proposed alternate e production of ferrochrome and

PROPOSED ALTERNATE

PRODUCTION OF FERROCHROME

AND FERROMANGANESE AT

ASSMANG CHROME –

MACHADADORP WORKS

DRAFT SCOPING REPORT

JUNE 2008

ENVIRONMENTAL

SCIENCE

ASSOCIATES

POSTAL

ADDRESS:

PO Box 2950

Saxonwold

2132

PHYSICAL

ADDRESS:

9 Victoria Street

Oaklands

Johannesburg

2192

TEL:

+27 (0)11 728 2683

CELL:

+27 (0)82 446 6414

FAX:

086 610 6703

WEBSITE:

www.escience.co.za

E-MAIL:

[email protected]


PROPOSED ALTERNATE PRODUCTION OF FERROCHROME AND

FERROMANGANESE AT ASSMANG CHROME – MACHADADORP

WORKS

COMPILED BY EAP:

Environmental Science Associates

PO Box 2950,

Saxonwold, 2132

9 Victoria Street,

Oaklands, Johannesburg, 2192

Tel: (011) 728 2683

Cell: 082 446 6414

Fax: 086 610 6703

E-mail: [email protected]

ON BEHALF OF APPLICANT:

ASSMANG CHROME – Machadadorp Works

PO Box 152

Machadadorp

Mpumalanga

1170

Tel: (013) 256 5071 / 5000

Cell: 082 373 4875

Fax: (013) 256 5139

E-mail: [email protected]

PREPARED FOR REVIEW BY COMPETENT AUTHORITY:

Directorate: Environmental Impact Management

Mpumalanga Department of Agriculture & Land Administration (MDALA)

3rd Floor, Piet Koornhof Building

C/o Betty & Justice Streets, Witbank

Private Bag X7255

Witbank

1035

Tel: (013) 690 1269/79

Fax: (013) 656 5469

JUNE 2008


PROPOSED ALTERNATE FERROCHROME & FERROMANGANESE PRODUCTION – ASSMANG MACHADADORP

Environmental Science Associates Page i

1. EXECUTIVE SUMMARY

ASSMANG CHROME – Machadadorp Works proposes to adapt existing operations at their

Machadadorp Ferrochrome works to allow for the alternate production of Ferrochrome

and Ferromanganese, due to fluctuating market conditions affecting ferrochrome

demand, and the generally opposite fluctuations in ferromanganese demand.

The proposed alternate production would to a large extent utilise existing infrastructure

without any modification, including transport infrastructure, raw material and product

storage bays, furnaces, and air pollution control equipment (bag filters). Raw material

demand, energy requirements, solid waste and emissions are expected to be the same or

less than during ferrochrome production. New infrastructure required would be a

dedicated site for disposal of manganese slag, and a briquetting plant for the processing

of bag filter dust, which would be recycled back into the furnaces.

The following activities are identified in Government Notice R.387, which requires a Scoping

and Environmental Impact Assessment to be conducted as part of Assmang’s application

for Environmental Authorisation for the proposed project:

o Activity 1(e): The construction of facilities or infrastructure, including associated

structures or infrastructure, for any process or activity which requires a permit or

license in terms of legislation governing the generation or release of emissions,

pollution, effluent or waste and which is not identified in Government Notice No. R.

386 of 2006; and

o Activity 1(g): The construction of facilities or infrastructure, including associated

structures or infrastructure, for the use, recycling, handling, treatment, storage or final

disposal of hazardous waste.

Environmental Impact Assessment aims to ensure effective compliance and governance

concerning the sustainable use of environmental resources, while simultaneously focusing

on key issues such as stakeholder empowerment, providing access to relevant and concise

information to enable informed decision making.

This Draft Scoping Report (DSR) was compiled through the execution of a methodology set

out to produce a report in compliance with the requirements of Section 29 of GN R.385 in

terms of Chapter 5 of the National Environmental Management Act (NEMA), 1998 (Act 107

of 1998, as amended).

The objective of this report is to identify and discuss issues of potential environmental

significance, and where possible, indicate the significance of those impacts, in order to

inform the scope of the Environmental Impact Assessment (EIA) phase to follow. The initial

identification and assessment of environmental impacts revealed the following potentially

significant environmental aspects which require further detailed assessment:

o Impact on Air Quality - Air quality assessment entailing a study of criteria pollutants

emitted by plant, specifically as it relates to current plant performance and any



Environmental Science Associates Page ii

effects on plant efficiency the proposed changeover to ferromanganese

production may have;

o Emission manganese dust - Ambient air quality baseline of manganese and emission

assessment to determine current exposures, and investigating emission and

abatement of manganese from the plant specifically, and review of Occupational

Health and Safety issues;

o Waste management - Waste classification and assessment investigating

requirements for waste handling, storage treatment and disposal with a specific

focus on hazardous wastes generated by the process and the processing thereof in

the proposed briquetting plant; and

o Potential impact on surface water – Assessment of generation, containment and

management of contaminated surface water, if any, e.g. from briquetting plant, ore

and product storage areas.



Environmental Science Associates Page iii

TABLE OF CONTENTS

1. EXECUTIVE SUMMARY........................................................................................................................ I

2. INTRODUCTION ..................................................................................................................................... 1

3. BACKGROUND – ASSMANG CHROME ............................................................................................ 4

4. LEGAL AND POLICY FRAMEWORK ................................................................................................ 8

4.1 CURRENT APPROVALS ......................................................................................................................... 8 4.2 ENVIRONMENTAL IMPACT ASSESSMENT............................................................................................. 8 4.3 AIR QUALITY ..................................................................................................................................... 10 4.4 WASTE ............................................................................................................................................... 10 4.5 OCCUPATIONAL HEALTH AND SAFETY .............................................................................................. 11

5. PROJECT DESCRIPTION.................................................................................................................... 12

5.1 DESCRIPTION OF PROPOSED ACTIVITY.............................................................................................. 12 5.2 ALTERNATIVES .................................................................................................................................. 14

6. PUBLIC PARTICIPATION PROCESS ............................................................................................... 15

6.1 STAKEHOLDER NOTIFICATION........................................................................................................... 15 6.2 KEY ISSUES RAISED ........................................................................................................................... 15

7. DESCRIPTION OF THE ENVIRONMENT AND POTENTIAL IMPACTS .................................. 16

7.1 LOCATION .......................................................................................................................................... 16 7.2 CLIMATE ............................................................................................................................................ 18 7.2.1 Temperature .............................................................................................................................. 18 7.2.2 Rainfall ...................................................................................................................................... 18 7.2.3 Wind........................................................................................................................................... 18

7.3 TOPOGRAPHY..................................................................................................................................... 18 7.4 GEOLOGY........................................................................................................................................... 19 7.5 SOIL ................................................................................................................................................... 19 7.6 VEGETATION...................................................................................................................................... 19 7.7 FAUNA ............................................................................................................................................... 19 7.8 SURFACE WATER ............................................................................................................................... 19 7.9 GROUNDWATER ................................................................................................................................. 19 7.10 AIR QUALITY ..................................................................................................................................... 20 7.11 NOISE ................................................................................................................................................. 21 7.12 VISUAL IMPACT ................................................................................................................................. 21 7.13 ARCHAEOLOGY, HERITAGE & CULTURE........................................................................................... 21 7.14 SOCIO-ECONOMIC ENVIRONMENT .................................................................................................... 21 7.15 MONITORING ..................................................................................................................................... 22 7.16 SUMMARY.......................................................................................................................................... 22

