectively in some cases such

impact can be reduced

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 6-2

Confidence This is the level knowledgeinformation the environmental impact

practitioner or a specialist had in hisher judgement and is rated as

o Low the judgement is based on intuition and not on knowledge or

information

o Medium common sense and general knowledge informs the decision

o High Scientific and or proven information has been used to give such a

judgment

Significance Based on the above criteria the significance of issues will be

determined This is the importance of the impact in terms of physical extent and

time scale and is rated as

o Low the impacts are less important

o Medium the impacts are important and require attention mitigation is

required to reduce the negative impacts

o High the impacts are of great importance Mitigation is therefore crucial

Cumulative Impacts The possible cumulative impacts will also be considered

Mitigation Mitigation for significant issues is incorporated into the EMP for

construction

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 7-1

7 ASSESSMENT OF ENVIRONMENTAL IMPACTS

71 IMPACTS DURING CONSTRUCTION

711 Air quality

Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris

handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine

particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural

operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks

and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)

Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Fugitive particulate emissions (dust)

related to construction activities Regional

Short

term Medium High High Medium Regional

Short

term Low High High Low

Construction vehicle gas emissions Regional Short

term Medium High High Medium Regional

Short

term Low High High Low

712 Heritage and archaeological resources

Naturedescription of impact excavation activities may impact on unidentified heritage resources

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-2

Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based

on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments

Heritage and archaeological

resources Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on unidentified heritage

resources Local

Short

term

Medium -

high Low High Low

713 Biodiversity and conservation

Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation

importance and cause soil contamination

Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species

Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan

and has compiled a list of protected species to be rescued (see draft EMP)

Biodiversity and conservation Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Loss of fauna and flora Local Perma

nent

Medium -

high High High High Local

Permanen

t Medium High High Medium

Soil contamination Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-3

714 Water related impacts

Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater

runoff spills and leaks Soil erosion

Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of

spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste

disposal Stormwater quality monitoring (see draft EMP)

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Soil erosion Local Short

term Medium Medium High Medium Local

Short

term Medium Low High Low

715 Waste management

Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed

Commentmitigation see draft EMP and waste management plan

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-4

Waste management Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Local

Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

716 Health and safety

Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Short

term

Medium -

high

Medium -

high High High Local

Short

term

Medium -

high Low High Low

717 Traffic

Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and

construction workers from surrounding areas and transport of equipment from the port

Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low

Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and

accurate estimates of quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-5

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Increased traffic on N2 and within the

IDZ Regional

Short

term Low High High Low

718 Noise

Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Short

term

Medium-

high High High Medium Local

Short

term Medium High High Medium

719 Socio-economic

Naturedescription of impact temporary employment will be created during the construction phase

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-6

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Temporary employment Regional Short

term Medium High High Medium

72 IMPACTS DURING OPERATION

721 Air quality

NatureDescription of impact gas and particulate emissions

Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle

exhaust emissions and household fuel burning

Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local

sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and

veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute

to background fine particulate concentrations (von Gruenewaldt 2011b)

Assumptions and limitations Potential release of CR6+

As no emission factors are available for trivalent chromium processing the

potential impacts due to these activities could not be quantified

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Dust emitted from traffic on paved roads Regional Long Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-7

Air quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

term

Hydrogen chloride emissions from

pickling process Local

Long

term Low High High Low

Particulate emissions (smoke) from

galvanizing process (due to the

volatilization of flux)

Local Long

term Low High High Low

Particulate oxides of nitrogen carbon

monoxide and sulphur dioxide emissions

from LNG burner

Local Long

term Low High High Low

Nuisance related to odour Local Long

term Low Low High Low

Abnormally high hydrogen chloride and

particulate emissions due to scrubber

malfunction

Local Short

term Medium Low High Medium

Gases (eg SOx NOx CO etc) and

smoke emitted in case of a fire Local

Short

term High Low High Medium

722 Water quality

NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks

Commentmitigation see draft EMP

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-8

Water quality Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Surface and groundwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Stormwater contamination Regional Short

term

Medium -

high Medium High Medium Regional

Short

term

Medium -

high Low High Low

Impact on attenuation pond Local Short

term

Medium -

high Medium High Medium Local

Short

term

Medium -

high Low High Low

723 Waste management and hazardous substances

NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous

waste both can affect environmental quality and human health

Commentmitigation see draft EMP and waste management plan

Waste management and hazardous

substances Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Soilwaterair pollution due to improper

waste handling storage and disposal Regional

Long

term High

Medium -

high High High Regional Long term High Low High Low

Soilwaterair pollution due to improper

transport storage and handling of

hazardous substances

Regional Long

term High

Medium -

high High High Regional Long term High Low High Low

Health hazard Local Long

term High

Medium -

high High High Local Long term High Low High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-9

724 Health and safety

Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site

Commentmitigation see draft EMP

Health and safety Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Health and safety hazards Local Long

term

Medium-

high

Medium-

high High High Local Long term

Medium-

high Low High Low

725 Traffic

Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on

the road network

Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak

hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road

network within Zone 6 of the IDZ (Iliso 2011)

Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)

Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of

quantities and weights of materials and equipment are not yet available

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-10

Traffic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Impact on traffic and capacity of the N2 Regional Long

term Low High High Low

Impact on traffic and capacity of ring

road 1 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR435 Local

Long

term Low High High Low

Impact on traffic and capacity of the

MR450 Local

Long

term Low High High Low

Impact on traffic and capacity of

Neptune road Local

Long

term Low High High Low

726 Noise

Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities

Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)

