Download - Clayville Thermal Plant
Clayville Thermal Plant Proposed development of the Clayville Thermal Plant
in the Clayville Industrial Area, Gauteng Province
Environmental Impact Assessment (EIA) Report
GDARD Ref No.: GAUT 002/18-19/E0063
September 2018
Environmental Impact Assessment Report September 2018
Clayville Thermal Plant
Gauteng Province
Prepared by:
Prepared for:
Bellmall Energy (Pty) Ltd
The Piazza, Level 1, The Cape Quarter
72 Waterkant Street
Cape Town
8001
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Project Details Page i
PROJECT DETAILS
GDARD Ref No. : GAUT 002/18-19/E0063
Title : Final Environmental Impact Asssessment Report for the Clayville Thermal
Plant in the Clayville Industrial Area, Gauteng Province.
Authors : Savannah Environmental (Pty) Ltd
Thalita Botha
Jo-Anne Thomas
Gabriele Stein
Client : Bellmall Energy Project 325 (Pty) Ltd
Report Status : Final Environmental Impact Assessment Report for the consideration by the
Gauteng Department of Agriculture and Rural Development
Date : September 2018
When used as a reference this report should be cited as: Savannah Environmental (2018) Final
Environmental Impact Assessment Report for the Clayville Thermal Plant in the Clayville Industrial Area,
Gauteng Province.
COPYRIGHT RESERVED
This technical report has been produced for Bellmall Energy Project 325 (Pty) Ltd. The intellectual property
contained in this report remains vested in Savannah Environmental (Pty) Ltd. No part of the report may be
reproduced in any manner without written permission from Savannah Environmental (Pty) Ltd or Bellmall
Energy Project 325 (Pty) Ltd.
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Purpose of the EIA Report Page ii
PURPOSE OF THE ENVIRONMENTAL IMPACT ASSESSMENT REPORT
Bellmall Energy Project 325 (Pty) Ltd is proposing the installation of a thermal plant utilising a Circulating
Fluidised Bed (CFB) boiler in the Clayville industrial area near Olifantsfontein. The thermal plant, also
referred to as the central plant, is proposed on Erf 457, Erf 459 and Portion 12 of Erf 508 which is situated
within the Ekurhuleni Metropolitan Municipality. The development footprint of the facility will be
appropriately placed within the project site of approximately 1.76ha in extent. The proposed project is to
be known as the Clayville Thermal Plant.
The purpose of the central plant would be to provide steam to off-takers in the industrial area. It is
proposed to utilise coal fines in combination with syngas and/or natural gas as feedstock for the CFB
boiler. The coal fines will be sourced from mines within the Delmas and Middelburg areas. Syngas will be
sourced from the Bellmall Energy Syngas Plant situated at remote locations. Natural gas will be sourced
from Sasol via an existing gas pipeline situated along Spanner Road (western boundary of the project site)
within the Clayville industrial area. The steam generation plant will have a capacity of up to 240 tons of
steam per hour which is an equivalent of up to 60 MWe. The installation of the Clayville Thermal Plant will
eliminate the need for off-takers to produce their own steam using small boilers located on the off-taker’s
site. The project will also be designed as a Zero Liquid Effluent Discharge (ZLED) facility, and will therefore
provide for the on-site treatment, reuse, and recycling of wastewater.
Bellmall Energy (Pty) Ltd has appointed Savannah Environmental as independent environmental
consultant to undertake the Environmental Impact Assessment (EIA) Process for the proposed Clayville
Thermal Plant. The EIA process is being undertaken in accordance with the requirements of the EIA
Regulations of December 2014 (GNR 326), as amended on 07 April 2017, promulgated in terms of the
National Environmental Management Act (NEMA; Act No. 107 of 1998).
The EIA Phase addresses those identified potential environmental impacts and benefits associated with all
phases of the project including design, construction and operation, and recommends appropriate
mitigation measures for potentially significant environmental impacts. The EIA Report aims to provide the
GDARD with sufficient information to make an informed decision regarding the project.
This final EIA Report consists of the following sections:
» Chapter 1 provides background to the project and the EIA, a summary of the recommendations and
conclusions from the Scoping Report, and the details of the Environmental Assessment Practitioner
(EAP) conducting the EIA.
» Chapter 2 outlines the strategic legal context for the project at a national, regional and local level.
» Chapter 3 provides a description of the project, including feasible alternatives considered, and the
need and desirability of the project.
» Chapter 4 outlines the approach to undertaking the EIA process.
» Chapter 5 describes the existing biophysical and socio-economic environment within and surrounding
the project development footprint.
» Chapter 6 provides an assessment of the potential issues and impacts associated with the Clayville
Thermal Plant and presents recommendations for mitigation of significant impacts.
» Chapter 7 provides an assessment of cumulative impacts associated with the Clayville Thermal Plant
together with other similar developments in the area.
» Chapter 8 presents the conclusions and recommendations based on the findings of the EIA.
» Chapter 9 provides a list of reference material used to compile the EIA Report.
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Purpose of the EIA Report Page iii
GDARD REQUIMENT FOR THE ENVIRONMENTAL IMPACT ASSESSMENT REPORT
Savannah Environmental has compiled a table (refer to Table 1 below) which outlines the GDARD
requirements as outlined in the acceptance of the scoping report dated 04 December 2017 and the
comments received from the GDARD on the EIA Report dated 18 July 2018, and where the requirements
have been addressed within this report for ease of reference. The comments received from the GDARD
on the EIA Report as well as the acceptance of the scoping report is included in Appendix B.
Table 1: Information requested by GDARD
No. Information Requirement CROSS REFERENCE IN THIS EIA REPORT
GDARD comments received on the EIA Report
A Alignment of the activity with applicable legislations and
policies
The development has a direct bearing on the National
Environmental Management Act (NEMA) (Act No. 107 of 1998)
(as amended) at both national and provincial levels. The
proposed development corresponds with the activity applied
for under the Environmental Impact Assessment (EIA)
Regulations, 2014, (GN R.983) Listing Notice 1, Activity 25 and
Listing Notice 2 Activity 6 published under the National
Environmental Management Act (NEMA) (Act No. 107 of 1998)
(as amended).
Gauteng Environmental Management Framework, 2015 (GEMF,
2015) identifies the proposed site as Environmental
Management Zone 5, which is the industrial and commercial
development focus zone
It is noted that the listed activities
applied for in section 4.2 correspond
with the project that is proposed and
that the project site is located within
Environmental Management Zone 5.
B Guidelines: GDARD requirements
The Departmental Conservation Plan depicts that there are no
sensitive biodiversity features occur on the proposed site.
However, the applicant compile all specialist study related to
the proposed activity and site for the proposed installation of a
thermal plant, all specialist's studies attached on the report are
noted and considered related to the proposed activity.
Comment noted.
C Alternatives
Project alternatives provided in the Draft Scoping and EIA
Report are supported. The site is not within critical biodiversity
sensitivities therefore the layout plan is supported. The site is
identified as Environmental Management Zone 5 which is the
industrial and commercial development focus zone, therefore
the site is suitable for the proposed activity.
It is recommended that the alternatives must be assessed and
form part of the preferred alternative which consider the use of
sustainable development means which involve the use of solar
geyser, solar energy, rainfall harvesting etc. must form part of
the final Scoping and EIA to be submitted.
The applicant is proposing to utilise
sustainable development means such as
harvesting rainfall, solar water heating
etc. Refer to Chapter 3.
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Purpose of the EIA Report Page iv
No. Information Requirement CROSS REFERENCE IN THIS EIA REPORT
D Significant rating of impacts
Identification of impacts and the proposed impact assessment
methodology provided in the Draft Scoping and EIA Report is
supported as this will lead to reliable conclusion that the
mitigation measures identified will reduce impacts to an
acceptable level.
It is noted that the impact assessment
methodology used (refer to section 4.4)
is supported by the Department and
that the Department
E Locality map and layout plans or facility illustrations
The locality map must be in colour and overlaid by the
sensitivity map. The Department propose the following
recommendations to be included in the Final Scoping and EIA
Report:
» The layout plan (A3 size) and indicate the site's access
point(s);
» The zoning certificate of the proposed site;
» Comments from Council for Geoscience must be
obtained and submitted as part of the final Scoping and
EIA.
» Comments of the storm water and traffic impact studies
from Ekurhuleni's Department of Road and Storm water.
» A confirmation from the local authority with regards to
provision of bulk services (e.g. water supply, sewerage and
waste disposal, energy, storm water) and related services
such as road infrastructures is required. This must include a
description of the infrastructure, specifications, layout,
capacity and the planned routes must be included in the
final Scoping and EIA.
» Refer to Appendix J for the A3
layout map.
» Refer to Appendix G2 for the
zoning certificate.
» Comments from the Council of
Geoscience were requested on 31 July
2018. Once comments have been
received, these will be submitted to the
Department for consideration.
» Comments from the City of
Ekurhuleni’s Roads and Stormwater
Department were received on 27 July
2018 (refer to Appendix C6.
» In order to obtain confirmation
from the City of Ekurhuleni with regards
to bulk services (e.g. water supply,
sewerage and waste disposal, energy,
stormwater) and related services such as
road infrastructures, a detailed study is
required to be undertaken. It has been
recommended that this study and
confirmation from the City of Ekurhuleni
be obtained prior to the
commencement of the construction
phase.
F Environmental Management Programme (EMPr)
The attached EMPr is noted and appears adequate to address
impacts that may arise because of the proposed development.
Noted.
G Public participation process
The Public Participation Process was conducted to the minimum
requirements of EIA Regulations 2014 and therefore it must be
done and included in the Final Scoping and EIA Report. Under
Appendix C2 Site Notices and Newspaper Advertisements, it is
noted that the Newspaper Advertisements is not attached on
the report as mentioned, therefore the Newspaper
Advertisement must be attached on the final Scoping and EIA.
Evidence the public participation
process undertaken is contained in
Appendix C of the EIAr. The newspaper
tear sheets are contained in Appendix
C2 of the EIAr.