8. ENVIRONMENTAL ASPECT & IMPACT REGISTER................................................................... 23

8.1 CONSTRUCTION IMPACT ASSESSMENT AND MITIGATION ................................................................. 26 8.1.1 Noise.......................................................................................................................................... 26 8.1.2 Construction Waste ................................................................................................................... 26

8.2 OPERATIONAL IMPACT ASSESSMENT AND MITIGATION ................................................................... 26 8.2.1 Emissions to Air......................................................................................................................... 26 8.2.2 Generation and Disposal of Hazardous Waste ......................................................................... 26 8.2.3 Energy and Raw material Usage............................................................................................... 26 8.2.4 Groundwater Contamination..................................................................................................... 26 8.2.5 Effluent Generation and Management....................................................................................... 27

9. WAY FORWARD ................................................................................................................................... 28



Environmental Science Associates Page iv

LIST OF FIGURES Figure 3-1: The Assmang Machadadorp Works ................................................................................. 4

Figure 3-2: Pelletising Plant at Machadodorp Works ........................................................................ 5

Figure 3-3: Tapping of Ferrochrome ..................................................................................................... 6

Figure 4-1: EIA Process ............................................................................................................................. 9

Figure 7-1: Location of Assmang Chrome......................................................................................... 16

Figure 7-2: Regional Location (1:50000 – 2530CA Belfast & 2530CB Waterval Boven) ............ 17

LIST OF APPENDICES

Appendix 1: Application for Authorisation Form

Appendix 2: Previous Exemption Granted by MDALA (28/04/2006)

Appendix 3: Public Participation Documentation

Appendix 4: EAP Curriculum Vitae

Appendix 5: Plan of Study for EIA



Environmental Science Associates Page 1

2. INTRODUCTION

ASSMANG CHROME – Machadadorp Works (‘Assmang’ / ‘the applicant’) proposes to

adapt existing operations at their Machadadorp Ferrochrome Works to allow for the

alternate production of ferromanganese in existing, authorised furnaces currently used

for the production of ferrochrome. Assmang is the fourth largest producer of

ferrochrome in the country (after Xstrata, Samancor and Hernic).

Due to its relatively small size compared with the other producers, the feasibility of

ferrochrome production at Assmang is particularly affected by international

fluctuations in the price/demand of ferrochrome. Historically, situations have arisen

where Assmang was forced to shut down some of its furnaces and reduce production

due to low ferrochome prices, with resultant job losses.

Due to, among others, the fluctuating market conditions affecting ferrochrome

demand and that ferromanganese demand generally varies in an opposite manner,

Assmang has identified an opportunity to use one or more of their existing electric arc

furnaces for the production of ferromanganese when demand in ferrochrome is low,

and visa versa. This would avoid Assmang having to down-scale production during

periods of low ferrochrome demand, with associated job losses etc.

The process and technology has to a large extent been tested and proven at

Assmang’s Cato Ridge Smelter, which produced ferromanganese, and the

environmental impacts and associated required mitigating and monitoring measures of

the process are known. The alternate production as proposed is also common practice

internationally, e.g. Europe and China. The technical requirements for the production

of manganese are very similar to that for ferrochrome, and the proposed alternate

production would therefore to a large extent utilise existing procedures and

infrastructure without any modification, including:

o Transport

o Raw materials – reductants, fluxes, coal

o Raw material handling and storage areas

o Handling procedures

o Furnaces

o Air pollution control equipment (bag filters)

o Product handling and storage

o Energy requirements

o Labour

o Occupational Health and Safety (OHS)

o Management and monitoring procedures

Raw material demand, energy requirements, quantity of solid waste and emissions are

expected to be the same or somewhat less than during ferrochrome production. New

infrastructure required would be a dedicated cell for disposal of manganese slag, and

a briquetting plant for the processing of bag filter dust, which would be recycled back




into the furnaces. Some update of OHS and environmental management and

monitoring procedures may be required based on the outcome of the EIA.

It must be noted that Assmang previously applied for Exemption in terms of section 28A

of the Environment Conservation Act (‘the Act’), 1989 (Act 73 of 1989) for the

conversion of one of its furnaces for so-called ‘Swing Capacity’ to produce

ferromanganese in a furnace used for ferrochrome production. On 28 April 2006, the

Mpumalanga Department of Agriculture and Land Affairs (MDALA), granted

conditional Exemption (MDALA Ref. No: 17/2/22 NK41) in terms of Section 28A of the

Act and Government Notice R.29 of 7 April 1995, from Section 22(2) of the Act and

Government Notice R.1182 and R.1183 of 5 September 1997, for the conversion of a

ferrochrome furnace to a ferromanganese furnace at the Assmang Machadadorp

Works (see Appendix 2).

Key factors for this Decision included:

o The site is already developed with the ferrochrome plant;

o The proposed conversion will require no additional structures or equipment and

the process will be conducted using an existing furnace and the same bagfilter

support service and infrastructure; and

o The proposed conversion will not add to the current production of any waste or

by products and according to the mass balance, the production of

ferromanganese will reduce the waste volume since no additional water will be

required.

However, the project was never implemented and no ferromanganese has been

produced at the site. Assmang decided to re-apply for authorisation, which is the

subject of this Draft Scoping Report, mainly due to the following:

o The Exemption granted by MDALA only allows for ferromanganese production in

one furnace, whereas Assmang needs the option to use all their furnaces for

ferromanganese production instead of ferrochrome if so required;

o Wording of the Exemption did not correctly reflect Assmang’s intentions; and

o The Exemption did not include the proposed briquetting plant.

In terms of the current project proposal, Environmental Science Associates (ESA) was

appointed by Assmang as the independent Environmental Assessment Practitioner to

facilitate the application for Environmental Authorisation (on their behalf) for the

following activities identified in Government Notice R.387, which requires a Scoping

and Environmental Impact Assessment as part of the application in terms of

Government Notice R.385 (the so called NEMA EIA Regulations) promulgated in terms

of Section 24(5) of the National Environmental Management Act (NEMA), 1998 (Act 107

of 1998, as amended):

o Activity 1(e): “The construction of facilities or infrastructure, including associated






pollution, effluent or waste and which is not identified in Government Notice No.

R. 386 of 2006”; and

o Activity 1(g): “The construction of facilities or infrastructure, including associated

structures or infrastructure, for the use, recycling, handling, treatment, storage or

final disposal of hazardous waste”.