Noise Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Nuisance Local Long

term Medium High High Medium Local Long term Low High High Low

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 7-11

727 Socio-economic

Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate

revenue for the municipality and the region as a whole

Socio-economic Pre-mitigation Post-mitigation

Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance

Employment and economic growth Regional Short

term Medium High High Medium

73 COMPARATIVE ASSESSMENT OF IMPACTS

During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as

low during operation after mitigation

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 8-1

8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

The draft EMP outlines how negative environmental impacts will be managed and

minimized during and after construction The EMP fulfils the GN 543 requirements

Recommendations are given with regard to the responsible parties for the

implementation of the EMP

As a tenant operating in the IDZ Casa Steel will be required to comply with all

current and future CDC requirements as well as with the relevant conditions of

permits licences issued to CDC (eg Integrated Stormwater Masterplan for the

eastern side of the Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)

In particular the CDC has its own requirements regarding the monitoring of certain

aspects of the project such as the quality of the effluent and the noise levels These

have been incorporated into the EMP

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 9-1

9 ENVIRONMENTAL IMPACT STATEMENT

All predicted negative impacts can be mitigated to a low significance The only

exceptions are biodiversity as the construction of the plant will result in the

destruction of habitat and loss of fauna and flora and noise impacts inherent to

construction activities Mitigation measures have been included in the EMP for these

impacts and they have a medium significance post-mitigation

Specifically the following conditions should be adhered to

Plant rescue in accordance with the CDCrsquos requirements (pre-construction and

construction phases)

Regular monitoring of noise levels (construction and operation)

Regular monitoring of effluent and stormwater quality (operation)

The temporary jobs created during construction of the plant and permanent

employment and economic growth generated by operation are the main positive

impacts of the project

The no-go option will result in a status quo in terms of impacts in the short-term and

the maintenance of the baseline as described in chapter 4 although in the medium to

long term similar impacts are likely to occur due to ongoing developments in the IDZ

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 10-1

10 CONCLUSION AND RECOMMENDATIONS

The proposed project is ideally located within an area earmarked for industrial

development and will benefit from the proximity of the Port of Ngqura as well as

other infrastructure and services available in the IDZ

All potentially significant environmental impacts of the project have been identified

and assessed No fatal flaws have been identified

It is recommended that the project be approved subject to the conditions listed in

chapter 9 and adherence to the EMP requirements

Final Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

April 2012 11-1

11 REFERENCES

Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ

Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants

Bennie JS (2010) The historical component (built environment) of the Heritage

Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port

Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report

compiled for Eastern Cape Heritage Consultants

Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater

Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay

Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage

Consultants

BKS (2006) Coega Industrial Development Zone Transport Study Volume 3

Demand Modelling Report Final Draft

Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I

Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6

Report compiled for SRK Consulting

Coastal amp Environmental Services (2010) Environmental Impact Assessment for the

Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone

Volume 3 Environmental Impact Assessment Report CES Grahamstown

Coega Development Corporation (2008) Industry Waste Management Plan -

Strategic Master Plan Report

Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants

Report No CDCSHE 03 8122

Department of Water Affairs and Forestry (1998) Waste Management Series

ldquoMinimum Requirements For The Handling Classification And Disposal Of

Hazardous Wasterdquo Second Edition

Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising

Plant in the Coega Industrial Development Zone

Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the

Coega Industrial Development Zone (IDZ) Specialist Water Study

Draft Environmental Impact Assessment Report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone

March 2012 11-2

Jacobs E (2008) Final Environmental Impact Report and Draft Environmental

Management Plan Proposed Steel Recycling and Processing Facility within the

Coega IDZ Report compiled for SRK Consulting

Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY

Galvanising Plant in the Coega Industrial Development Zone Waste Management

and Hazardous Substances Report compiled for ILISO Consulting

RSA National air quality standard for thoracic particulates (PM10) SA standards

(Government Gazette No 32816)