Acceptance of Scoping
1. Please note that the activity for sorting, shredding, crushing,
grinding or bailing of general waste applied for which was listed
in terms of the Government Notice 921, National Environmental
Management: Waste Act (NEM: WA), 2008 (Act No. 59 of 2008),
under Category A, Activity (2),
"The sorting, shredding, grinding, crushing, screening or bailing
Noted, the project no longer triggers an
activity within the National
Environmental Management: Waste Act
(NEM: WA), 2008 (Act No. 59 of 2008.
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Purpose of the EIA Report Page v
No. Information Requirement CROSS REFERENCE IN THIS EIA REPORT
of general waste at a facility that has an operational area in
excess of 1000m2" has been repealed.
2. The Minister published a Government Notice, (GN) 1093 for the
National Norms and Standards for the sorting, shredding,
grinding, crushing, screening or Bailing of General Waste, 2017
on 11 October 2017. The notice repealed the above-mentioned
waste management activity from Category A and listed it under
Category C, Activity 6, as
"The sorting, shredding, grinding, crushing, screening or bailing
of general waste at a waste facility that has an operational
area that is 1000m2 and more".
The " sorting, shredding, shredding, grinding, crushing ..." activity
no longer requires a waste management licence but requires
the person to register with the Department in accordance with
the Norms and Standards for the sorting, shredding, grinding,
crushing, screening or bailing of general waste, 2017.
The registration must be done within ninety (90) days from the
date of publication of the Norms and Standards in the
Government Gazette (i.e. from 11 October 2017) and prior to
any construction taking place on site.
Noted, the project no longer triggers an
activity within the National
Environmental Management: Waste Act
(NEM: WA), 2008 (Act No. 59 of 2008.
3. In terms of the transitional arrangements of the National Norms
and Standards for the sorting, shredding, grinding, crushing,
screening or bailing of General Waste, 2017 "A person who
submitted an application for a waste management licence for
the repealed waste management activity contemplated in
paragraph 2 of this notice and a decision is still pending on the
date of commencement of this Notice, must consider such an
application withdrawn and such a person must comply with the
National Norms and Standards for the Sorting, Shredding,
Grinding, Crushing, Screening or Bailing of General Waste,
2017."
Noted, the project no longer triggers an
activity within the National
Environmental Management: Waste Act
(NEM: WA), 2008 (Act No. 59 of 2008.
4. It was indicated on the application form that the waste will be
dried and used as feedstock for the boiler. This triggers activity
listed in terms of the Government Notice 921, National
Environmental Management: Waste Act (NEM: WA), 2008 (Act
No. 59 of 2008), under Category A, Activity (6),
"The treatment of general waste using any form of treatment at
a facility that has the capacity to process in excess of 10 tons
but less than 100 tons."
The project no longer triggers an activity
within the National Environmental
Management: Waste Act (NEM: WA),
2008 (Act No. 59 of 2008 as no waste will
be treated.
5. The Department requires Bellmall Energy (Pty) Ltd to amend
the application to remove Activity 2 and include Activity 6.
The project no longer triggers Activity 6
or any other activity within the NEM:WA.
6. The actual "several waste streams" and "other production
facilities" mentioned in page 25 as well as the anticipated
quantities thereof must be stipulated - as the type of air
emissions, quantities and impacts will depend on actual
waste used.
The project no longer triggers an other
activity within the NEM:WA.
7. The municipal waste mentioned under 3.3 in page 25 must
be clearly stipulated as the different types of municipal
The project no longer triggers an other
activity within the NEM:WA.
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Purpose of the EIA Report Page vi
No. Information Requirement CROSS REFERENCE IN THIS EIA REPORT
waste may emit different emissions.
8. The Environmental Management Programme cannot be well
determined without specifically stipulating all the wastes and
their individual impacts. The Environmental Management
Programme must consider and include the impacts associated
with the treatment of each type waste
The project no longer triggers an other
activity within the NEM:WA.
9. The geotechnical assessment must be undertaken by the
suitable qualified specialist.
A Geotechnical Assessment will be
undertaken before the commencement
of construction and the need for such
an assessment has been included in the
EMPr (refer to Appendix H.
10. The layout plan must be A3 size and using different colours on
the layout plan.
The layout plan has been included in
Appendix J.
11. The layout must be scale, clear legible and indicate legend
which corresponds with activity components.
The layout plan included in Appendix J is
legible and includes a legend.
12. Comments from City of Ekurhuleni Department of Environmental
Resource management must form part of the report.
Comments will be requested from the
City of Ekurhuleni Department of
Environmental Resource management
on the EIA Report for public review.
13. It is indicated that an Atmospheric Emissions Licence (AEL) will
be completed only after a decision has been issued by GDARD.
However, an Air Quality Impact Report that considers the
different waste types applied for use in the proposal as well as
their impacts must be submitted for consideration for the review
of the waste licence. The report must consider the specific
waste types applied for and indicate expected emissions from
the development.
The project no longer triggers an other
activity within the NEM:WA.
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Legal Requirements in terms of the EIA Regulations Page vii
LEGAL REQUIREMENTS IN TERMS OF THE EIA REGULATIONS
An overview of the contents of the Scoping Report, as prescribed by Appendix 3 of the 2014 EIA
Regulations (GNR 326); and where the corresponding information can be found within the report is
provided in Table 2.
Table 2: Legal requirements in terms of the EIA regulations
Requirement Location in Report
(a) Details of –
(i) The EAP who prepared the report.
(ii) The expertise of the EAP, including a curriculum vitae.
Chapter 1
Appendix A
(b) The location of the development footprint of the activity on the approved site as
contemplated in the accepted Scoping Report, including –
(i) The 21 digit Surveyor General code of each cadastral land parcel.
(ii) Where available, the physical address and farm name.
(iii) Where the required information in items (i) and (ii) is not available, the
coordinates of the boundary of the property or properties.
Chapter 1
Table 1.1
(c) A plan which locates the proposed activity or activities applied for as well as the
associated structures and infrastructure at an appropriate scale, or, if it is –
(i) A linear activity, a description and coordinates of the corridor in which the
proposed activity or activities is to be undertaken.
(ii) On land where the property has not been defined, the coordinates within which
the activity is to be undertaken.
Chapter 1
(d) A description of the scope of the proposed activity, including –
(i) All listed and specified activities triggered and being applied for.
(ii) A description of the associated structures and infrastructure related to the
development.
Chapter 3
Chapter 4
(e) A description of the policy and legislative context within which the development is
located and an explanation of how the proposed development complies with and
responds to the legislation and policy context.
Chapter 2
(f) A motivation for the need and desirability for the proposed development, including the
need and desirability of the activity in the context of the preferred development footprint
within the approved site as contemplated in the accepted Scoping Report.
Chapter 3
(g) A motivation for the preferred development footprint within the approved site as
contemplated in the accepted Scoping Report. Chapter 3
(h) A full description of the process followed to reach the proposed development footprint
within the approved site as contemplated in the accepted Scoping Report, including –
(i) Details of the development footprint alternatives considered.
(ii) Details of the public participation process undertaken in terms of Regulation 41 of
the Regulations, including copies of the supporting documents and inputs.
(iii) A summary of the issues raised by interested and affected parties, and an
indication of the manner in which the issues were incorporated, or the reasons for
not including them.
(iv) The environmental attributes associated with the development footprint
alternatives focusing on the geographical, physical, biological, social, economic,
heritage and cultural aspects.
(v) The impacts and risks identified including the nature, significance, consequence,
extent, duration and probability of the impacts, including the degree to which
these impacts –
Chapter 3
Chapter 4
Chapter 5
Chapter 6
Chapter 8
Appendix C
Appendix D – F
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Legal Requirements in terms of the EIA Regulations Page viii
Requirement Location in Report
(aa) Can be reversed.
(bb) May cause irreplaceable loss of resources
(cc) Can be avoided, managed or mitigated.
(vi) The methodology used in determining and ranking the nature, significance,
consequences, extent, duration and probability of potential environmental
impacts and risks.
(vii) Positive and negative impacts that the proposed activity and alternatives will
have on the environment and on the community that may be affected focusing
on the geographical, physical, biological, social, economic, heritage and
cultural aspects.
(viii) The possible mitigation measures that could be applied and level of residual risk.
(ix) If no alternative development footprints for the activity were investigated, the
motivation for not considering such.
(x) A concluding statement indicating the location of the preferred alternative
development footprint within the approved site as contemplated in the
accepted Scoping Report.
(i) A full description of the process undertaken to identify, assess and rank the impacts the
activity and associated structures and infrastructure will impose on the preferred
development footprint on the approved site as contemplated in the accepted Scoping
Report through the life of the activity, including –
(i) A description of all environmental issues and risks that were identified during the
environmental impact assessment process.
(ii) An assessment of the significance of each issue and risk and an indication of the
extent to which the issue and risk could be avoided or addressed by the
adoption of mitigation measures.
Chapter 6
(j) An assessment of each identified potentially significant impact and risk, including –
(i) Cumulative impacts.
(ii) The nature, significance and consequences of the impact and risk.
(iii) The extent and duration of the impact and risk.
(iv) The probability of the impact and risk occurring.
(v) The degree to which the impact and risk can be reversed.
(vi) The degree to which the impact and risk may cause irreplaceable loss of
resources.
(vii) The degree to which the impact and risk can be mitigated.
Chapter 6
Chapter 7
(k) Where applicable, a summary of the findings and recommendations of any specialist
report complying with Appendix 6 to these Regulations and an indication as to how these
findings and recommendations have been included in the final assessment report.
Chapter 6
Chapter 7
Chapter 8
Appendix D – F
Appendix H
(l) An environmental impact statement which contains –
(i) A summary of the key findings of the environmental impact assessment.
(ii) A map at an appropriate scale which superimposes the proposed activity and its
associated structures and infrastructure on the environmental sensitivities of the
preferred development footprint on the approved site as contemplated in the
accepted Scoping Report indicating any areas that should be avoided,
including buffers.
(iii) A summary of the positive and negative impacts and risks of the proposed
activity and identified alternatives.