Note that in terms of activity 1(e) above, no new production infrastructure, or

modification thereof, related to the manufacture of ferromanganese (instead of

ferrochrome) would be required – existing raw material pre-processing and feed

equipment, electric arc furnaces and bag filters to control emissions would be utilised

as is. However, the production of ferromanganese would require an amendment of

existing Registration Certificates, which are currently being converted to Air Emission

Licences in terms of the National Environmental Management: Air Quality Act

(NEMAQA), 2004 (Act 39 of 2004), as these currently only allows for the production of

ferrochrome.

In addition, the proposed briquetting plant would be used to process bag filter dust

into a form that can be fed into the furnaces (i.e. re-use / recycling). This bag filter dust

is considered to be a waste (likely to be hazardous), and therefore this new plant would

require a so-called Waste Permit in terms of Section 20 of the Environment Conservation

Act, 1989 (Act 73 of 1989), as a waste handling facility, i.e. an area/installation where

waste would be stored, treated, or from which a valuable constituent would be

recovered. The plant is therefore also listed as activity 1(g) referred to above.

Note that the final waste products from the production of ferromanganese, i.e.

manganese slag, would be disposed of in a dedicated cell at Assmang’s existing,

approved hazardous slag disposal site. The expansion of this site is currently the subject

of a separate application for Environmental Authorisation and associated EIA (MDALA

Ref. No: 17/2/2/1(g)MP-3), and does not form part of this application for Environmental

Authorisation.




3. BACKGROUND – ASSMANG CHROME

Assmang Limited is a company incorporated in the Republic of South Africa to supply

raw material to the world's steel mills and alloy plants. Formed in 1935, and listed on the

Johannesburg Stock Exchange in 1936, the Group employs 2 865 permanent

employees. Assmang was delisted in February 2006. Assmang is jointly owned by

African Rainbow Minerals Limited (50%) and Assore Limited (50%), and currently has

three independently operating divisions based on its three commodities – chrome,

manganese and iron ore.

Assmang’s Chrome Division consists of the Dwarsrivier chrome mine and the

Machadodorp ferrochrome works both in Mpumalanga, and the Manganese Division

consists of the manganese mines in the Northern Cape, Nchwaning and Gloria, and

the ferromanganese works at Cato Ridge in KwaZulu-Natal. The Iron Ore Division is

made up of the Beeshoek mine and the Khumani iron ore project in the Northern Cape

around Postmasburg, and on the three farms adjacent to Kumba Resources' Sishen

mine.

Figure 3-1: The Assmang Machadadorp Works




In 1971 Feralloys Limited, a wholly-owned subsidiary of Assmang, expanded and

erected a ferro-chrome smelter at Machadodorp for the production and export of

charge and low-carbon ferrochrome. After a major reinvestment and expansion

programme, the works now has a ferrochrome capacity of approximately 300 000 tons

per annum, and has ISO 9000/2000, OSHAS 18 000 and ISO 14000/2004 certification.

Chrome containing ore is obtained from the modern Dwarsrivier Chrome Mine, located

140 km from Machadodorp, which supplies quality lumpy ore and concentrate to meet

most of the works' ore requirements. Some ore is also currently purchased from the

Nkomati Mine belonging to Lion Ore, which is close to Machadodorp. Other raw

materials are (i) reductants, which are sourced locally and include coke, char and

metallurgical coal, and (ii) flux (quartz and limestone) supplied under contract by local

quarries. A highly automated materials handling system distributes the raw materials to

four furnaces.

The metallurgical concentrate, together with recycled baghouse dust, are pelletised

using Outokumpu technology. The pellet production capacity is 350 000 tons pa. Pellets

substantially improve furnace production and efficiency. Using computer-based mass

balances and automated batching systems, the raw materials are blended into a

charge suitable for each of the furnaces. The blend varies depending on the

ferrochrome specification required.

Figure 3-2: Pelletising Plant at Machadodorp Works

The furnace operations consists of two open 33 MVA , one open 30 MVA (all of

Tagliaferri design) and one closed 54 MVA submerged arc furnace (Titaco) with pre-

heater (Outokumpu). The combined capacity is 290 000 tpa of charge chrome.

Despite the Eskom electricity shortage, Machadodorp continues to operate all 4

furnaces (at reduced load) to best meet the strong market conditions. Studies are

underway to examine the optimal strategy to expand production when the electricity

crisis alleviates. Slag-free ferrochrome ingots are produced by bottom ladle teeming.




Figure 3-3: Tapping of Ferrochrome

All slag and ladle skulls are cooled and sent to the Metal Recovery Plant to produce

saleable ferrochrome products. The production of ferrochrome results in a discard slag,

which contains entrapped ferrochrome metal. This ferrochrome can, however be

recovered in the metal recovery plant which has an installed capacity of 20 000 tons of

saleable product per annum. The slag and skulls which are recovered by excavator

and front-end loader, are crushed and screened into suitable size fractions, and Batig

and Delkor jigs are used to separate the metal from the slag in the coarser fractions,

while spirals are used to separate material of <1mm. Remaining waste slag is disposed

of at the existing slag disposal site after hexavalent chromium neutralization.

An automated three stage crushing and screening plant is closely controlled to ensure

that the ferrochrome complies with customer size requirements. The plant is operated in

campaigns to crush products with different silicon specifications. All products are

weighed and stockpiled according to size and silicon specification:

o Size: To customer specification

o Silicon (Si): 3 % to 6 %

o Chrome (Cr): Typically 51.5 % to 52.5 %

o Sulphur (S): 0.060 maximum (typically 0.04)

o Phosporous (P): 0.030 maximum (typically 0.023)

o Carbon (C): 6.3 % to 8 %

Assmang’s Machadodorp Works has had OSHAS 18 000 certification since 2003. The

site’s health care programme is monitored and managed by an independent

contractor. This consists of pre-employment, annual and termination medicals. An

accredited external company monitors exposure to hazards such as noise, dust and

chrome emissions. Results are used to improve protective equipment and operating

standards.




The Machadodorp Works has also been ISO 14 000 accredited since 2001, and

operates to a standard that is considered to be a benchmark in the industry. The works

is situated in a pristine environment with trout fishing downstream of the works. It has a

licensed slag dump and is a zero effluent site. Storm water is captured via concrete

channels to storm water dams. The storm water and process water are recycled to the

plant. Boreholes around the works and from the river streams are analysed on a regular

basis to ensure that the pristine environment is maintained.

The Environmental Management System monitors and manages risk in the areas of air,

ground and water pollution to minimise the impact the operations have on the

environment. All furnace waste gas systems are duplicated to ensure superior

operating availability. Taphole fume extraction improves conditions for employees. All

waste gas scrubber effluent is contained, treated and the water recycled. No slimes

dams are used. Extensive training programmes ensure workforce awareness of

environmental responsibilities.

As an ISO 9000 listed operation, all raw materials are closely monitored both on receipt

and during use to ensure that the product meets customer expectations. Mass

balances are used to ensure the furnace ingot product complies with specifications.

Each furnace tap is separately sampled and analysed with the ingots only allocated to

a stockpile once the analysis is known. The crushing plant operates in campaigns to

handle the different products separately. Each shift's production is sampled and

analysed prior to being placed on a final product stockpile. All products are carefully

checked both on dispatch and again at the harbour during loading. A modern

laboratory equipped with ICP, XRF, XRD and wet chemical facilities ensures accurate

chemical analysis.