von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed

Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape

Report compiled for ILISO Consulting

von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel

Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report

compiled for ILISO Consulting

Additional sources

Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed

Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared

for Coastal Environmental Services

Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed

Kalagadi Manganese smelter in the Coega Industrial Development Zone Port

Elizabeth Eastern Cape Province Report prepared for Coastal Environmental

Services

Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia

steel recycling facility at the Coega Industrial Development Area Port Elizabeth

Prepared for SRK Consulting Port Elizabeth

APPENDIX A

LIST OF INTERESTED AND

AFFECTED PARTIES

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

DEDEARegional Manager

and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza

DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza

DEA Ocean and

CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza

DEA Ocean and

Coast

Oceanographer land-

based sources of

marine pollution

Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza

DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza

CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza

CDCEnvironmental

Project

Manager

Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza

TNPAPort of Ngqura

Environmental

Manager

Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet

NMBMEnvironmental

ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza

NMBMEnvironmental

ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza

DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza

DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza

WESSASenior Conservation

Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza

Zwartkops

ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700

hughlauegmailcom

zwartkopstrustiafricacom

SANParksNational Marine

CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza

Department Of

LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza

NMBM Air Quality

Division

Assistant

DirectorAir

Pollution and Noise

Templeton Titima 079 490 0574 Ttitimamandelametrogovza

NMBM Air Quality

DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza

NUMSARegional

RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza

Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail

Department of

HealthNadiema

van der

Bergh083 378 2103

nadiemavanderberghimpiloecprovgov

za

DWA Chief Services

Officer

Joseph Jacobs 041 586 4884 jjacobsdwafgovza

EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza

NUMSecretary of union

officesZandile Xhentsa 043 743 6597 zxhentsanumorgza

DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza

Dynamic

CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom

EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza

Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza

UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom

lprincezago2uticom

Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza

Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza

Absa Mr Johann Steyn 082 3775820 johannstabsacoza

Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza

PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza

Universal

EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza

Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza

GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom

Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza

NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom

DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza

DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza

TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet

DWA Mr Landile Jack JackLdwagovza

DWA Ms Lizna Fourie FourieL4dwagovza

APPENDIX B

NOTICE OF ATMOSPHERIC

EMISSIONS LICENCE APPLICATION

AND ADVERTISEMENT

APPENDIX C

NOTICE OF COMMENT PERIOD FOR

DRAFT SCOPING REPORT

APPENDIX D

SUMMARY OF ISSUES RAISED AND

RESPONSES THERETO

April 2012

1

PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL

DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))

IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt

AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt

This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses

provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process

conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the

Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

2

IssueCommentQuestion Date

received Origin Response

1 Please provide more information with respect to the potential

dangers including the toxicity of the proposed project

07032011

By email

Wayne Poulton

(Bosun Brick

tenant at the

IDZ)

An Environmental Impact Assessment (EIA) was undertaken

which assessed the potential toxicity of the emissions and

effluent Mitigation measures were also recommended in the draft

Environmental Management Programme (EMP) to avoid

minimise or compensate any significant impacts The Draft

Environmental Impact Report and draft EMP were made available

to stakeholders for comment in March 2012

2 Do you have a Background Information Document (BID) or

similar that provides more information on the project

27032011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The BID was sent to all registered IampAPs on 4 May 2011

3 The RoD issued to the CDC on 632007 for the change in

land use for the remaining area of the Coega IDZ includes a

number of requirements with respect to

atmospheric emissions that should be considered in the

Atmospheric Emissions Licence (AEL) application such as

prohibiting and monitoring where possible visible emission

plumes to the atmosphere In particular the

recommendations on pp87-91 of the final revised Scoping

Report dated Nov 2006 must be implemented (clause 421)

04042011

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

We have obtained copies of the documents referred to and ensure

that these requirements were taken into account in the

environmental assessment and AEL application

4 If the Port of Ngqura is used for import and export the scope

of the traffic impact assessment (TIA) should also include the

port

10052011

By email

Elliot

Motsoahole

(TNPA Port of

Ngqura)

The scope of the TIA was extended to include port related traffic

The TNPA at the Port of Ngqura was consulted and does not

have any objection to the project TNPA has indicated that the

development would require a minimum number of vessels per

year which would have minimal impact on the Port operations

However due notice would have to be given to the Port of Ngqura

before a vessel is scheduled to arrive so that the vessel can be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

3

IssueCommentQuestion Date

received Origin Response

accommodated at an available berth

5 Concerns with respect to potential stormwater pollution

draining into the Coega catchment and the port of Ngqura

The port needs to be dredged and heavy metals present a

risk in that regard

16052011

By

telephone

Andrew Lucas

(Department of

Water Affairs)

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination by effluent waste or

hazardousdangerous substances is very low

Thus no metals oils or other contaminants are expected to be

present in the stormwater

However stormwater pollution can occur in exceptional

circumstances such as accidents and emergencies The

emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

6 All steel sheets bathing unit must be under roof

7 The sludge out of the decreasing bath will be high in Na and

pH Therefore handling and disposal must be clarified up front

in this project

8 Per se the wastewater from decreasing bath will have high

ph and the component from the pickling unit will have low ph

Then it may be assumed that both streams will neutralize

each other Please then clarify proposed sewer discharge

with Nelson Mandela Bay Municipality up-front for acceptance

of influent as per the documented proposal

9 Pickling may result in dissolved metals How does your team

expect to deal with this As it is planned for discharge into

24052011

By email

Landile Jack

(Department of

Water Affairs)

All bathing units will be under roof

Effluent from the degreasing and pickling baths will be discharged

to the wastewater treatment plant The respectively alkaline and

acidic effluents will mix and neutralise each other in the

wastewater treatment plant Calcium or gypsum will be added if

required to complete the neutralisation process Effluent from the

treatment plant will be discharged to sewer Contact has been

made with the relevant officials and the Municipalityrsquos

requirements have been obtained The effluent discharged to

sewer will notably comply with the applicable discharge standards

Traces of metals (eg iron) may be present but will not exceed

prescribed thresholds The necessary authorisation will be

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

4

IssueCommentQuestion Date

received Origin Response

sewer Clarity and acceptance needs to be agreed with

Nelson Mandela Bay Municipality Who owns the sewer

10 Quenching unit will results to Zinc particles How will this

affect sewer discharge This again must be dealt with within

the negotiations with the Municipality

11 Once all has been agreed with the Municipality and at the

same time due negotiations must be done with hazardous

waste courier and disposal facility to accept the hazardous

waste identified in all production lines

12 Of note is the low volume of the proposed WWTW facility ie

250 cubmweek And the no discharge of the quenching

water ie over-flow and cooling only Hence Zinc particles

generation

obtained from the municipality

The sludge from the treatment plant will be collected by a licensed

service provider and disposed of at a permitted site

The quenching bath will be periodically emptied (every 6 months)

and the water discharged will go to the water treatment plant Zinc

particles will settle in the sludge which will be disposed of at a

permitted site

Contact has been made with EnviroServ who manages the

Aloes II HH waste site regarding collection and disposal of

hazardous waste (See waste management report)