Chapter 8
(m) Based on the assessment, and where applicable, recommendations from specialist
reports, the recording of proposed impact management outcomes for the development
Chapter 6
Appendix D – F
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Legal Requirements in terms of the EIA Regulations Page ix
Requirement Location in Report
for inclusion in the EMPr as well as for inclusion as conditions of authorisation.
(n) The final proposed alternatives which respond to the impact management measures,
avoidance, and mitigation measures identified through the assessment.
Chapter 8
(o) Any aspects which were conditional to the findings of the assessment either by the EAP or
specialist which are to be included as conditions of authorisation. Chapter 8
(p) A description of any assumptions, uncertainties and gaps in knowledge which relate to
the assessment and mitigation measures proposed.
Chapter 4
Appendix D – F
(q) A reasoned opinion as to whether the proposed activity should or should not be
authorised, and if the opinion is that it should be authorised, any conditions that should be
made in respect of that authorisation.
Chapter 8
(r) Where the proposed activity does not include operational aspects, the period for which
the environmental authorisation is required and the date on which the activity will be
concluded and the post construction monitoring requirements finalised.
N/A
(s) An undertaking under oath or affirmation by the EAP in relation to –
(i) The correctness of the information provided in the reports.
(ii) The inclusion of comments and inputs from stakeholders and I&APs.
(iii) The inclusion of inputs and recommendations from the specialist reports where
relevant.
(iv) Any information provided by the EAP to interested and affected parties and any
responses by the EAP to comments or inputs made by interested or affected
parties.
Appendix I
(t) Where applicable, details of any financial provision for the rehabilitation, closure, and
ongoing post decommissioning management of negative environmental impacts. N/A
(u) An indication of any deviation from the approved scoping report, including the plan of
study, including –
(i) Any deviation from the methodology used in determining the significance of
potential environmental impacts and risks.
(ii) A motivation for the deviation.
N/A
(v) Any specific information that may be required by the competent authority. N/A
(w) Any other matters required in terms of Section 24(4)(a) and (b) of the Act. N/A
(2) Where a government notice gazetted by the Minister provides for any protocol or
minimum information requirement to be applied to an Environmental Impact Assessment
Report the requirements as indicated in such notice will apply.
N/A
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Invitation to comment on the EIA Report Page x
FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT FOR SUBMISSION TO GDARD
This final EIA Report has been prepared by Savannah Environmental in order to assess the potential
environmental impacts associated with the proposed activities. This process is being undertaken in support
of an application for Environmental Authorisation from the Gauteng Department of Agriculture and Rural
Development in terms of the National Environmental Management Act (NEMA; Act 107 of 1998).
Members of the public, local communities and stakeholders were invited to comment on the EIA Report for
the Clayville Thermal Plant which was made available for 30-day public review and comment period at
the following locations from 26 June 2018 – 26 July 2018:
» Olifantsfontein Library (c/o Pearce & Mason Avenue, Olifantsfontein, Kempton Park)
» Winnie Mandela Library (Margaret Zyma Street, Tembisa)
» www.savannahSA.com
This final EIA Report includes all comments received as well as responses to those comments. Where
applicable, this final EIA Report has been amended to address these comments. All amendments and/or
additions to this report have been underlined for ease of reference.
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Executive Summary Page xi
EXECUTIVE SUMMARY
Background
Bellmall Energy Project 325 (Pty) Ltd is proposing
the installation of a thermal plant utilising a
Circulating Fluidised Bed (CFB) boiler in the
Clayville industrial area near Olifantsfontein. The
thermal plant, also referred to as the central
plant is proposed on Erf 457, Erf 459 and Portion
12 of Erf 508 which is situated within the Ekurhuleni
Metropolitan Municipality. The project site is
approximately 1.76ha in extent. The proposed
project is to be known as the Clayville Thermal
Plant (refer to Figure 1).
The purpose of the central plant would be to
provide steam to off-takers in the industrial area.
It is proposed to utilise coal fines in combination
with syngas and/or natural gas as feedstock for
the CFB boiler. The steam generation plant will
have a capacity of up to 240 tons of steam per
hour which is an equivalent of up to 60 MWe. The
development of the thermal plant in the Clayville
industrial area will provide the opportunity to
utilise an already available resource such as coal
fines which are regarded as a waste by-product
from coal mining, as a fuel to produce steam for
off-takers to utilise in various processes (i.e. direct
heat, process steam, power generation etc.).
The installation of the Clayville Thermal Plant will
eliminate the need for off-takers to produce their
own steam using small boilers located on the off-
taker’s site. The project will also be designed as a
Zero Liquid Effluent Discharge (ZLED) facility, and
will therefore provide for the on-site treatment,
reuse, and recycling of wastewater.
Potential process steam off-takers include:
» Aspen;
» Astral Foods;
» Clover SA;
» Sasko and
» Nestle R&R Ice cream.
The applicant is also considering two additional
off-takers; Norcros Johnson and Vesuvius.
The main infrastructure associated with the
Clayville Thermal Plant includes the following:
» CFB Boiler;
» Steam supply pipes from the central plant to
various off-takers within the Clayville industrial
area;
» Steam condensate return pipes to the central
plant from various off-takers within the
Clayville industrial area;
» Exhaust stack located adjacent to the central
plant;
» Condenser on site for the conversion of steam
back to water;
» Wastewater treatment plant with a capacity
of 6 000kl per day;
» Effluent pipes and clean water supply pipes
connected from the central plant to 5 off-
takers within the Clayville industrial area;
» Holding tanks for the storage of water;
» Storage of diesel within permanent immobile
liquid tanks;
» Silos for the storage of bottom ash, fly ash and
limestone;
» Gas cylinders for the storage of syngas;
» Dome for the storage of coal fines;
» Feedstock holding and processing area;
» Ancillary infrastructure including access
roads, maintenance building, access control
facilities and office.
Potential impacts associated with the
development of the Clayville Thermal Plant are
expected to occur during both the construction
and operation phases. From the conclusions of
the detailed specialist studies undertaken, no
fatal flaws, no-go areas or areas of
environmental sensitivity were identified within
the project site. The potential environmental
impacts associated with the proposed Thermal
Plant include:
» Air Quality and Human Health: The operation
of the Clayville Thermal Plant will generate
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Executive Summary Page xii
low emissions which will result in low ambient
SO2, NO2, CO and PM10 concentrations, and
low ambient air quality impacts for the
construction, operation and decommissioning
phase. The proposed development and
associated infrastructure is therefore unlikely
to result in permanent damage to ambient air
quality, and poses a low risk to human health.
Considering the results of the dispersion
modelling and air quality impact assessment,
the operation of the Clayville Thermal Plant is
expected to generate relatively low emissions
from the CFB boiler for the coal fines-only
scenario, and significantly lower emissions for
the Syngas and natural gas scenarios. These
in turn, result in ambient concentrations that
are well below the NAAQS. The risk
associated with the proposed development
from an air quality and human health risk
perspective is therefore considered to be of
low significance and acceptable.
» Heritage Resources: No significant
archaeological, cultural landscape, built
environment or battlefield sites were
recorded on the development site during the
field surveys. No impacts on heritage
resources are expected to occur due to the
development of the Clayville Thermal Plant.
Based on the findings of the Heritage
Assessment the site is considered to be of low
archaeological significance. The impact of
the development of the Clayville Thermal
Plant on the archaeological nature of the site
is considered to be of a low significance with
the implementation of the appropriate
mitigation measures.
» Traffic: Impacts on traffic will be most
significant during the construction phase due
to an increase of heavy vehicles on the
existing road network. However, traffic
volumes associated with the project are not
significant and can be accommodated on
the existing road network with ease.
However, the four-way stop controlled
intersection of Industry Road/ Nut Avenue is
however already over capacity and it is
recommended that the intersection be
signalised in consultation with the relevant
roads authority. Overall the impacts of the
Thermal Plant on traffic will be of a medium to
low significance with the implementation of
mitigation measures. It is concluded that the
development of the Clayville Thermal Plant
will not have a detrimental impact on traffic
or existing roads.
» Cumulative Impacts: Considering the findings
of the specialist assessments undertaken for
the project, cumulative impacts range from a
low to moderate significance and can be
considered as both positive and negative.
Based on a detailed evaluation, the
cumulative impacts associated with the
construction and operation of the Clayville
Thermal Plant and other developments in the
region are considered to be acceptable. The
implementation of the EMPr and
recommended mitigation measures would
assist in mitigating these negative impacts to
an acceptable level as well as enhancing the
positive impacts to a beneficial level.
The findings of the specialist studies undertaken
within this EIA to assess both the benefits and
potential negative impacts anticipated as a
result of the proposed project conclude that
there are no environmental fatal flaws that should
prevent the Clayville Thermal Plant from
proceeding, provided that the recommended
mitigation and management measures are
implemented.
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Executive Summary Page xiii
Figure 1: Locality map showing the area proposed for the establishment of the Clayville Thermal Plant within the Clayville industrial area.