From a human resource management and corporate social responsibility point of view,

the Machadodorp Works has developed a modern multi-skilled work structure and

extensive multi-media training systems are in place to develop ABET, knowledge and

skills throughout the workforce. Wherever possible, local communities supply the

resources required. Organised labour and other stakeholders are represented on

various forums to facilitate participative management. This ensures transparency,

common purpose and understanding. The company takes a keen interest in the social

development and upliftment of the community and this is reflected in the number of

projects undertaken in the areas of education, welfare and recreation.




4. LEGAL AND POLICY FRAMEWORK

4.1 CURRENT APPROVALS

Assmang’s Machadadorp Works is currently registered to conduct scheduled

processes (smelting) in terms of the Atmospheric Pollution Prevention Act 451/1965 –

Registration certificate Nos. 424/1, 424/2, 424/3 and 424/4, with additional certification

in terms of the National Water Act 36/1998, and the Integrated Water management

License, which is in its final draft form, and a permit in terms of No 250N. The disposal of

slag is covered and authorized in terms of the Environmental Conservation Act

73//1989, and a ROD Ref No. 17/2/20/NK13, and the authorization for the recycling of

storm-water in terms of the Environmental Conservation Legislation, and a ROD Ref No.

17/2/22/1 NK24 in terms of the Environmental Conservation Act.

4.2 ENVIRONMENTAL IMPACT ASSESSMENT

The proposed alternate production of ferromanganese would require new and

amendment of existing permits, as well as Environmental Authorisation for new

infrastructure (briquetting plant). The proposed activities are identified in Government

Notice R.387, as follows:

o Activity 1(e): “The construction of facilities or infrastructure, including associated



pollution, effluent or waste and which is not identified in Government Notice No.

R. 386 of 2006”; and

o Activity 1(g): “The construction of facilities or infrastructure, including associated

structures or infrastructure, for the use, recycling, handling, treatment, storage or

final disposal of hazardous waste”.

With the activities being listed in GN R.387, the process of applying for Environmental

Authorisation includes a requirement to conduct an initial Scoping phase, followed by

a detailed Environmental Impact Assessment as part of the application in terms of

Government Notice R.385 (the so called NEMA EIA Regulations) promulgated in terms

of Section 24(5) of the National Environmental Management Act (NEMA), 1998 (Act 107

of 1998, as amended).

The assessment required (see next page) is therefore comprehensive and detailed

where appropriate, and is a systematic process (see Appendix 2 for methodology) to

identify potential positive and negative impacts on the environment (biophysical,

socio-economic, cultural) associated with proposed activity, which aims to:

o Examine alternatives / management measures to minimise negative and

optimise positive consequences;

o Prevent substantial detrimental impact to the environment;

o Improve the environmental design of the proposal;

o Ensure that resources are used efficiently; and

o Identify appropriate management measures for mitigation and the monitoring

thereof.




Figure 4-1: EIA Process

Scoping & Plan Of Study

for EIA (POSEIA )

Environmental Impact Assessment

Application :

Submit to Competent Authority (MDALA)

Accept Reject

Amend

Public Participation Phase 1:

Submission :

Submit Scoping & POSEIA to MDALA

Amend


AuthoriseReject Refuse

Amend Submission :

Submit EIR to MDALA

Appeal

Scoping & Plan Of Study

for EIA (POSEIA )

Environmental Impact Assessment

Application :

Submit to Competent Authority (MDALA)

Accept Reject

Amend


Submission :

Submit Scoping & POSEIA to MDALA

Amend


AuthoriseReject Refuse

Amend Submission :

Submit EIR to MDALA

AppealAppeal




4.3 AIR QUALITY

Environmental legislation applicable to air quality includes the Atmospheric Pollution

Prevention Act of 1965 (APPA), the National Environmental Management Act of 1998

(NEMA) and the National Environmental Management Air Quality Act of 2004

(NEMAQA). The production of ferromanganese would require an amendment of

existing Registration Certificates, which are currently being converted to Air Emission

Licences in terms of the National Environmental Management: Air Quality Act

(NEMAQA), 2004 (Act 39 of 2004), as these currently only allow for the production of

ferrochrome.

Although sections of NEMAQA particularly relevant to the operations of Assmang have

not been enacted as yet, the duty to care imposed by Section 28 of NEMA is relevant

in the case of emissions of particulates and waste gases from the processes. Process

emissions to air where significant risk of particulate emissions is present will be passed

through existing bag filter units, thus limiting particulate emissions. Any changes to the

process emissions and efficiency of bag filters will be evaluated as part of the EIA

through the Air Quality Impact Assessment.

4.4 WASTE

In terms of the Environment Conservation Act of 1989 Section 20(1) & (6) “Waste”, is

defined as:

Any matter (whether gaseous, liquid or solid or any combination thereof) which is an

undesirable or superfluous by-product, emission, residue or remainder of any process

which originates from any residential, commercial or industrial area and which is:

a) discarded by any person; or

b) is, accumulated and stored by any person with the purpose of eventually

discarding it, with or without prior treatment connected with the discarding

thereof; or

c) is stored by any person with the purpose of recycling, re-using or extracting a

useable product from such matter and

d) building rubble used for filling or levelling purposes.”

Excluded from the definition is -

a) waste water disposed of in accordance with the National Water Act;

b) French drains and septic tanks;

c) minerals, tailings, waste-rock or slimes produced by or resulting from activities at

a mine or works as defined in section 1 of the Mines and Works Act, 1956; and

d) radio-active waste.

(Other laws regulate the excluded categories.)

Furthermore, a "disposal site" is defined as a site used for the accumulation of waste

with the purpose of disposing or treatment of such waste.

Waste generated from the process (slag and bag filter dust) will be accumulated on

site. Storage of this waste material, and processing in the briquetting plant, qualifies as

a waste disposal activity as referred to in Section 1 Environment Conservation Act of

1989. By strict interpretation of the law this means that the area where waste is being




stored, treated, or from which a valuable constituent is recovered, is regarded as a

waste handling facility which should be permitted (or possibly exempted from

permitting) in terms of Section 20(1) of the same Act.

According to Section 20(1) of the ECA, “no person shall establish, provide or operate

any disposal site without a permit issued by the Minister of Water Affairs...”, the process

of which is in turn informed by the DWAF Minimum Requirements Waste Management

Series (DWAF 1998a, DWAF 1998b, DWAF 1998c) documents (with the draft 3rd edition

having been released). Provision is made for the Minister to grant exemptions from the

permitting requirements. As such, Assmang will need to apply for:

o a waste disposal site permit in terms of Section 20(1) of the ECA; or

o an exemption from the provisions of Section 20(1) of the ECA.

4.5 OCCUPATIONAL HEALTH AND SAFETY

The Occupational Health and Safety Act (OHSA) regulations include Regulation 1179

(Hazardous Chemical Substances) and Regulation 7122 (Major Hazard Installations). A

“hazardous chemical substance” is defined in Government Notice R.1179 Hazardous

Chemical Substances Regulations (1995) as any toxic, harmful, corrosive, irritant or

asphyxiant substance, or a mixture of such substances for which (a) an occupational

exposure limit is prescribed, or (b) an occupational exposure limit is not prescribed; but

which creates a hazard to health.