13 Investigate the potential effects of toxicity andor influence of

emissions waste and hazardous substances both in

terrestrial and marine fauna

14 With regards to water usage where is the plant going to

extract its waters used in galvanization andor waste

management process ie rainfall rivers or even from the

sea) and which avenues would be more environmental

friendly and effective

31052011

By email

A Bewana

(SANPARKS)

Emissions waste and hazardous substances are not expected to

affect terrestrial or marine ecosystems The air quality study

concluded that atmospheric emissions would not be harmful to

human health and by extension terrestrial fauna There are no

standards for air quality for defining faunal impacts therefore by

ensuring that standards for humans are complied with the impact

on fauna is deemed to be acceptable In this case the impact of

emissions on terrestrial and marine fauna are thus not significant

Solid and liquid wastes both general and hazardous as well as

hazardous substances will be stored handled and disposed of

appropriately to as not to cause harm to terrestrial or marine

fauna

Due to the design of the plant and mitigation measures in place

(ie contained process bunded areas oil trap specified

procedures for the transport storage and handling of

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

5

IssueCommentQuestion Date

received Origin Response

hazardousdangerous substances) it is considered that

stormwater leaving the site will be clean under normal conditions

and the risk of stormwater contamination and hence land-based

marine pollution by effluent waste or hazardousdangerous

substances is very low

The risk of emissions waste and hazardous substances to

terrestrial and marine fauna is thus very low

However pollution of terrestrial and marine ecosystems can occur

in exceptional circumstances such as accidents and emergencies

The emergency preparedness and response plan and remediation

procedures will be developed and will deal with such

circumstances

The CDC has an agreement with the NMBM to supply potable

water to the Coega IDZ Currently the infrastructure to supply

return effluent (RE) to the IDZ is not in place therefore Casa Steel

will be supplied with potable water up until such time as the

following 2 options of RE are available

1) Upgrading of the existing Fishwater Flats waste water

treatment works (between IDZ amp PE) including RE plant

and infrastructure to pipe RE to the IDZ (EIA for the

upgrade is underway)

2) Construction of a new waste water treatment works

including RE plant in Zone 9 of the Coega IDZ

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option should be investigated further between Agni and Casa The

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

6

IssueCommentQuestion Date

received Origin Response

CDC can facilitate discussions between the 2 investors

Compliance with CDC Permits amp Requirements

15 It should be made clear that tenants will be required to

comply with CDC requirements and the relevant conditions of

permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water

Licence for its Storm Water Systems on the

East Side of the Coega River that tenants will

need to take cognizance of The contents of the

ldquoIntegrated Stormwater Masterplan for the

eastern side of the Coega IDZ Oct 2010rdquo

especially the Table of best practice p53

onwards may need to be taken cognizance of

o CDC is developing an Operations

Environmental Management Plan that will place

certain obligations on tenants

16 Environmental audits and data collected during monitoring

(eg stack emissions stormwater) will need to be shared with

CDC

Air Emissions

17 Presumably permanent in stack monitoring will be required in

terms of AEL permit requirements

18 Abnormal operating conditions resulting in air emissions ndash I

could find nothing in the EIR to indicate under what

circumstances these could occur (eg start-up) potential

frequency and duration and the impact on ambient air quality

ndash these events usually result in the most problems wrt air

emissions

09042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

15 Compliance with the CDCrsquos Permits amp Requirements has

been included explicitly as a requirement in the EIR (p8-1) and

EMP (pp18 and 25) in the following terms

ldquoAs a tenant operating in the IDZ Casa Steel will be required to

comply with all current and future CDC requirements as well as

with the relevant conditions of permits licences issued to CDC

(eg Integrated Stormwater Masterplan for the eastern side of the

Coega IDZ Operations Environmental Management Plan Water

Use Licence etc)rdquo

16 The need to communicate with the CDC on monitoring and

auditing activities was emphasised in Chapter 8 of the EMP The

following paragraphs were added

ldquoDuring construction the environmental officer will be responsible

for monitoring compliance with the EMP and authorisation

conditions and keeping records as required in the EMP andor

authorisation conditions

The ECO will conduct site inspections every two weeks audit the

records kept by the environmental officer and submit an

environmental compliance report every two months to the

authorities and the CDC (via the Environmental Monitoring

Committeersquos ECO)

During operation the health and safety officer will monitor

compliance with the EMP and the conditions of the Environmental

Authorisation Data collected during monitoring activities and any

environmental audits conducted will be shared with authorities

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

7

IssueCommentQuestion Date

received Origin Response

Water

19 Large volumes of (2000 m3mth) of water are required of

which only 400m3 needs to be potable The NMBM return

effluent system will provide non-potable water once it is

constructed What other water recycling initiatives can be

utilized to reduce potable water requirements (the ISWMP for

the eastern side of the Coega IDZ has some best practice

guidelines collecting rainwater from the roof etc)