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Table of Content Page xiv
TABLE OF CONTENTS
PAGE
PROJECT DETAILS ............................................................................................................................................................ i
PURPOSE OF THE ENVIRONMENTAL IMPACT ASSESSMENT REPORT ............................................................................ ii
GDARD REQUIMENT FOR THE ENVIRONMENTAL IMPACT ASSESSMENT REPORT ...................................................... iii
LEGAL REQUIREMENTS IN TERMS OF THE EIA REGULATIONS ..................................................................................... vii
FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT FOR SUBMISSION TO GDARD ............................................ x
EXECUTIVE SUMMARY ................................................................................................................................................... xi
TABLE OF CONTENTS ................................................................................................................................................... xiv
APPENDICES .............................................................................................................................................................. xviii
DEFINITIONS AND TERMINOLOGY ............................................................................................................................. xix
ABBREVIATIONS AND ACRONYMS ........................................................................................................................... xxii
CHAPTER 1 INTRODUCTION ........................................................................................................................................... 1
1.1 Outline of the EIA Report ................................................................................................................................... 2
1.2 Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended) .................................................................................................................... 2
1.3 Project Overview ................................................................................................................................................ 3
1.4 Requirements for an Environmental Impact Assessment (EIA) ..................................................................... 9
1.5 Conclusions from the Scoping Phase .............................................................................................................. 9
1.5.1 Evaluation of the Proposed Project .............................................................................................................. 9
1.5.2 Risks Associated with the Proposed Project .............................................................................................. 11
1.5.3 Scoping Phase Conclusion and Recommendations................................................................................ 14
1.6 Details and Expertise of the Environmental Assessment Practitioner (EAP) .............................................. 14
CHAPTER 2 POLICY AND LEGISLATIVE CONTEXT ....................................................................................................... 16
2.1 Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended) .................................................................................................................. 16
2.2 Regulatory and Legal Context........................................................................................................................ 16
2.3 National Policy and Planning Context ........................................................................................................... 17
2.3.1 National Waste Management Strategy 2011 ............................................................................................17
2.3.2 The White Paper on Integrated Pollution and Waste Management for South Africa, 2000 ............17
2.3.3 National Development Plan (NDP), 2030 ...................................................................................................18
2.3.4 New Growth Path Framework, 2011 ............................................................................................................18
2.3.5 Climate Change Bill, 2018 .............................................................................................................................18
2.3.6 National Climate Change Response Policy, 2011 ....................................................................................19
2.3.7 Industrial Policy Action Plan (IPAP), 2016 / 2017 – 2018 / 2019 ..............................................................20
2.4 Provincial Policy and Planning Context ........................................................................................................ 20
2.4.1. Gauteng Provincial Environmental Management Framework (GPEMF) 2014 ...................................20
2.4.2. Gauteng Integrated Waste Management Policy ....................................................................................22
2.4.3. Review of the 2009 Gauteng Air Quality Management Plan (AQMP)(2018)......................................23
2.5 Local Policy and Planning Context ................................................................................................................ 24
2.5.1. Ekurhuleni Metropolitan Municipality Spatial Development Framework (MSDF), 2015 .....................24
2.5.2 Ekurhuleni Growth and Development Strategy, 2025..............................................................................24
2.5.3 Ekurhuleni Metropolitan Municipality Integrated Development Plan (IDP), 2013/2014 ....................25
2.5.4 Ekurhuleni Metropolitan Municipality Regional Spatial Development Framework (RSDF): Region B,
2015 25
2.6 International Policy .......................................................................................................................................... 26
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Table of Content Page xv
CHAPTER 3 PROJECT DESCRIPTION ............................................................................................................................ 28
3.1 Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended) .................................................................................................................. 28
3.2 Need and Desirability for the Clayville Thermal Plant ................................................................................. 28
3.3 Project Alternatives .......................................................................................................................................... 30
3.3.1 Site Alternatives ...............................................................................................................................................30
3.3.2 Layout Alternatives .........................................................................................................................................32
3.3.3 Technology Alternatives ................................................................................................................................34
3.3.4 Cooling Technology alternatives .................................................................................................................34
3.3.5 The ‘Do-Nothing’ Alternative ........................................................................................................................34
3.4 Description of the Proposed Project............................................................................................................... 34
3.4.1 Infrastructure ....................................................................................................................................................36
3.4.2 Overview CFB Boiler Technology .................................................................................................................38
3.4.3 Recycling of wastewater ...............................................................................................................................40
3.5 Life-cycle Phases of the Thermal Plant .......................................................................................................... 41
3.5.1 Construction Phase .........................................................................................................................................41
3.5.2 Operation Phase .............................................................................................................................................42
3.5.3 Decommissioning Phase ................................................................................................................................43
CHAPTER 4: APPROACH TO UNDERTAKING THE EIA PHASE .................................................................................... 44
4.1. Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended) .................................................................................................................. 44
4.2. Relevant legislative permitting requirements ............................................................................................... 45
4.2.1. National Environmental Management Act (No. 107 of 1998) (NEMA)..................................................45
4.2.2. National Environmental Management: Air Quality Act (No. 39 of 2004) (NEM:AQA) .......................46
4.2.3. EIA Regulations, 2014 as amended (GNR326) ..........................................................................................47
4.3. Scoping Phase .................................................................................................................................................. 47
4.4. EIA Phase ........................................................................................................................................................... 48
4.4.1. Tasks completed during the EIA Phase .......................................................................................................48
4.4.2. Authority Consultation ....................................................................................................................................49
4.4.3. Public Participation Process ..........................................................................................................................50
4.4.4. Identification and Recording of Issues and Concerns .............................................................................53
4.4.5. Assessment of Issues Identified through the Scoping Process ...............................................................56
4.4.6. Assumptions and Limitations .........................................................................................................................58
4.5. Legislation and Guidelines that have informed the preparation of this Environmental Impact
Assessment Report ...................................................................................................................................................... 58
4.5.1 International Guidelines .................................................................................................................................68
i. The Equator Principles III (June, 2013) ................................................................................................................68
ii. International Finance Corporation (IFC) Performance Standards on Environmental and Social
Sustainability (January 2012) .......................................................................................................................................69
iii. The IFC Environmental Health and Safety (EHS) Guidelines .......................................................................70
CHAPTER 5: DESCRIPTION OF THE RECEIVING ENVIRONMENT ................................................................................. 72
5.1 Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended) .................................................................................................................. 72
5.2 Regional Setting: Location of the Project Site ............................................................................................... 72
5.3 Climatic Conditions .......................................................................................................................................... 73
5.4 Biophysical Characteristics of the Study Area ............................................................................................. 74
5.4.1 Geology ............................................................................................................................................................74
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5.4.2 Soils and Agricultural Potential .....................................................................................................................76
5.4.3 Ecological Profile .............................................................................................................................................76
5.5 Access and Transport Routes in the Region .................................................................................................. 78
5.6 Air Quality .......................................................................................................................................................... 78
5.7 Heritage features of the region ....................................................................................................................... 79
5.7.1 Heritage and archaeology ..........................................................................................................................79
5.7.2 Palaeontology (Fossils) ..................................................................................................................................81
5.8 Social and Economic Characteristics of the Project Site and Surrounding Areas ................................... 82
CHAPTER 6: ASSESSMENT OF POTENTIAL IMPACTS .................................................................................................... 83
6.1 Legal Requirements as per the EIA Regulations for the undertaking of a Environmental Impact
Assessment (EIA) Report, 2014 (as amended) ........................................................................................................ 85
6.2. Potential Impacts on Ambient Air Quality ..................................................................................................... 86
6.2.1 Results of Impact Assessment .......................................................................................................................86
6.2.2 Description of Impacts ...................................................................................................................................87
6.2.3 Impact table summarising the significance of impacts on the ambient air quality during
construction and operation (with and without mitigation) ...................................................................................88
6.2.4 Implications for Project Implementation ....................................................................................................90
6.3. Potential Impacts on Heritage Features ........................................................................................................ 90
6.3.1 Results of Impact Assessment .......................................................................................................................90
6.3.2 Description of Impacts ...................................................................................................................................91
6.3.3 Impact table summarising the significance of heritage impacts (with and without mitigation) ...91
6.3.4 Implications for Project Implementation ....................................................................................................92
6.4. Potential Impacts on Traffic ............................................................................................................................. 92
6.4.1 Results of Impact Assessment .......................................................................................................................92
6.4.2 Description of Impacts ...................................................................................................................................93
6.4.3 Impact table summarising the significance of traffic impacts (with and without mitigation) ........93
6.4.4 Implications for Project Implementation ....................................................................................................96
6.5. Impacts related to the Storage and Handling of Dangerous Goods ......................................................... 96
6.5.1 Description of Impacts associated with the Storage and Handling of Dangerous Goods .............97
6.5.2 Impact table summarising the significance of the storage and handling of dangerous goods
(with and without mitigation) .......................................................................................................................................97
6.6. Assessment of the Do Nothing Alternative .................................................................................................... 98
CHAPTER 7: ASSESSMENT OF CUMULATIVE IMPACTS ..............................................................................................100
7.1. Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended) ................................................................................................................100
7.2. Approach Taken to Assess Potential Cumulative Impacts .......................................................................101
7.3. Cumulative Impacts Associated with the Development of the Clayville Thermal Plant .......................103
7.3.1. Potential Cumulative Impacts on Air Quality ......................................................................................... 103
7.3.2. Potential Cumulative Impacts on Archaeology and Heritage ........................................................... 104
7.3.3. Potential Cumulative Impacts on Traffic ................................................................................................. 105
7.4. Conclusions Regarding Cumulative Impacts .............................................................................................106
CHAPTER 8 CONCLUSIONS AND RECOMMENDATIONS .........................................................................................108
8.1 Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended) ................................................................................................................108
8.2 Assessment Process .......................................................................................................................................109
8.3 Overview of the Clayville Thermal Plant ......................................................................................................110
8.4 Evaluation of the Proposed Project ..............................................................................................................111
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Table of Content Page xvii
8.4.1 Impacts on Air Quality and Human Health ............................................................................................. 111
8.4.2 Impacts on Heritage Resources ................................................................................................................ 112
8.4.3 Impacts on Traffic ......................................................................................................................................... 112
8.4.4 Cumulative impacts .................................................................................................................................... 112
8.5 Environmental Costs of the Project versus Benefits of the Project ............................................................116
8.6 Overall Conclusion (Impact Statement) .....................................................................................................116
8.7 Overall Recommendation.............................................................................................................................117
CHAPTER 9: REFERENCES ...........................................................................................................................................119
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Final Environmental Impact Assessment Report September 2018
Appendices Page xviii
APPENDICES
Appendix A: EIA Project Consulting Team CVs
Appendix B: Correspondence with Authorities
Appendix C: Public Participation Information
Appendix C1: I&AP Database
Appendix C2: Site Notices and Newspaper Advertisements
Appendix C3: Background Information Document
Appendix C4: Organs of State Correspondence
Appendix C5: Stakeholder Correspondence
Appendix C6: Comments Received
Appendix C7: Minutes of Meetings
Appendix C8: Comments and Responses Report
Appendix D: Air Quality Impact Assessment
Appendix E: Heritage Impact Assessment
Appendix F: Traffic Assessment
Appendix G: Other Additional Information
Appendix G1: Site Coordinates
Appendix G2: Zoning Certificates
Appendix G3: Site Plan
Appendix H: Environmental Management Programme
Appendix I: EAP Affirmation and Declaration
Appendix J: A3 Maps
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Definitions and Terminology Page xix
DEFINITIONS AND TERMINOLOGY
Alternatives: Alternatives are different means of meeting the general purpose and need of a proposed
activity. Alternatives may include location or site alternatives, activity alternatives, process or technology
alternatives, temporal alternatives or the ‘do nothing’ alternative.