The emissions of manganese containing particulates may be seen as potentially

creating a hazard to health. In terms of Section 8(2) of the Occupational Health and

Safety Act, 1993, the following applies to employers:

(d) establishing, as far as is reasonably practicable, what hazards to the health or

safety of persons are attached to any work which is performed, any article or

substance which is produced, processed, used, handled, stored or transported

and any plant or machinery which is used in his business, and he shall, as far as is

reasonably practicable, further establish what precautionary measures should

be taken with respect to such work, article, substance, plant or machinery in

order to protect the health and safety of persons, and he shall provide the

necessary means to apply such precautionary measures.

A Major Hazardous Installation is defined in terms of the Occupational Health and

Safety Act as an installation:

o where more than the prescribed quantity of any substance is or may be kept,

whether permanently or temporarily; or

o where any substance is produced, used, handled or stored in such a form and

quantity that it has the potential to cause a major incident.

A major incident as referred to in (b) is defined as “an occurrence of catastrophic

proportions, resulting from the use of plant or machinery, or from activities at a

workplace”.




5. PROJECT DESCRIPTION

5.1 DESCRIPTION OF PROPOSED ACTIVITY

The proposed change-over from ferrochrome (FeCr) to ferromanganese (FeMN)

production (and visa versa) would not require changes to furnace infrastructure, but

the following operational steps would be necessary to prevent any cross-

contamination of product:

o Give notice one month’s notice to relevant authorities and I&AP’s of proposed

changeover;

o Smelting the furnace/s down over 2-3 days, i.e. remove and clear the furnace/s

of existing FeCr materials (if changing to FeMn production) or remove FeMn

materials (if changing back to FeCr production);

o Empty affected gas-cleaning equipment, i.e. clear bag filters of any chrome or

manganese dust, as the case may be;

o Clean and check gas-cleaning equipment; and

o Introduce new materials, i.e. FeMn or FeCr, as the case may be.

Manganese Ore would be obtained from the existing Assmang Blackrock Mine in the

Northern Cape, and fluxes and reductants (similar as for FeCr production) from existing

suppliers. Approximately 2000 tons of ore per week would be brought on site via one

“Block load” rail wagons. Existing tipplers would be cleaned before and after the off-

loading process using contractors. Loading would, as is currently the case, occur

directly from the tippler to clam shells, with direct loading from the clam shells to the

holding bins.

FeMn production is expected to produce approximately 95 tons of slag per day,

approximately 52% less in volume than slag produced by the FeCr manufacturing

process. The slag will be disposed of on Assmang’s existing, licensed slag disposal site,

which has an approved engineered barrier lining and associated engineered and

licensed storm water control facility.

Bag filter dust and other manganese containing residues will be collected and

processed through a new briquetting plant. The plant will form the fine dust into a

conglomerate that can be re-introduced into the furnaces as raw material. Figure 5-1

shows the existing briquetting operations at Assmang’s Cato Ridge plant in KwaZulu

Natal where ferromanganese is produced.




Figure 5-1: Briquetting Plant (Assmang Cato Ridge)




To illustrate the similarities between FeCr (current) and FeMn (proposed) production,

the expected mass balance for each process is indicated below. Notable is the

decrease in use of energy and raw materials, as well as emissions and waste products,

during the production of FeMn compared with the quantities associated with FeCr

production. Therefore, the overall environmental impact of FeMn production is

expected to be less than for FeCr, mainly due to higher quality manganese ore and

enabling a more efficient manufacturing process with less residues.

FeCr PRODUCTION FeMn PRODUCTION INPUT/OUTPUT

TONS / DAY TONS / MONTH TONS / DAY TONS / MONTH

% DECREASE

during FeMn

production

IN

Power (MWh) 2899 86970 2049 61470 29.31

Ore 1929 57870 1729 51870 10.36

Reductants 559 16770 371 11130 33.66

Fluxes 290 8700 20.5 615 92.93

OUT

HCFeCr 890 26700 675 20250 24.16

Slag 985 29550 475 14250 51.78

Bag Filter Dust 42.9 1287 34 1020 20.93

Off Gas 935 28050 840 25200 10.16

The closure and decommissioning of the proposed conversion will be included in, and

carried out in accordance with the systems as detailed in the Commissioning EIA

undertaken for the existing plant infrastructure, and any expansions undertaken. It is

important to note that this will require that all concrete slabs and any contaminated

ground would need to be disposed of in accordance with the types of contamination

noted. In addition, all infrastructure will need to be demolished, and all materials sold,

or disposed of at a landfill site or waste facility that is licensed to take the waste stream

in question. Some of the soils may need to be deposited onto the existing H:H Site (Slag

Dump) before it is completely rehabilitated and capped. However, these materials will

need to be tested and assessed before a decision can be made in this regard.

5.2 ALTERNATIVES

The proposed conversion was initiated in response to the decrease in demand and

price for ferro-chrome. The alternative to the proposed conversion is that one of the

existing open furnaces would have to be taken out of production for at least the next

19 months, resulting in the direct loss of approximately 40 jobs and the indirect

reduction of contractor labour in the slag handling process. In addition this alternative

will have a significant negative impact on the profitability of the total operation.

After considering the FeMn conversion, the saving and creation of job opportunities

and the economic advantages of the process in relation to the fact that no additional

or significant environmental aspects are associated with this conversion, it was

concluded that the implementation of the proposed project would be viable and

environmentally sustainable.




6. PUBLIC PARTICIPATION PROCESS

6.1 STAKEHOLDER NOTIFICATION

The public and stakeholder participation process to date have entailed the following:

o Pre-identification of interested and affected parties (I&APs) using existing

databases from previous projects at Assmang Machadadorp.

o Advertising the proposed project and associated EIA process in “The

Lowevelder” and “Boven Herald” newspapers in the week of 25-29 February

2008. The advertisements indicated where written comments may be directed

to, and included an invitation to an initial briefing and information sharing

meeting.

o Placement of a Site Notice at the Assmang Chrome – Machadodorp Works.

o An initial stakeholder meeting open to all I&APs was held on Friday 14 March

2008 at 10:00 at the Assmang Chrome – Machadodorp Works Training Centre,

which coincided with a public participation meeting on the EIA process for the

proposed expansion of Assmang’s slag disposal site (MDALA Ref. No:

17/2/2/1(g)MP-3). During the meeting, the proposed project was explained by

means of a presentation. Further clarification was provided and issues related to

the project were raised during discussions that followed.

o This Draft Scoping Report will be made available for comment by I&APs for a

period of 30 days.

Refer to Appendix 3 for further detail on the public participation process to date.

6.2 KEY ISSUES RAISED

o Would the project require only Basic Assessment, or Scoping and EIA?

o Has it been proven elsewhere that the proposed conversion can be done?

o How will the proposed project impact on power consumption?

o Would the EIA be informed by any specialist studies?

o How will ‘internal’ dust (i.e. occupational health risk) be monitored and

managed?

o Can wet scrubbers be considered to replace bagfilters to reduce dust further?