General

20 There is no mention of how the CDC Architectural Guidelines

will be incorporated into the development (eg to prevent a

stark uniform warehouse type development)

21 Does NMBM have adequate fire services to cover this

development Apart from the large petroleum store are there

any other large fire hazards

22 Reports from the tenantrsquos ECO during construction and from

the SHE Officer during operations should be channeled to the

Coega Environmental Monitoring Committee This can be

directly or preferably via the EMCrsquos ECO (this will be while

the EMC and ECO are in place) A precedent has been set

for this in the Environmental Authorisations for Agni-Steel and

Kalagadi Manganese Smelter

23 All mitigation actions emanating from the EIR should be

summarized (preferably in a table) If compliance with them is

to be part of the Environmental Authorization from DEDEAT

then they (or the ones that DEDEAT deems to be applicable)

and the CDC (via the Environmental Monitoring Committeersquos

ECO)

The ECO (during construction) and the health and safety officer

(during operation) will report to the Coega Environmental

Monitoring Committee (EMC) via the EMCrsquos ECO (this will be

while the EMC and ECO are in place)rdquo

17 The draft EMP recommends regular monitoring of emissions

from the scrubbers and from the chromating process Additional

emissions monitoring requirements will be confirmed once the

AEL is issued Mention has been made in the EMP (pp11 and 19)

that all AEL conditions including monitoring and reporting

requirements should be adhered to

18 Abnormal emissions can occur in exceptional circumstances

Start-up will not cause abnormal emissions as the scrubbers

will be commissioned first and will be functioning once the plant

starts operating However abnormal emissions could be

caused if scrubbers are malfunctioning These emissions

would be emitted as a building fugitive

The hourly hydrogen chloride ground level concentrations

(directly offsite) were predicted to be 239 microgmsup3 (based on the

emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits

as stipulated for listed activities for galvanising processes) using a

screen model which assumes worst case meteorological

conditions The health effect screening level for hourly HCl

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

8

IssueCommentQuestion Date

received Origin Response

should be attached to the EA as an Appendix (otherwise no

one knows about them or takes cognizance of them)

concentrations is 2100 microgmsup3 Assuming abnormal emissions

emanating from the building are five times higher than routine

emissions the hourly predicted HCl concentrations due to upset

conditions will still be well within the health effect screening

levels

Similarly the hourly particulate emissions from the building

fugitives during upset conditions would amount to 293 microgmsup3

(based on the emission limits as stipulated for listed activities for

galvanising processes) well within the daily PM10 NAAQS (ie

120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1

January 2015) directly off-site

Therefore if emissions are 5 times higher normal they will still be

within health effect screening levels and the daily PM10 NAAQS

levels

In the case of a fire a cocktail of gases and particulates could be

emitted and could be over the recommended levels This

situation will however be dealt with as an emergency and

normalised as quickly as is possible

The above has been added to the impact identificationdescription

and assessment sections of the EIR

19 The CDC has an agreement with the NMBM to supply

potable water to the Coega IDZ Currently the infrastructure to

supply return effluent to the IDZ is not in place therefore Casa

Steel will be supplied with potable water up until such time as the

infrastructure is in place

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

9

IssueCommentQuestion Date

received Origin Response

Agni Steel an investor located in Zone 6 has commenced with

construction Once operational Agni Steel will be generating

effluent which may be considered for use by Casa Steel This

option will be investigated further between Agni and Casa The

CDC has come forward to facilitate discussions between the two

investors

Other water recycling initiatives such as rainwater harvesting

have been considered but are not practical

20 The CDCrsquos Architectural and Landscape Design guidelines

contain requirements pertaining to such aspects as the height

orientation and mass and form of buildings as well as guidelines

for landscaping and signage in order to ensure an attractive

development and achieve an architectural integrity within the

Coega IDZ The plans for the proposed galvanizing plant will be

submitted to the Design Review Committee for approval as

required by the CDC

21 Casa Steel will be required to install fire hydrants according

to the NMBMrsquos standardsrequirements The CDC will provide

potable water (up until such time as return effluent is available)

and a connection to the boundary of the site which will be

connected to the fire hydrants The installation of the fire hydrants

will require approval by the Metrorsquos Fire Chief as was done for

Agni-Steel one of the investors in Zone 6

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

10

IssueCommentQuestion Date

received Origin Response

The Coega IDZ falls within the NMBM and therefore the rates and

taxes paid by the CDC covers the fire services for which the Metro

is responsible Currently the Metro has sufficient capacity to

provide fire services to the tenants within the IDZ This was

confirmed in discussion with the CDCrsquos Infrastructure

Development Unit It is however unknown at which point the

Metrorsquos Disaster Management Plan would not be able to

accommodate servicing tenants in the IDZ

The LNG burner is the only major fire hazard on the plant

22 See response to item 16 above

23 Key mitigation and management measures emanating from

the EIR were recapitulated in Chapter 9 of the EIR to form part of

the conditions attached to the Environmental Authorization from

DEDEAT All mitigation measures recommended as a result of the

impact assessment are presented in a table in the draft EMP

which is appended to the EIR (Appendix J)