Commence: The start of any physical activity, including site preparation and any other activity on site
furtherance of a listed activity or specified activity, but does not include any activity required for the
purposes of an investigation or feasibility study as long as such investigation or feasibility study does not
constitute a listed activity or specified activity.
Commissioning: Commissioning commences once construction is completed.
Construction: Construction means the building, erection or establishment of a facility, structure or
infrastructure that is necessary for the undertaking of a listed or specified activity. Construction begins with
any activity which requires Environmental Authorisation.
Cumulative impacts: Impacts that result from the incremental impact of the proposed activity on a
common resource when added to the impacts of other past, present or reasonably foreseeable future
activities (e.g. discharges of nutrients and heated water to a river that combine to cause algal bloom and
subsequent loss of dissolved oxygen that is greater than the additive impacts of each pollutant).
Cumulative impacts can occur from the collective impacts of individual minor actions over a period and
can include both direct and indirect impacts.
Decommissioning: To take out of active service permanently or dismantle partly or wholly, or closure of a
facility to the extent that it cannot be readily re-commissioned. This usually occurs at the end of the life of
a facility.
Direct impacts: Impacts that are caused directly by the activity and generally occur at the same time and
at the place of the activity (e.g. noise generated by blasting operations on the site of the activity). These
impacts are usually associated with the construction, operation, or maintenance of an activity and are
generally obvious and quantifiable.
Disturbing noise: A noise level that exceeds the ambient sound level measured continuously at the same
measuring point by 7 dB or more.
‘Do nothing’ alternative: The ‘do nothing’ alternative is the option of not undertaking the proposed activity
or any of its alternatives. The ‘do nothing’ alternative also provides the baseline against which the impacts
of other alternatives should be compared.
Endangered species: Taxa in danger of extinction and whose survival is unlikely if the causal factors
continue operating. Included here are taxa whose numbers of individuals have been reduced to a critical
level or whose habitats have been so drastically reduced that they are deemed to be in immediate
danger of extinction.
Emergency: An undesired/ unplanned event that results in a significant environmental impact and requires
the notification of the relevant statutory body, such as a local authority.
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Final Environmental Impact Assessment Report September 2018
Definitions and Terminology Page xx
Endemic: An "endemic" is a species that grows in a particular area (is endemic to that region) and has a
restricted distribution. It is only found in a particular place. Whether something is endemic or not depends
on the geographical boundaries of the area in question and the area can be defined at different scales.
Environment: the surroundings within which humans exist and that are made up of:
i. The land, water and atmosphere of the earth;
ii. Micro-organisms, plant and animal life;
iii. Any part or combination of (i) and (ii) and the interrelationships among and between them;
and
iv. The physical, chemical, aesthetic and cultural properties and conditions of the foregoing that
influence human health and well-being.
Environmental impact: An action or series of actions that have an effect on the environment.
Environmental impact assessment: Environmental Impact Assessment, as defined in the NEMA EIA
Regulations and in relation to an application to which scoping must be applied, means the process of
collecting, organising, analysing, interpreting and communicating information that is relevant to the
consideration of that application.
Environmental management: Ensuring that environmental concerns are included in all stages of
development, so that development is sustainable and does not exceed the carrying capacity of the
environment.
Environmental management programme: An operational plan that organises and co-ordinates mitigation,
rehabilitation and monitoring measures in order to guide the implementation of a proposal and its ongoing
maintenance after implementation.
Heritage: That which is inherited and forms part of the National Estate (Historical places, objects, fossils as
defined by the National Heritage Resources Act of 2000).
Indigenous: All biological organisms that occurred naturally within the study area prior to 1800.
Indirect impacts: Indirect or induced changes that may occur because of the activity (e.g. the reduction
of water in a stream that supply water to a reservoir that supply water to the activity). These types of
impacts include all the potential impacts that do not manifest immediately when the activity is undertaken
or which occur at a different place because of the activity.
Interested and affected party: Individuals or groups concerned with or affected by an activity and its
consequences. These include the authorities, local communities, investors, work force, consumers,
environmental interest groups, and the public.
No-go areas: Areas of environmental sensitivity that should not be impacted on or utilised during the
development of a project as identified in any environmental reports.
Pollution: A change in the environment caused by substances (radio-active or other waves, noise, odours,
dust or heat emitted from any activity, including the storage or treatment or waste or substances.
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Definitions and Terminology Page xxi
Pre-construction: The period prior to the commencement of construction, this may include activities which
do not require Environmental Authorisation (e.g. geotechnical surveys).
Rare species: Taxa with small world populations that are not at present Endangered or Vulnerable, but are
at risk as some unexpected threat could easily cause a critical decline. These taxa are usually localised
within restricted geographical areas or habitats or are thinly scattered over a more extensive range. This
category was termed Critically Rare by Hall and Veldhuis (1985) to distinguish it from the more generally
used word "rare.”
Red data species: Species listed in terms of the International Union for Conservation of Nature and Natural
Resources (IUCN) Red List of Threatened Species, and/or in terms of the South African Red Data list. In
terms of the South African Red Data list, species are classified as being extinct, endangered, vulnerable,
rare, indeterminate, insufficiently known or not threatened (see other definitions within this glossary).
Risk: The chance or likelihood of a hazard causing harm to a person, to property or the environment. The
extent of the risk depends not only on the severity of potential harm to the environment but also on other
factors such as the number of people exposed.
Significant impact: An impact that by its magnitude, duration, intensity, or probability of occurrence may
have a notable effect on one or more aspects of the environment.
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Final Environmental Impact Assessment Report September 2018
Abbreviations Page xxii
ABBREVIATIONS AND ACRONYMS
BID Background Information Document
CBOs Community Based Organisations
CDM Clean Development Mechanism
CSIR Council for Scientific and Industrial Research
CO2 Carbon dioxide
D Diameter of the rotor blades
DAFF Department of Forestry and Fishery
DEA National Department of Environmental Affairs
DENC Department of Economic Development and Nature Conservation
DME Department of Minerals and Energy
DOT Department of Transport
DWS Department of Water and Sanitation
EIA Environmental Impact Assessment
EMPr Environmental Management Programme
GIS Geographical Information Systems
GG Government Gazette
GN Government Notice
Ha Hectare
I&AP Interested and Affected Party
IDP Integrated Development Plan
IEP Integrated Energy Planning
km2 Square kilometres
km/hr Kilometres per hour
kV Kilovolt
m2 Square meters
m/s Meters per second
MW Mega Watt
NEMA National Environmental Management Act (Act No 107 of 1998)
NERSA National Energy Regulator of South Africa
NHRA National Heritage Resources Act (Act No 25 of 1999)
NGOs Non-Governmental Organisations
NIRP National Integrated Resource Planning
NWA National Water Act (Act No 36 of 1998)
SAHRA South African Heritage Resources Agency
SANBI South African National Biodiversity Institute
SANRAL South African National Roads Agency Limited
SDF Spatial Development Framework
SKA Square Kilometre Array
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Introduction Page 1
CHAPTER 1 INTRODUCTION
Bellmall Energy Project 325 (Pty) Ltd is proposing the installation of a thermal plant utilising a Circulating
Fluidised Bed (CFB) boiler in the Clayville industrial area near Olifantsfontein. The thermal plant, also
referred to as the central plant, is proposed on Erf 457, Erf 459 and Portion 12 of Erf 508 which is situated
within the Ekurhuleni Metropolitan Municipality. The development footprint of the facility will be
appropriately placed within the project site of approximately 1.76ha in extent. The proposed project is to
be known as the Clayville Thermal Plant.
The purpose of the central plant would be to provide steam to off-takers in the industrial area. It is
proposed to utilise coal fines in combination with syngas and/or natural gas as feedstock for the CFB
boiler. The coal fines will be sourced from mines within the Delmas and Middelburg areas. Syngas will be
sourced from the Bellmall Energy Syngas Plant situated at remote locations. Natural gas will be sourced
from Sasol via an existing gas pipeline situated along Spanner Road (western boundary of the project site)
within the Clayville industrial area. The steam generation plant will have a capacity of up to 240 tons of
steam per hour which is an equivalent of up to 60 MWe. The development of the thermal plant in the
Clayville industrial area will provide the opportunity to utilise an already available resource such as coal
fines which are regarded as a waste by-product from coal mining, as a fuel to produce steam for off-
takers to utilise in various processes (i.e. direct heat, process steam, power generation etc.). The
installation of the Clayville Thermal Plant will eliminate the need for off-takers to produce their own steam
using small boilers located on the off-taker’s site. The project will also be designed as a Zero Liquid Effluent
Discharge (ZLED) facility, and will therefore provide for the on-site treatment, reuse, and recycling of
wastewater. The associated skills transfer and demonstration effects of the proposed technology provides
a learning opportunity for future developments of this nature in South Africa.
As the project has the potential to impact on the environment, an Environmental Impact Assessment (EIA)
process is required to be completed in support of an application for Environmental Authorisation prior to
the commencement of construction and operation of the project. The nature and extent of the Clayville
Thermal Plant, as well as the potential environmental impacts associated with the construction, operation
and decommissioning phases are explored in more detail in this EIA Report.