7. DESCRIPTION OF THE ENVIRONMENT AND POTENTIAL

IMPACTS

7.1 LOCATION

The Assmang works, approximately 25 ha in size, is located on the Remaining Extent of

Portion 3, and Remaining Extent of Portion 4, of the Farm Schoongezicht 364 JT,

currently zoned for industrial use. The land capability has been altered to industrial land

use and will remain as industrial land for the life of the project. The site is situated

roughly 6 km southwest of Machadodorp, and 55 km northeast of Carolina, in the

province of Mpumalanga. The plant and slag dump is located approximately 650

metres west of the R36 between Machadadorp and Carolina. The centre co-ordinates

of the property is 25º 42' 51" S and 30º 13' 45" E.

The works fall within the jurisdiction of the Emakhazeni Local Municipality, which

incorporates the towns of Belfast, Dullstroom, Machadodorp and Waterval Boven. The

area falls under the Nkangala District Municipality. Surrounding land use is largely

agricultural. The works have been in operation for more than 35 years, and the

alternate production of FeMn would not affect surrounding land use.

Figure 7-1: Location of Assmang Chrome

NNNN




Figure 7-2: Regional Location (1:50000 – 2530CA Belfast & 2530CB Waterval Boven)

NNNN




7.2 CLIMATE

The Assmang Chrome Smelter is situated on the edge of the escarpment within the

Mpumalanga Province. The area typically receives summer rainfall in the form of

thundershowers between the months of November and March and experiences cold

winter nights and warm winter days. The climate can generally be defined as sub-

humid, and can be locally described as normally hot and dry.

7.2.1 TEMPERATURE

Temperature data obtained from the Machadodorp Weather Station show that

summers are generally warm with temperatures rarely exceed 30 ºC, and winters are

cold to very cold, with frost events that occur regularly. Mean annual maximum

temperature is 25.5 ºC and average minimum is 7.7 ºC.

7.2.2 RAINFALL

Rainfall records for the weather stations Machadodorp station 05 174306 is most

representative for the area. The rainfall and evaporation figures were taken into

account with the design of the existing Return Water Facility on-site, as well as the

undertaking of the Integrated Water Management Plan. The annual average

precipitation is 816.55 mm, and mean annual evaporation is 1658 mm:

Period Jan Feb March April May June July Aug Sept Oct Nov Dec

1985 –2000

133.64 122.01 86.39 38.91 17.61 8.03 2.01 7.37 33.36 100.13 108.48 158.61

15 year average = 816.55mm

7.2.3 WIND

The Machadodorp Weather Station is the nearest station to the Assmang site, and an

on-site station is used to improve to the accuracy of the data. In general, winds vary

from light (1.6 to 3.5 m/s) northwest and southeast for the majority of the year, with

strong to very strong (4.2 to 8.0m/s) northerly to north-easterly winds that occur at times

predominantly during the winter months. The proximity of the works to the escarpment

and the extremely flat terrain has some influence on the extremes of winds in the area.

7.3 TOPOGRAPHY

The proposed work areas for FeMn production is within the existing site, at an elevation

of approximately 1 200 mamsl. The site is founded on sound and competent

engineering materials that have been tested for their foundation properties (during the

initial construction phase of the plant). The shales and mudstone lithologies are

generally moderate to good founding materials.

Existing licensed infrastructure is in place to protect any surface water or groundwater

impacts, and the area is monitored on a regular basis in terms of the license

agreements with the relevant authorities. These results are submitted to the authorities

as required. The general slope of the site is approximately 2% to the southwest. The

topography of the whole area has been altered through industrial activities on the site.

The existing topography will not be further impacted upon by the proposed project.




7.4 GEOLOGY

The Machadodorp area is underlain by sediments of the Transvaal Group of rocks

comprising predominantly shales and mudstones with interlayers of siltstone and in

places sandstone lithologies. Dolerite and diabase dykes and sills have intruded these

sediments. The regional dip is to the north at approximately 5º. The proposed project

will have no additional impact on the geology of the area.

7.5 SOIL

Soils in the area are generally fine to medium grained mesotrophic to dystrophic sandy

loams to sandy clay loams, with moderate to low agricultural potential. The soils

underlying the site have all been disturbed. No additional surface areas will be

disturbed or soils removed as part of the proposed project.

7.6 VEGETATION

The site is located in a Moist Sandy Grassland area (Acocks, 1988) on the border

between the Bankenveld and North Eastern Sandy Grassveld types. The proposed

project will take place within the existing works where vegetation has been disturbed

historically. No additional natural vegetation will be impacted on by the proposed

project.

7.7 FAUNA

In general, animal life within the area is dependant on the soil, plant, and water

resources of the area. It is these basic biophysical resources that afford suitable habitat

and food to a range of fauna. The area proposed for the project is within the industrial

area of the existing plant infrastructure and no animals have been identified on site.

There will be no additional impact on the fauna of the area.

7.8 SURFACE WATER

The Assmang site is located within the Leeuspruit Elands River Catchment, which forms

part of the greater Komati River Water Management Area. The closest drainage line to

the site is located approximately 300m to the south of the site, and drains to the Elands

River. The site is contained within the existing water management area, and there will

be no impact on any surface water bodies due to the proposed project. Surface water

is monitored on a quarterly basis.

7.9 GROUNDWATER

As with the surface water, the proposed project will have no additional impact on the

groundwater environment, and no discharge of wastewater will occur. There is no

significant continuous aquifer within the study area.

The site has a full Integrated Water Management Plan in place, and this is well

managed. The water use has also been licensed through the DWAF for the utilization

of water within the works. The overall Machadodorp Works is monitored on an on-going

basis using 22 monitoring positions, and the proposed additional infrastructure lies within

this well managed area.




7.10 AIR QUALITY

The Assmang Chrome works does not fall within the recently proclaimed Highveld

Priority Air Quality Management Area. Notwithstanding, air quality is an issue of

concern in Mpumalanga, as it is in many other parts of South Africa. A wide variety of

air pollution sources exist in the province including industrial processes, agriculture,

mining activities, power generation, paper and pulp processing, vehicles and domestic

coal burning. A variety of pollutants including heavy metal containing particulates,

Oxides of Nitrogen, Sulphur Dioxide, and volatile organic compounds are emitted from

these activities (adapted from Mpumalanga SOER, 2003).

Due to the use of existing infrastructure and pollution abatement equipment (bag

filters), the alternate production of FeMn is not expected to increase current emissions

from FeCr production. This will be investigated in detail during the EIA phase. Assmang

is also in the process of compiling an Air Quality Management Plan as part of the

process of converting their existing APPA Registration Certificates to NEMAQA Air

Emission Licences. This plan would include developing a detailed emissions inventory

and setting up a comprehensive air quality monitoring system.