24 Hydrogen chloride is one of the main emissions There are no

ambient air quality guidelines for HCl and the EIR says

concentrations will be well within health parameters

However the main problem with HCl is its corrosive effect -

there is absolutely no mention of this in the draft EIR nor air

specialist report

There needs to be some sort of comment assessment as to

whether HCl emissions are likely to impact on for example

the adjacent Agni-Steel Plant wrt corrosion - their factory

structure will be made of steel

11042012

By email

Dr Paul Martin

(Environmental

Control Officer

Coega IDZ)

The atmospheric corrosion of metals is a complex process with

both the extent of deterioration and the mechanisms varying

considerably depending on the metal Depending on the way

pollutants are transported from the atmosphere to the corroding

surface two types of deposition processes are recognized in

atmospheric corrosion ndash dry deposition and wet deposition Wet

deposition refers to precipitation whereas dry deposition refers to

the remaining processes including gas phase deposition and

particle deposition The most important pollutants acting as

corrosive agents are sulphur and nitrogen compounds including

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

11

IssueCommentQuestion Date

received Origin Response

The EIR specialist rpt suggests monitoring HCl at ground

level on the property boundary and this is supported in case

there are complaints from neighbours

secondary pollutants and particulates Pollutants can contribute to

corrosivity individually however there may be a synergistic effect

when more than one of these pollutants is present in the

environment being affected In the field of atmospheric corrosion

sulphur dioxide is the single most investigated gaseous pollutant

and the quantification of the direct contribution of sulphur dioxide

to the corrosion process of metallic materials is comparatively well

understood (Tidblad amp Kucera 1998)

Very little work has reported on the effect of HCl on the

degradation of materials in the environment with no local dose-

response thresholds developed for corrosion occurring due to HCl

exposures This is probably because HCl which is present

outdoors in markedly reduced concentrations when compared

with SO2 has not been considered to contribute to significant

degradation of materials (Syed 2006) For this reason the

incremental corrosion due to HCl from the Coega Galvanising

Plant cannot be quantified

25 It is unacceptable for ILISO to be using CDC maps (see

figure 9 ndash pg5-6) without these maps being referenced

accordingly particularly when it appears that a CDC map has

been used and then overlaid with features by an unknown

author (ie CASA steel site Port (where the boundaries

depicted are incorrect) and a North legend which is out of

keeping with the overall cartographic intent of the original

work

26 Figure 10 is not referenced appropriately and I believe that I

commented previously in respect to references to roads not

12042012

By email

Graham Taylor

(Spatial

Development

Manager -

Infrastructure

Development

CDC)

This has been rectified in the final version of the report

Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24

Issues and Responses Report

April 2012

12

IssueCommentQuestion Date

received Origin Response

yet built As a result Figure 10 is confusing and clarity needs

to be provided in terms of referencing In addition the Port

shape is irregular and similar to the comment above

27 I acknowledge the emergency preparedness and response

plan but please confirm that this includes pro-active routine

monitoring of storm water leaving your premises to verify that

your assumptions of clean storm water are correct

13042012

By post

Andrew Lucas

(Director

WRampU

Department of

Water Affairs)

Pro-active routine monitoring of stormwater leaving the premises

will be undertaken This has been explicitly emphasised in

chapter 8 of the draft EMP

28 Will portablechemical toilets be used during construction

29 What provisions have been made for storm water drainage

during construction

18042012

By

telephone

Department of

Water Affairs

Port Elizabeth

Chemical toilets will be used during construction

The Casa Steel site will be located at the corner of two roads

drainage of stormwater from the site will take place through the

roadsrsquo drainage system

From Lea September [mailtoleailisocom]

Sent 11 March 2011 0935 AM

To Wayne Poulton

Cc Terry Baker

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Wayne

An Environmental Impact Assessment (EIA) will be undertaken for this project during the

next 10 to 12 months

We foresee that some of the key environmental impacts of the project will be in terms of air

quality water quality waste and hazardous substances

At this stage I am not able to give you any details regarding the potential toxicity of the

emissions andor effluent However specialist studies will be conducted as part of the EIA

that will determine the key impacts of the project Mitigation measures will also be identified

to avoid minimise or compensate any significant impacts

You are registered on the stakeholder database and you will be kept informed of progress in

the EIA process you will notably get the opportunity to access the reports produced and

provide any feedback on them

Please feel free to contact me should you need any further information

Best regards

Lea September

From Wayne Poulton [mailtowaynepbosuncoza]

Sent 07 March 2011 1257 PM

To Lea September

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

Please can you provide me with some more information as to the potential dangers including

the toxicity of this

Kind regards

Wayne

From Lea September [mailtoleailisocom]

Sent 04 March 2011 1123

To Lea September

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 March 2011 0745 AM

To Paul Martin

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 05 April 2011 0847 AM

To Paul Martin

Cc Terry Baker Renee von Gruenewaldt

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Thank you Paul for this information

I have downloaded a copy of the RoD and Scoping report you referred to and will make sure

these requirements are taken into account in the environmental assessment

Best regards

Lea September

From Paul Martin [mailtopmartinaxxesscoza]

Sent 04 April 2011 0955 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Further to my comments on 27311

Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in

the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega

IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised

scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions

including prohibiting and monitoring where possible visible emission plumes to the atmosphere

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Paul Martin

Sent Monday March 28 2011 745 AM

Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Paul

In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before

submitting any application forms to the authorities and starting with the EIA process