In terms of the EIA Regulations 2014, as amended in April 2017, a Scoping and EIA study is required to be
undertaken for the project. The Scoping Phase of the EIA process identified potential environmental
impacts that may be associated with the proposed Clayville Thermal Plant. The Scoping Report was
accepted by the Gauteng Department of Agriculture and Rural Development (GDARD) in December
2017.
Following this, the applicant consulted with the National Energy Regulator of South Africa (NERSA) in order
to confirm compliance of the proposed project with relevant legislation and to confirm the feedstock type
and source. Confirmation in this regard was received in March 2018. The EIA project schedule was
therefore delayed, and the applicant and specialist consulting team were not in a position to provide the
Competent Authority with all the information requested within the prescribed timeframes. Subsequently,
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Introduction Page 2
the applicant requested that the file be closed on 18 May 2018. In terms of Regulation 21(2) of the EIA
Regulations of 2014 (as amended), the findings of the scoping report remain valid and the environmental
context has not changed. Therefore, the EIA process is proceeding from the EIA Phase following the
submission of a new application form.
1.1 Outline of the EIA Report
The EIA Phase addresses those identified potential environmental impacts and benefits associated with all
phases of the project including design, construction and operation, and recommends appropriate
mitigation measures for potentially significant environmental impacts. The EIA Report aims to provide the
GDARD with sufficient information to make an informed decision regarding the project.
This final EIA Report consists of the following sections:
» Chapter 1 provides background to the project and the EIA, a summary of the recommendations and
conclusions from the Scoping Report, and the details of the Environmental Assessment Practitioner
(EAP) conducting the EIA.
» Chapter 2 outlines the strategic legal context for the project at a national, regional and local level.
» Chapter 3 provides a description of the project, including feasible alternatives considered, and the
need and desirability of the project.
» Chapter 4 outlines the approach to undertaking the EIA process.
» Chapter 5 describes the existing biophysical and socio-economic environment within and surrounding
the project development footprint.
» Chapter 6 provides an assessment of the potential issues and impacts associated with the Clayville
Thermal Plant and presents recommendations for mitigation of significant impacts.
» Chapter 7 provides an assessment of cumulative impacts associated with the Clayville Thermal Plant
together with other similar developments in the area.
» Chapter 8 presents the conclusions and recommendations based on the findings of the EIA.
» Chapter 9 provides a list of reference material used to compile the EIA Report.
1.2 Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended)
This final EIA Report has been prepared in accordance with the requirements of the EIA Regulations
published on 08 December 2014 (as amended on 07 April 2017), promulgated in terms of Chapter 5 of the
National Environmental Management Act (Act No 107 of 1998). This chapter of the EIA Report includes the
following information required in terms of Appendix 3: Content of Environmental Impact Assessment
Reports:
Requirement Relevant Section
3(a) the details of the EAP who prepared the report and
(ii) the expertise of the EAP, including a curriculum vitae.
The details (including expertise) of the EAP who prepared
the EIA Report as well as the supporting Savannah
Environmental project team are included in Section 1.5.
The CVs of the project team have also been included as
Appendix A.
3(b) the location of the development footprint of the The location of the project site proposed for the
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
Final Environmental Impact Assessment Report September 2018
Introduction Page 3
Requirement Relevant Section
activity on the approved site as contemplated in the
accepted Scoping Report including (i) the 21 digit
Surveyor General code of each cadastral land parcel,
(ii) where available the physical address and farm name
and (iii) where the required information in items (i) and (ii)
is not available, the co-ordinates of the boundary of the
property or properties.
development of the Clayville Thermal Plant is illustrated in
Figures 1.1 and 1.2. Details of the project site are
included in Section 1.2, Table 1.1.
1.3 Project Overview
As a fast emerging economy, South Africa needs to balance the competing need for continued
economic growth with its social needs and the protection of the natural environment. South Africa needs
to grow in its ability to sustain the natural environment through the sustainable management of waste.
According to ESI Africa (2014), coal mining in South Africa has produced approximately a billion tonnes of
discarded thermal-grade coal fines within the past 150 years. Due to the difficult handling and
transportation of coal fines, this waste by-product is discarded into heaps and slurry dams and emits CO2
as it is being stored. Bellmall Energy Project 325 (Pty) Ltd has identified these coal fines as a potential
feedstock for the production of steam to be provided to various industrial off-takers.
Bellmall Energy Project 325 (Pty) Ltd is investigating the installation of a thermal plant utilising a Circulating
Fluidised Bed (CFB) boiler on a site in the Clayville industrial area in Gauteng Province. The thermal plant
will combine high-efficiency combustion of various solid fuels with low emissions, even when burning fuels
with completely different calorific values simultaneously. The feedstock is proposed to be a combination
of syngas/natural gas and coal fines. The purpose of the central plant would be to provide steam to Astral
Foods and other off-takers in the industrial area, thereby eliminating the need for each of these industries
to produce their own steam.
Potential process steam off-takers include (refer to Figure 1.3):
» Aspen;
» Astral Foods;
» Clover SA;
» Sasko; and
» Nestle R&R Ice cream;
The applicant is also considering two additional off-takers; Norcros Johnson and Vesuvius.
The Clayville Thermal Plant and associated infrastructure is proposed to be constructed on Erf 457, Erf 459
and Portion 12 of Erf 508 within the Clayville industrial area (refer to Figure 1.1, Figure 1.2 and Table 1.1).
The thermal plant will generate up to 240 tons of steam per hour which is an equivalent of up to 60 MWe.
The main infrastructure associated with the facility includes the following:
» CFB Boiler;
» Steam supply pipes from the central plant to various off-takers within the Clayville industrial area;
» Steam condensate return pipes to the central plant from various off-takers within the Clayville industrial
area;
» Exhaust stack located adjacent to the central plant;
» Condenser on site for the conversion of steam back to water;
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» Wastewater treatment plant with a capacity of 6 000kl per day;
» Effluent pipes and clean water supply pipes connected from the central plant to 5 off-takers within the
Clayville industrial area;
» Holding tanks for the storage of water;
» Storage of diesel within permanent immobile liquid tanks;
» Silos for the storage of bottom ash, fly ash and limestone;
» Gas cylinders for the storage of syngas;
» Dome for the storage of coal fines;
» Feedstock holding and processing area;
» Ancillary infrastructure including access roads, maintenance building, access control facilities and
office.
Steam generated at the central plant will also be utilised to generate power via steam turbines. In
accordance with the requirements of NERSA, individual turbines for each industrial off-taker being supplied
with steam from the central plant will be located within the central site. These turbines will be owned by
the various steam off-takers, and each turbine will be sized to each off-taker’s requirements. Should the
electricity output of an individual turbine exceed 10MW, an environmental authorisation will be required to
be obtained. Separate applications for authorisation will be undertaken once the details of these turbines
are fully defined.
Potential steam off-takers include:
» Coca-Cola Beverages SA;
» Actom-Wilec;
» Adcock Ingram;
» Aspen;
» Astral Foods;
» Clover SA;
» Nampac;
» Nestle R&R Ice cream;
» RSC Steel;
» Spar;
» Tiger Brands;
» Sasko; and
» Hulamin.
Table 1.1: A detailed description of the project site identified for the development of the Clayville
Thermal Plant
Province Gauteng
Municipality Ekurhuleni Metropolitan Municipality
Ward number(s) 1
Nearest residential areas Clayville East (~1.1km east), Tswelapele (~1.8km west) and Clayville (~1.95km
north west)
Farm name(s) and number(s) Erf 457,
Erf 459, and
Portion 12 of Erf 508
SG 21 Digit Code (s) » T0JR00360000045700000
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» T0JR00360000045900000
» T0JR00360000050800012
Current zoning Industrial Use – The affected properties are located within the Clayville
Industrial Area and are zoned as Industrial 1.
Current land use Erf 459 is being used for industrial purposes, while Erf 457 and Erf 12 of 50 are
currently vacant land.
Site Co-ordinates Northern-most extent: 25°58’8.65’’ S 28°14’5.71’’ E
Eastern-most extent: 25°58’10.33’’ S 28°14’7.01’’ E
Southern-most extent: 25°58’15.93’’ S 28°13’59.47’’ E
Western-most extent: 25°58’14.26’’ S 28°13’58.17’’ E
Centre point: 25°58’12.35’’ S 28°14’ 2.40’’ E
More details regarding the proposed project are included within Chapter 3 of this Report.
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Figure 1.1: Locality map showing the area proposed for the establishment of the Clayville Thermal Plant within the Clayville Industrial Area
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Figure 1.2: Locality map showing the affected properties which form the project site proposed for the development
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Figure 1.3: Locality map showing the affected properties in relation to the potential process steam off-taker sites.
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1.4 Requirements for an Environmental Impact Assessment (EIA)
In accordance with Section 24(5) of the National Environmental Management Act (No. 107 of 1998)
(NEMA), and the 2014 Environmental Impact Assessment (EIA) Regulations (GNR 326) the development of
the Clayville Thermal Plant and associated infrastructure requires Environmental Authorisation (EA) from the
Competent Authority (CA), the Gauteng Department of Agriculture and Rural Development (GDARD).
Environmental Authorisation (EA) required for the project is subject to the completion of a full Scoping and
Environmental Impact Assessment (S&EIA) process as the proposed project entails, amongst others, the
development of facilities or infrastructure for any process or activity which requires a permit or licence or
an amended permit or licence in terms of the national or provincial legislation governing the generation or
release of emissions, pollution or effluent (Activity 6, Listing Notice 2 (GNR 325)).
This EIA process is therefore being conducted in support of an application for EA (previous GDARD
Reference Number: GAUT 002/17-18/I0004), and is also intended to support an Atmospheric Emissions
License (AEL) required in terms of Section 21 of the National Environmental Management: Air Quality Act
(No. 39 of 2004) (NEM:AQA) and the List of Activities resulting in Atmospheric Emissions (GNR 893) from the
Atmospheric Emissions Licensing Authority (AELA), the Ekurhuleni Metropolitan Municipality. The process of
applying for an AEL will be completed following the completion of the EIA process, once EA has been
granted for the project.