Stack monitoring to date have yielded the following results:

Date Parameters

evaluated Pellitising Off Gas

Stack

Pellitising

Baghouse

Stack

Furnace 2

Baghouse

outlet

Furnace 3

Baghouse

outlet

Furnace 5

Baghouse

outlet

Gas Volumetric Flow

rate; Actual (m3/s) 75.03 30.32 119.75 127.84

TPM Concentration

(mg/m3) 27.34 40.36 9.072 7.622

Mar

2005

TPM emission flow

rate; Actual (kg/hr) 7.385 4.405 3.911 3.508

Gas Volumetric Flow

rate; Actual (m3/s) 60.273 43.982 130.762 156.224

TPM Concentration

(mg/m3) 29.339 12.876 16.441 24.189

Mar

2006

TPM emission flow

rate; Actual (kg/hr) 6.366 2.039 7.739 13.604

Gas Volumetric Flow

rate; Actual (m3/s) 39.57 130.09 122.05 82.74

TPM Concentration

(mg/m3) 23.02 12.95 8.97 5.12

Oct

2006

TPM emission flow

rate; Actual (kg/hr) 3.279 6.065 3.941 1.525

Gas Volumetric Flow

rate; Actual (m3/s) 28.18 126.09 123.64 80.15

TPM Concentration

(mg/m3) 164.96 7.54 8.74 13.23

Apr

2007

TPM emission flow

rate; Actual (kg/hr) 16.735 3.423 3.890 3.817

AVERAGES 6.875 6.615 5.284 7.145 2.950




Monitored daily, monthly, and yearly ground level dust deposition concentrations are

well within the Department of Environmental Affairs and Tourism’s Guidelines for air

emissions:

10/12/03 to 06/02/04 Sample

No.

Description / Position Concentration

(mg/m2/day)

Description

1 Eastern Border (fence) 139.20 Slight

2 Eastern Border (security gate) 201.24 Slight

3 Northern Border of plant 219.19 Slight

4 Western Border (substation) 98.72 Slight

5 South West of Plant (slag dumps) 298.97 Moderate

6 South of Plant (slag dumps) 729.20 Heavy

7 South of Plant (main gate) 300.11 Moderate

8 South West in Plant (slag dumps) 211.29

Slight

9 North in plant (fence) 1120.17 Heavy

10 East in Plant (Pelletising plant) 872.44 Heavy

11 Glenchee Trout Farm 8.72 Slight

12 DR J van Niekerk 19.20 Slight

13 H van der Westhuizen 11.19 Slight

14 Bella Vista Country Club 12.12 Slight

15 Leon Stoltz 12.97 Slight

16 P Coetzee 19.72 Slight

17 Oostewald van Niekerk 18.71 Slight

18 Hostel / Local community 17.63 Slight

Slight = <250 mg/m2/day; Moderate = 250-500 mg/m2/day;

Heavy = 500-1200 mg/m2/day; Very Heavy = >1200 mg/m2/day

7.11 NOISE

The noise levels associated with the existing works is monitored on an on-going basis by

an independent body, and the results report to the MDALA on a quarterly basis. No

additional noise is expected as a result of the proposed alternate production of FeMn.

The existing noise levels at the site can be described as slightly higher than the

recommended allowable norm (85dBA), but are typical for an industrial area, i.e.

between 70 and 100 dBA.

7.12 VISUAL IMPACT

The proposed project will be within the present infrastructure of the works and no

additional visual impact is expected.

7.13 ARCHAEOLOGY, HERITAGE & CULTURE

The site falls within an established industrial site. As the site has a long term industrial

history, evidence of any cultural and archaeological nature which may be present is

neither visible nor accessible. Due to the established nature of the site and its location

in an industrial area it is not expected that any places of archaeological or cultural

importance would occur on the site itself.

7.14 SOCIO-ECONOMIC ENVIRONMENT

Almost 30% of households in Mpumalanga are considered to be living in poverty and

70% of the population are considered poor. Literacy and education is also a problem,

while the unemployment rate is currently 33%. There has also been a decrease in life




expectancy, probably due to HIV/AIDS, and is expected to decrease even further. In

general sanitation and potable water services are somewhat basic (Mpumalanga

SOER, 2003). Job creation is a direct positive impact on the socio-economic

environment. The proposed project will avoid Assmang to down-scale with resultant job

losses, and would lead to the creation of some employment opportunities during the

construction phase, upstream processes, downstream process and service provision

related to the industry.

7.15 MONITORING

A number of existing monitoring systems are in place, and would incorporate the

proposed project, which would be contained within the existing dirty water control

facility (as per the Integrated Water Management Plan), and is within the area at

present being monitored by the groundwater monitoring borehole system.

In addition to the water monitoring undertaken, the site is monitored for dust, noise, lux

(illumination) and air emissions. The preventions, monitoring and measuring programs in

place are part of the management systems implemented for the works. These include:

o Water Quality of all groundwater and surface water bodies including 22

boreholes, and the Leeuspruit and Elands River (Independent consultants);

o Biological Water Quality (Independent consultants);

o Air Quality – Air Pollution Liaison Committee of Mpumalanga;

o Waste Management – Separation program is in place;

o Noise Monitoring (Independent consultants).

In addition, the whole site is audited by the SABS on a biannual basis, and an

environmental complaints register is kept and actions recorded.

7.16 SUMMARY

The fact that the proposed project will occur within an existing industrial area, and

within the existing environmental management area, minimises environmental risks to a

large extent. Some initial environmental aspects have however been identified,

including:

o Handling & storage of manganese ore, product and slag – dust, surface water,

ground water, OHS;

o Air pollution control – emission level, capacity;

o Construction of briquetting plant – noise, dust, surface water, soil (temporary);

o Transition from chrome to manganese – clean-up of equipment, handling,

disposal; and

o Briquetting plant – dust, storage & handling, water.


PROPOSED ALTERNATE FERROCHROME & FERROMANGANESE PRODUCTION – ASSMANG M

ACHADADORP


Page 23

8.

ENVIRONMENTAL ASPECT & IMPACT REGISTER

Below is an initial assessment of environmental aspects and their associated impacts related to the proposed project. Differentiation is

made between significance of impact and priority for the m

anagement of an impact, which is determ

ined by impact significance, and

existence of applicable legislation.

PROJECT

ACTIVITY

ASPECT OF

PROJECT

ACTIVITY

IMPACT (S) OF

PROJECT

ASPECT

GEOGRAPHIC

EXTENT OF

IMPACT

DURATION OF

IMPACT

PROBABILITY

OF IMPACT

INTENSITY OF

IMPACT

SIGNIFICANCE

OF IMPACT (WITH AND WITHOUT

MITIGATION)

RELEVANT

LEGISLATION

PRIORITY OF

IMPACT

MANAGEMENT

MITIGATION/

OPTIMISATION

Low

Noise

Noise pollution

Site

Temporary

Definite

Low

Low

National Air

Quality

Management Act

of 2004.

Low

Noise during installation and

assembly of equipment, expected

to have no significant impact

outside of the site. People working

on-site will wear ear protection as

per Assmang Health and Safety

rules.