We have now submitted all applications (for AEL waste licence and environmental

authorisation) and have started with the scoping process

A BID is being drafted as well and I will send it through to you and other registered

stakeholders as soon as it is ready

I trust this answers your question

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Paul Martin [mailtopmartinaxxesscoza]

Sent 27 March 2011 0647 PM

To Lea September

Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Lea

Please Register me as an IampAP for this project

My comment

Do you have a BID document or similar that provides more information on the project

It is difficult to comment without knowing what is involved

Dr Paul Martin

Environmental Control Officer

Coega IDZ Port of Ngqura

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Lea September

To Lea September

Sent Friday March 04 2011 1122 AM

Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

You have been identified as a potential Interested andor Affected Party in relation to the

above-mentioned project

Please find attached correspondence in this regard

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 10 May 2011 0327 PM

To ElliotMotsoaholetransnetnet

Cc Terry Baker

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Mr Motsoahole

Thank you for your input on this issue

The Port of Ngqura will indeed be used for import and export At the moment the scope of

the traffic impact assessment only covers road traffic I have however relayed the matter to

our traffic specialist and we will consider this issue in the finalization of the Scoping Report I

will keep you informed of any developments in that regard

I trust this is acceptable to you

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]

Sent 10 May 2011 0855 AM

To Lea September

Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per

year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Lea

It has been noted that Casa Steel will source steel coils from various markets internationally and

in South Africa and the bulk of the plantrsquos production output will be exported to African countries

However there is no mention of logistic requirements

Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will

be used the scope of traffic impact assessment should also include the port

Regards

From Lea September [mailtoleailisocom]

Sent 04 May 2011 0747 AM

To Lea September

Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year

Galvanizing Plant in the Coega Industrial Development Zone (IDZ)

Dear Stakeholder

Please find attached a letter announcing the EIA process underway for the proposed 80 000

tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as

a Background Information Document (BID) outlining the details of the project

Please contact me should you require any further information on this project

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

Elliot Motsoahole

Manager - Environment

Transnet National Ports Authority

Port of Nqqura

Port Control Building Klub Road Port Elizabeth 6212

PO Box 612054 Bluewater Bay 6212

+27 41 507 8450

+27 86 674 7729

Cell +27 83 542 5619

E-mail Elliotmotsoaholetransnetnet

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

DISCLAIMER The information contained in this communication is subject to copyright and

intended only for the use of leailisocom Unauthorised use disclosure or copying is

strictly prohibited Should a virus infection occur as a result of this communication the sender

will not be liable If you have received this communication in error please notify

elliotmotsoaholetransnetnet

From Lea September [mailtoleailisocom]

Sent 25 May 2011 1147 AM

To Jack Landile (ELS)

Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi

Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Landile

Thank you for your input

Contact has been made with the relevant Municipal Directorate and we will follow up with

them to obtain clarifications on all these issues

I have added both Lizna and yourself on the database and will keep you updated on

progress on this project

Best regards

Lea September

From Jack Landile (ELS) [mailtoJackLdwagovza]

Sent 24 May 2011 0524 PM

To Fourie Lizna (ELS)

Cc Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Hi Lizna

I missed you on this sorry

I linked Pieter twice Instead

Regards

Landile

From Jack Landile (ELS)

Sent 24 May 2011 0445 PM

To leailisocom

Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi

Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Lea

The e-mail you sent to Mr Kooverji dated 19 May 2011 refer

Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are

All steel sheets bathing unit must be under roof

The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project

Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal

Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer

Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality

Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines

Of note is the low volume of the proposed WWTW facility ie 250 cubmweek

And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles

generation

Regards

Landile

From Lea September [mailtoleailisocom]

Sent 19 May 2011 0947 AM

To Lea September

Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report

Dear Stakeholder

Please find attached the remaining appendices to the draft Scoping report for the proposed

80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Lea September [mailtoleailisocom]

Sent 28 June 2011 0411 PM

To Aphiwe Bewana

Subject RE Proposed 80 000 TPY Galvanizing plant in Coega

Dear Mr Bewana

Thank you for your input and apologies for the late reply

We have taken note of your comments and are will be taking them forward in the EIA phase

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby

notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official

business of our firm shall be understood as neither given nor endorsed by it

Please consider the environment before printing this email

From Aphiwe Bewana [mailtoaphiwebewanagmailcom]

Sent 31 May 2011 1205 PM

To Lea September

Subject Re Proposed 80 000 TPY Galvanizing plant in Coega

Comment

Re Proposed 80 000 TPY Galvanizing plant in Coega

As SANParks we would like the EIA phase to investigate the potential effects of toxicity

andor influence of emissions waste and hazardous substances both in terrestrial and

marine fauna In the draft scoping report reference has been made with regards to the

terrestrial fauna but there is no attention to potential effects to marine fauna

Equally with regards to water usage where is the plant going to extract its waters used in

galvanization andor waste management process ie rainfall rivers or even from the sea)

and which avenues would be more environmental friendly and effective

Regards

Aphiwe Bewana

Marine Planner

South African National Parks

POBox 76693

NMMU

Port Elizabeth

6031

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 06 July 2011 1031 AM

To Lea September

Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Hi Lea

Irsquove reviewed the Final Scoping Report Herewith a few comments

1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the

Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a

revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the

NMBLP Please include only those in the IDZ as part of your IAP list

Regards

Andrea

From Lea September [mailtoleailisocom]