An EIA is an effective planning and decision-making tool for the project developer as it allows for the
identification and management of potential environmental impacts. It provides the opportunity for the
developer to be fore-warned of potential environmental issues, and allows for the resolution of issues
reported on in the Scoping and EIA Reports, as well as a dialogue with interested and affected parties
(I&APs).
1.5 Conclusions from the Scoping Phase
1.5.1 Evaluation of the Proposed Project
From the Scoping Study undertaken, it was concluded that the potential positive and negative impacts
identified to be associated with the construction and operation of the Clayville Thermal Plant are
anticipated to be at a site-specific or localised level, with few impacts extending to a local or national
extent. The following section provides a summary of the findings of the specialist studies undertaken.
» Air Quality: The construction of the Clayville Thermal Plant has the potential to impact on the ambient
air quality of the area by increasing concentrations of the various gases and particulates, especially
during the operation phase of the plant. The impact is expected to be of a low significance. The
significance of the impact will be confirmed through a detailed assessment undertaken during the EIA
phase. Climate change impacts associated with the development of the thermal plant relates to the
emission of greenhouse gases that will contribute to the global phenomenon of anthropogenic climate
change. Climate change is projected to effect many environmental changes across the globe. The
contribution of the Clayville Thermal Plant to global warming is expected to be very low due to
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relatively low emissions of GHGs and the global effect will not be directly measurable. The downwind
sector from the thermal plant is predominantly east-southeast to west-southwest of the facility, i.e.
downwind under the prevailing west-northwest to east-northeast. There are two residential areas in
close proximity to the project site and includes Clayville East (1.1km north east) and Tswelopele (1.8km
to the west). A risk exists that emissions from the Clayville Thermal Plant may result in ambient
concentrations of the air pollutants in the nearby residential areas that exceeds the health based
NAAQS. The project site is located in an industrial area which provides a buffer between the thermal
plant and the residential areas. It was recommended that air dispersion modelling utilising the DEA
recommended SCREEN3 model to predict ambient concentrations of air pollutants resulting from the
Thermal Plant for emissions during the operational phase be undertaken. It was furthermore
recommended that a comprehensive air quality impact assessment report in the format prescribed by
the Department of Environmental Affairs (DEA) in support of the Atmospheric Emission License (AEL)
application be compiled for the Thermal Plant.
» Ecology: No impacts on ecology are expected to occur due to the highly transformed and disturbed
nature of the affected properties as well as the highly fractured and isolated nature of the area. There
are no form of noteworthy natural biodiversity, ecological functions and services as well as biotic
interactions within the project site. Most of the vegetative species comprises of weeds, pioneers and
Invasive Alien Plants (IAPs). Bare patches, devoid of vegetation, are also present within Erf 457 and
Portion 12 of Erf 508 and has resulted in soil compaction and some sheet erosion. Due to the
ecological conditions as well as the industrial setting of the project site, it was concluded that no
further ecological investigation is required to be undertaken.
» Archaeological and Heritage Resources: The construction phase of the Clayville Thermal Plant may
impact on archaeological resources due to the construction activities which include excavation.
Stone Age sites are expected to occur within the project site and could be impacted by the
development. The impacts of the construction activities on the archaeological and heritage resources
include potential damage to and destruction of archaeological and heritage sites, indirect impacts
including impact on the cultural landscape and residual risks including the depletion of the
archaeological record of the broader region. The impact is expected to be of a low-medium
significance and will be confirmed through a detailed assessment and fieldwork during the EIA phase.
» Palaeontological Resources: Loss of palaeontological heritage could occur during the construction
phase of the Clayville Thermal Plant. Construction activities could result in the damage and
destruction of the resources or sealing in of fossils below the ground surface making these no longer
available for scientific consideration. Even though the project site is located within very high
palaeontological sensitivity zone, the project site is highly disturbed from previous and current industrial
buildings, infrastructure and roads, and any surface fossils that may occur in the Vryheid Formation
would be very weathered and unrecognisable. Therefore the impact will be of a low significance.
Due to a lack of fossil heritage located within the project site, it was concluded that no further study
was required for the EIA phase.
» Socio-economic aspects: The construction of the Clayville Thermal Plant will result in both positive and
negative impacts. During the construction phase the positive impacts will include temporary
employment opportunities, skills development and household income leading to improved standard of
living. These impacts are expected to be of medium significance. Negative impacts expected during
the construction phase include a change in the demographics of the area due to an influx of
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jobseekers, increased pressure on basic services and social and economic infrastructure, an increased
demand in housing within the broader area and an increase in traffic and impacts on movement
patterns. These impacts are expected to be of low and medium significance. Positive and negative
impacts are expected to occur with the operation of the Clayville Thermal Plant. Positive impacts
include employment opportunities, skills development, household income that will improve the
standard of living. These impacts are expected to be of low-medium significance. The negative
impact expected during operation is the deterioration of quality of public health due to combined
emissions from the operating thermal plant. The expected significance of the negative impact is
medium. Another impact that will possibly occur during operation is traffic impacts which are
expected to be of low significance. From the above identified potential impacts it is concluded that
the positive impacts outweigh the negative impacts from a social perspective. Only potential impacts
associated with increased traffic are required to be further investigated through a detailed assessment
within the EIA Phase.
» Impacts Related to the Storage and Handling of Dangerous Goods: During the operation phase, the
Thermal Plant will require the storage of materials which may be considered to be dangerous goods,
including chemicals for the wastewater treatment plant and diesel. The facilities or infrastructure for
storage and handling of a dangerous good will be located in containers with a combined capacity of
80m³ (cubic metres). These substances will be stored on-site in appropriate storage vessels within
bunded areas/ on impervious surfaces. The storage and handling of dangerous goods has the
potential to result in soil and/or water contamination should any spillages/leakages occur. The impact
is expected to be of medium significance. Appropriate mitigation measures will be included within the
Environmental Management Programme such that the risk of the impact occurring is minimised and
appropriately managed.
» Cumulative Impacts: The project site is located within the centre of the Clayville industrial area that is
zoned for industrial use, within Zone 5 of the Gauteng Province EMF and within an area where further
industry is planned. Other industrial facilities within the area include Nestle Ice Cream, Coca-Cola
Beverages, Sasko and Astral Foods. Positive cumulative impact associated with the thermal plant
include the reduction of waste by utilising waste as a feedstock. From a cumulative perspective, it is
anticipated that the development of the Clayville Thermal Plant will not result in unacceptable risk or
loss to the environment. This is supported by the fact that the site is located within the Clayville
industrial area and with Zone 5 according to the GPEMF and can therefore be considered as a site
which would have been developed for some type of industry. It is also considered unlikely that the site
will be used for agricultural purposes due to its location within the industrial area, the limited land
capability of the project site and also due to the current land zoning of the site.
No environmental fatal flaws or impacts of very high significance were identified to be associated with the
development of the Clayville Thermal Plant on the identified project site during the Scoping Phase. This
conclusion will be confirmed through a detailed investigation of the development footprint by the
independent specialist studies within the EIA Report.
1.5.2 Risks Associated with the Proposed Project
Figure 1.4 provides the environmental sensitivity map compiled on the basis of the findings of the Scoping
Study. No environmental sensitivities were identified within the project site. The most significant risk
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associated with the project is the potential for increase in air quality impacts associated with the operation
phase of the project. Detailed investigation of impacts of the Clayville Thermal Plant on air quality will be
required to be undertaken in order to confirm the significance of potential impacts and risks. During the
Olifantsfontein Business Forum on 03 August 2017, concerns regarding traffic impacts during the
construction and operation of the thermal plant were raised. A Traffic Impact Assessment will be
undertaken to assess the significance of traffic impacts.
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Figure 1.4: Scoping Phase Environmental sensitivity map illustrating the sensitive environmental features located within the Clayville Thermal
Plant project site
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1.5.3 Scoping Phase Conclusion and Recommendations
The findings of the Scoping Study were based primarily on a desktop assessment, and based on this
assessment no environmental fatal flaws associated with the Clayville Thermal Plant and associated
infrastructure within the project site were identified. Therefore, no reason was identified for the project not
to be evaluated further in a detailed EIA study.
The facility layout will be assessed in detail and the potential impacts of the development, as identified
during the Scoping Phase, will be ground-truthed by the independent specialist studies that form part of
the EIA Study (as per the Plan of Study for the EIA included in the final Scoping Report). The independent
specialist studies will also provide recommendations for the implementation of avoidance strategies
(where possible) and mitigation and management measures (if required) to ensure that the final
recommended facility layout retains an acceptable environmental impact and considers all highly
sensitive features located within the project site.
1.6 Details and Expertise of the Environmental Assessment Practitioner (EAP)
Savannah Environmental has been appointed by Bellmall Energy Project 325 (Pty) Ltd as independent
consultants to undertake the required EIA Process. Savannah Environmental is a leading provider of
integrated environmental and social consulting, advisory and management services with considerable
experience in the fields of environmental assessment and management. The company is wholly woman-
owned (51% black woman-owned), and is rated as a Level 2 Broad-based Black Economic Empowerment
(B-BBEE) Contributor as the company is an Exempted Micro Enterprise (EME). The company was
established in 2006 with a clear objective to provide services to the infrastructure development sector. The
undertaking of studies involving all environmental-related disciplines has allowed for considerable
experience to be gained in the fields of environmental impact assessment and management. Savannah
Environmental’s team have been actively involved in undertaking environmental stud ies over the past 12
years, for a wide variety of infrastructure development projects throughout South Africa.
The EIA process for the Clayville Thermal Plant is being managed by Jo-Anne Thomas. She is supported by
Thalita Botha and Gabriele Stein.
» Jo-Anne Thomas is a Director at Savannah Environmental (Pty) Ltd. Jo-Anne has a Master of Science
Degree in Botany (M.Sc. Botany) from the University of the Witwatersrand, and is registered as a
Professional Natural Scientist (400024/2000) with the South African Council for Natural Scientific
Professions (SACNASP). She has gained extensive knowledge and experience on potential
environmental impacts associated with electricity generation and transmission projects through her
involvement in related EIA processes over the past 20 years. She has successfully managed and
undertaken EIA processes for infrastructure development projects throughout South Africa.