Low

Construction

waste

Contribution to

landfill

Locally

Perm

anent

Definite

Low

Low

Minimum

Requirements for

the Handling

Classification and

Disposal of

Hazardous Waste

Low

Construction waste produced

expected to be minimal.

Low

Construction

Installation waste

Contribution to

landfill

Locally

Perm

anent

Definite

low

Low

Minimum

Requirements for

the Handling

Classification and

Disposal of

Hazardous Waste

Low

Small amounts of steel and electric

cabling waste, and possible

packaging waste will be produced.



ACHADADORP


Page 24

PROJECT

ACTIVITY

ASPECT OF

PROJECT

ACTIVITY

IMPACT (S) OF

PROJECT

ASPECT

GEOGRAPHIC

EXTENT OF

IMPACT

DURATION OF

IMPACT

PROBABILITY

OF IMPACT

INTENSITY OF

IMPACT

SIGNIFICANCE


MITIGATION)

RELEVANT

LEGISLATION

PRIORITY OF

IMPACT

MANAGEMENT

MITIGATION/

OPTIMISATION

Low

Noise

Noise pollution

Site

Long Term

Definite

Low

Low

National Air Quality

Management Act of

2004.

Low

Noise generated as a result of

running m

achinery is expected to

have no significant impact outside

the site. People onsite will wear ear

protection as per Assmang’s Health

and Safety rules.

High

Gaseous and

particulate

emissions from

furnaces and

briquetting

Air pollution

Regional

Long term

Definite

Medium

Low

National

Environmental

Management Air

Quality Act: 2004

High

Air emissions will be treated via

bag-filter plants.

low

Other fugitive

emissions from

processing and

handling

Air pollution

Regional

Long term

Definite

Medium

Low

National

Environmental

Management Air

Quality Act: 2004

High

These emissions will be kept minimal

through m

anagement procedures.

Low

Groundwater

contamination

Water pollution

Local

Long term

Improbable

Low

Low

National Water Act of

1998;

Low

Provided that raw m

aterials and

waste are adequately stored,

handled and disposed of it is

unlikely that groundwater

contamination will result from the

proposed development

Medium

Effluent generation

Water pollution

Regional

Short term

Definite

Medium

Low

National Water Act of

1998

High

Water and solutions

generated/used in the process will

largely be recycled.

Medium

Job creation

Socio-economic

Locally

Long term

Definite

Medium

LO

W

Low

Operation

Use of raw m

aterials

and energy

Depletion of

natural resources

Regionally

Long term

Definite

Low

Low

Environmental

Conservation Act:

1989,

Low

Energy and raw m

aterial usage to

be monitored and managed to

ensure optimal usage



ACHADADORP


Page 25

PROJECT

ACTIVITY

ASPECT OF

PROJECT

ACTIVITY

IMPACT (S) OF

PROJECT

ASPECT

GEOGRAPHIC

EXTENT OF

IMPACT

DURATION OF

IMPACT

PROBABILITY

OF IMPACT

INTENSITY OF

IMPACT

SIGNIFICANCE


MITIGATION)

RELEVANT

LEGISLATION

PRIORITY OF

IMPACT

MANAGEMENT

MITIGATION/

OPTIMISATION

High

Operation

Handling and

disposal of

hazardous waste

Surface and

ground Water

pollution

Local

Long term

Definite

Low

Low

National Environmental

Management Act (Act

No. 107 of 1998).

Department of Water

Affairs and Forestry

Minimum Requirements

for the Handling,

Classification & Disposal

of Hazardous Waste.

High

Hazardous waste containing

manganese and other metals will be

generated by the process, Hazardous

waste to be classified and hazard

rated, handled and disposed of as

per the Minimum Requirements for

the Handling, Classification & Disposal

of Hazardous Waste.




8.1 CONSTRUCTION IMPACT ASSESSMENT AND MITIGATION

8.1.1 NOISE

The generation of noise during installation of the proposed facilities is rated as low with

or without mitigation. The closest built up area to the proposed sites is Emthonjeni 2 km

north, and given that heavy industrial activities are undertaken on the site, it is highly

unlikely that noise from the construction of the proposed development will pose a

nuisance.

8.1.2 CONSTRUCTION WASTE

It is expected that minimal waste will be generated during the installation of the

proposed structures and equipment. Consequently, generation of construction waste is

rated as low with and without mitigation.

8.2 OPERATIONAL IMPACT ASSESSMENT AND MITIGATION

8.2.1 EMISSIONS TO AIR

Emissions to atmosphere will include:

o Particulate emissions

o Manganese containing particulate emissions

o Oxides of nitrogen

o Fugitive emission from material and waste handling and processing

8.2.2 GENERATION AND DISPOSAL OF HAZARDOUS WASTE

The following major waste streams will need to be considered in terms of handling,

storage, treatment, re-use and disposal options:

• Bag filter dusts (generated as a result of emissions abatement - this is recycled

back to the plant but need to be stored and handled),

• Manganese slag from - this waste stream needs to be stored, handled and

disposed)

These are potentially hazardous wastes due to the presence of manganese, presence

of trace amounts of other heavy metals, as well as the possible salts.

8.2.3 ENERGY AND RAW MATERIAL USAGE

The chief source of energy will be electricity. Various raw materials including water will

be fed into the process. Note that FeMn production is expected to use less energy and

other raw materials.

8.2.4 GROUNDWATER CONTAMINATION

No significant interaction with groundwater is anticipated provided that raw materials,

products and waste are handled and stored appropriately.




8.2.5 EFFLUENT GENERATION AND MANAGEMENT

Process solutions will generally be reintroduced, to the process to improve extraction

and input material efficiencies. The briquetting system will require water replenishment

due to inherent losses.

Uncontaminated surface water approaching the site from upstream will be diverted

around the site to prevent contamination. Contaminated storm may water need to be

collected in storm water dams for testing before release. If the water is unacceptably

contaminated it may be to be treated before release or used as process water.




9. WAY FORWARD

Comments received on this Draft Scoping Report will be communicated to MDALA at

the end of the comment period. Inputs received will be evaluated to further inform the

EIA Phase of the application for Environmental Authorisation as relevant.

Based on the independent evaluation and assessment of the proposed project during

the Scoping Phase by the Environmental Assessment Practitioner (see Appendix 4 for

CV), a Plan of Study for Environmental Impact Assessment (POSEIA) has been

developed. The POSEIA (refer to Appendix 5) includes the scope of further specialist

studies to be conducted, which would inform the accurate assessment and mitigation

of potential environmental impacts that may arise from the proposed project. This

would result in the compilation of a detailed EIA Report that would allow the

competent authority (MDALA) to make an informed decision regarding the

authorisation of the proposed project.




APPENDIX 1: APPLICATION FOR

AUTHORISATION FORM




APPENDIX 2: PREVIOUS EXEMPTION

GRANTED BY MDALA (28/04/2006)




APPENDIX 3: PUBLIC PARTICIPATION

DOCUMENTATION




APPENDIX 4: EAP CURRICULUM VITAE




APPENDIX 5: PLAN OF STUDY FOR EIA

proposed alternate e production of ferrochrome and

Documents