Sent Wednesday July 06 2011 859 AM

To Lea Septemberrsquo

Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment

Dear Stakeholder

The final scoping report for the above-mentioned project (attached) is available for comment

until 27 July 2011

The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic

commentaryrdquo tab

Best regards

Lea September

Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101

Email leailisocom

ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 09 April 2012 1159 AM

To Lea September

Subject Comments on Galvanising Plant EIR Coega IDZ

Lea

Attached are my comments on the Draft EIR for the Coega IDZ galvanising

plant

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

Email attachment

COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ

Dr Paul Martin PO Box 61029

Bluewater Bay 6212 Tel 041 4665698

Email pmartinaxxesscoza

Compliance with CDC Permits amp Requirements

It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg

o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of

o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants

Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC

Air Emissions

Presumably permanent in stack monitoring will be required in terms of AEL permit requirements

Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions

Water

Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)

General

There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)

Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards

Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter

All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)

-----Original Message-----

From Paul Martin [mailtopmartinaxxesscoza]

Sent 11 April 2012 1245 PM

To Lea September

Subject Fw Comments on Galvanising Plant EIR Coega IDZ

Lea

One other comment on that I have on the Galvanising Plant Draft EIR

Hydrogen chloride is one of the main emissions There are no ambient air

quality guidelines for HCl and the EIR says concentrations will be well

within health parameters

However the main problem with HCl is its corrosive effect - there is

absolutely no mention of this in the draft EIR nor air specialist report

There needs to be some sort of comment assessment as to whether HCl

emissions are likely to impact on for example the adjacent Agni-Steel

Plant wrt corrosion - their factory structure will be made of steel

The EIR specialist rpt suggests monitoring HCl at ground level on the

property boundary and this is supported in case there are complaints from

neighbours

Dr Paul Martin

PO Box 61029

Bluewater Bay 6212

Tel 041 4665698

Cell 0732524111

email pmartinaxxesscoza

----- Original Message -----

From Paul Martin ltpmartinaxxesscozagt

To Lea September ltleailisocomgt

Sent Monday April 09 2012 1158 AM

Subject Comments on Galvanising Plant EIR Coega IDZ

gt Lea

gt

gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising

gt plant

gt

gt

gt Dr Paul Martin

gt PO Box 61029

gt Bluewater Bay 6212

gt Tel 041 4665698

gt Cell 0732524111

gt email pmartinaxxesscoza

gt

From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]

Sent 12 April 2012 1139 AM

To Lea September

Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Hi Lea

Hope yoursquore keeping well

I have requested comments from my colleagues and the CDC Casa team on the Draft EIR

Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report

Regards

Andrea

From Graham Taylor

Sent Thursday April 12 2012 838 AM

To Andrea Von Holdt Firhana Sam

Cc Johan Fourie Maria van Zyl Melikhaya Sihawu

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Andrea Firhana

Firhana if you could please ensure that the co-ordinates provided in the EIR correspond

with our records (pages 4-1 amp 4-2)

My comments are as follows

It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work

Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above

Regards

Graham Taylor

Spatial Development Manager - Infrastructure Development

Mobile 0832283055

Office 0414030454

Facsimile 0865185033

Email GrahamTaylorcoegacoza

Website wwwcoegacom

right PLACE | right TIME | right CHOICE

This email and all contents are subject to the following disclaimer

httpwwwcoegacomemaildisclaimerhtml

From Lea September [mailtoleailisocom]

Sent 04 May 2012 0411 PM

To Andrea Von Holdt

Cc Terry Baker

Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment

Dear Andrea

We have taken note of the comments from the GIS Unit These issues have been rectified in

the final version of the EIR

Please can you forward to the relevant persons at the GIS Unit

Thank you

Best regards

Lea September

APPENDIX E

BACKGROUND INFORMATION

DOCUMENT

APPENDIX F

AIR QUALITY IMPACT ASSESSMENT

APPENDIX G

TRAFFIC IMPACT ASSESSMENT

APPENDIX H

WASTE MANAGEMENT AND HAZARDOUS

SUBSTANCES SPECIALIST STUDY

APPENDIX I

WATER QUALITY SPECIALIST STUDY

APPENDIX J

ENVIRONMENTAL MANAGEMENT

PROGRAMME

Page 14: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 15: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 16: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 17: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 18: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 19: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 20: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 21: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 22: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 23: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 24: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 25: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 26: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 27: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 28: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 29: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 30: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 31: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 32: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 33: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 34: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 35: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 36: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 37: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 38: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 39: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 40: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 41: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 42: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 43: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 44: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 45: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 46: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 47: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 48: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 49: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 50: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 51: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 52: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 53: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 54: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 55: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 56: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 57: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 58: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 59: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 60: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 61: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 62: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 63: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 64: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 65: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 66: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 67: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 68: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 69: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 70: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 71: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 72: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 73: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 74: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 75: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 76: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 77: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 78: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 79: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 80: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 81: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 82: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 83: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 84: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 85: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 86: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 87: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 88: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 89: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 90: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 91: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 92: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 93: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 94: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 95: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 96: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 97: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 98: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 99: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 100: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 101: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 102: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 103: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 104: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA
Page 105: PROPOSED 80 000 TPY GALVANIZING PLANT IN THE COEGA