» Thalita Botha is the principle author of this report. She holds a Bachelor degree with Honours in
Environmental Management and has two (2) and a half years of experience in the environmental field.
Her key focus is on environmental impact assessments, public participation, environmental
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management plans and programmes, as well as mapping using ArcGIS for a variety of environmental
projects.
» Gabriele Stein is a Social and Public Participation Consultant at Savannah Environmental. Gabriele has
a Bachelor of Arts Honours Degree in Anthropology (B.A. Honours) from the University of Johannesburg
(UJ). She has 10 years of experience as a Social Consultant in the field of public participation and
social research. Her experience includes the professional execution of public participation consulting
for a variety of projects, and includes the management and coordination of public participation
processes for EIAs for projects in a wide range of sectors, including the infrastructure sector. Gabriele is
responsible for managing the Public Participation process required as part of the EIA for this project.
Curricula Vitae (CVs) detailing Savannah Environmental teams expertise and relevant experience are
provided in Appendix A.
In order to adequately identify and assess potential environmental impacts as well as evaluate
alternatives, Savannah Environmental has appointed several specialist consultants to conduct specialist
studies, as required. Details of these specialist studies are included in Chapter 4. The curricula vitae for the
EIA specialist consultants are also included in Appendix A.
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CHAPTER 2 POLICY AND LEGISLATIVE CONTEXT
This Chapter provides an overview of the policy and legislative context within which the Clayville Thermal
Plant and associated infrastructure is proposed. It identifies environmental legislation, policies, plans,
guidelines, spatial tools, municipal development planning frameworks and instruments that are applicable
to this activity and are to be considered in the assessment process which may be applicable or have
relevance to the proposed project.
2.1 Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended)
This chapter of this finalEIA report includes the following information required in terms of Appendix 3:
Content of Environmental Impact Assessment reports:
Requirement Relevant Section
3(e) a description of the policy and legislative context
within which the development is located and an
explanation of how the proposed development complies
with and responds to the legislation and policy context.
The policy and legislative context at a national,
provincial and local level associated with the
development of the Clayville Thermal Plant has been
considered throughout this chapter. A description of
how the project responds to the identified policy and
legislative context is also included.
2.2 Regulatory and Legal Context
The regulatory hierarchy for the development of the Clayville Thermal Plant consists of three tiers of
authorities who exercise control through both statutory and non-statutory instruments - that is National,
Provincial and Local levels.
At National Level, the main regulatory agencies are:
» NERSA
» South African National Roads Agency (SANRAL): This Agency is responsible for the regulation and
maintenance of all national routes.
At the Provincial Level, the main regulatory agencies are:
» Gauteng Department of Agriculture and Rural Development – This department is the competent
authority identified for the project. This department aims to conserve the environment and its
resources, promote sustainable use, protect and continually enhance environmental assets, enhance
socio-economic benefits and employment creation for present and future generations from a healthy
environment.
» Provincial Heritage Resources Authority Gauteng (PHRAG) - This department identifies, conserves and
manages heritage resources throughout the Gauteng Province.
At the Local Level, the local and municipal authorities are the principal regulatory authorities responsible
for planning, land use and the environment. In the Gauteng Province, the local, district and metropolitan
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municipalities play a role. For the Clayville Thermal Plant, the local level authority is the Ekurhuleni
Metropolitan Municipality. The Ekurhuleni Metropolitan Municipality is responsible for the issuing of
Atmospheric Emissions Licenses (AELs) under the National Environmental Management: Air Quality Act (No.
39 of 2004) (NEM:AQA) for activities within its area of jurisdiction.
2.3 National Policy and Planning Context
The following national policies are considered to be relevant to the development of the Clayville Thermal
Plant.
2.3.1 National Waste Management Strategy 2011
Waste management has become a challenge within South Africa due to rapid growth, urbanisation and
consumerist population. The National Waste Management Strategy 2011 recognises the limited ability of
landfills to absorb solid and liquid waste. “Through the country’s commitment to sustainable development,
South Africa aims to balance the broader economic and social challenges of a developing and unequal
society while protecting environmental resources”. This can be achieved though the implementation of
various processes such as re-using, recycling and recovery of waste.
The National Waste Management Strategy lists eight main strategic goals which include:
» Promote waste minimisation, re-use, recycling and recovery of waste.
» Ensure the effective and efficient delivery of waste services.
» Grow the contribution of the waste sector to the green economy.
» Ensure that people are aware of the impact of waste on their health, well-being and the environment.
» Achieve integrated waste management planning.
» Ensure sound budgeting and financial management for waste services.
» Provide measures to remediate contaminated land.
» Establish effective compliance with and enforcement of the National Waste Act.
The Strategy follows the same management hierarchy approach as the National Waste Act. This hierarchy
identifies the avoidance and reduction of waste as the foundation of the approach.
2.3.2 The White Paper on Integrated Pollution and Waste Management for South Africa, 2000
The White Paper places emphasis on preventative strategies which aims to minimise waste and prevent
pollution. The White Paper recognises the crucial role which the private sector and civil society plays along
with the government to ensure sustainable and effective pollution and waste management in South
Africa. One of the fundamental approaches of this policy is to prevent pollution, minimise waste, and to
control and remediate impacts. According to the White Paper, management of waste will be
implemented in a holistic and integrated manner, and will extend over the entire waste cycle, from
“cradle to grave”, including the generation, storage, collection, transportation, treatment, and final
disposal of waste.
Through the implementation of the White Paper, the government aims to:
» Encourage the prevention and minimisation of waste generation and thus pollution at source;
» Encourage the management and minimisation of the impact of unavoidable waste from its generation
to its final disposal;
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» Ensure the integrity and sustained “fitness for use” of all environmental media , i.e. air, water and land;
» Ensure that any pollution of the environment is remediated by holding the responsible parties
accountable;
» Ensure environmental justice by integrating environmental considerations with the social, political and
development needs and rights of all sectors, communities and individuals; and
» Prosecute non-compliance with authorisations and legislation.
2.3.3 National Development Plan (NDP), 2030
The National Development Plan (NDP) 2030 is a plan prepared by the National Planning Commission in
consultation with the South African public which is aimed at eliminating poverty and reducing inequality
by 2030. The NDP aims to achieve this by drawing on the energies of its people, growing and inclusive
economy, building capabilities, enhancing the capacity of the state and promoting leaderships and
partnerships throughout society. While the achievement of the objectives of the NDP requires progress on
a broad front, three priorities stand out, namely:
» Raising employment through faster economic growth
» Improving the quality of education, skills development and innovation
» Building the capability of the state to play a developmental, transformative role.
The Clayville Thermal Plant is in-line with the National Development Plan as the development will create
employment opportunities which could assist in addressing poverty issues.
2.3.4 New Growth Path Framework, 2011
The purpose of the New Growth Path (NGP) Framework is to provide effective strategies towards
accelerated job-creation through the development of an equitable economy and sustained growth. The
target of the NGP is to create 5 million jobs by 2020. With economic growth and employment creation as
the key indicators identified in the NGP, the framework seeks to identify key structural changes in the
economy that can improve performance in terms of labour absorption and the composition and rate of
growth. To achieve this, government will seek to, amongst other things, identify key areas for large-scale
employment creation, as a result of changes in conditions in South Africa and globally, and to develop a
policy package to facilitate employment creation in these areas.
The construction and operation of the Clayville Thermal Plant will aid in the creation of sustainable
employment and is therefore is considered to be in line with the NGPF.
2.3.5 Climate Change Bill, 2018
On 8 June 2018 the Minister of Environmental Affairs published the Climate Change Bill (“the Bill”) for public
comment. The Bill provides a framework for climate change regulation in South Africa aimed at governing
South Africa’s sustainable transition to a climate resilient, low carbon economy and society. The Bill
provides a procedural outline that will be developed through the creation of frameworks and plans. The
following objectives are set within the Bill:
a) provide for the coordinated and integrated response to climate change and its impacts by all
spheres of government in accordance with the principles of cooperative governance;
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b) provide for the effective management of inevitable climate change impacts through enhancing
adaptive capacity, strengthening resilience and reducing vulnerability to climate change, with a
view to building social, economic, and environmental resilience and an adequate national
adaptation response in the context of the global climate change response;
c) make a fair contribution to the global effort to stabilise greenhouse gas concentrations in the
atmosphere at a level that avoids dangerous anthropogenic interference with the climate system
within a timeframe and in a manner that enables economic, employment, social and
environmental development to proceed in a sustainable manner.
Off-takers in the Clayville industrial area utilise small boilers located on-site to produce steam. The
installation of the Clayville Thermal Plant will eliminate the need for small boilers on the off-taker’s site. It is
expected that the removal of individual boilers will reduce emissions within the industrial area. The CFB
boiler will utilise coal fines (i.e. a waste by-product from coal mining) as a fuel source. These coal fines are
commonly stored as coal dumps and slurry dams and emits CO2 as it is being stored. By utilising coal fines
as a fuel source, emissions will be reduced.
2.3.6 National Climate Change Response Policy, 2011
South Africa’s National Climate Change Response Policy (NCCRP) establishes South Africa’s approach to
addressing climate change, including adaptation and mitigation responses. The NCCRP formalises
Government’s vision for a transition to a low carbon economy, through the adoption of the ‘Peak, Plateau
and Decline’ (PPD) GHG emissions trajectory whereby South Africa’s emissions should peak between 2020
and 2025, plateau for approximately a decade, and then decline in absolute terms thereafter, and based
on this the country has pledged to reduce emissions by 34% and 42% below Business As Usual (BAU)
emissions in 2020 and 2025, respectively.
As an integral part of the policy, a set of near-term priority flagship programmes will be implemented to
address the challenges of climate change. Amongst others, the Waste Management Flagship Programme
was identified by the government and will be led by the DEA. This flagship programme will “establish the
GHG mitigation potential of the waste management sector”. This will include investigating the generation,
capture, conversion and/or use of methane emissions amongst others. This data will in turn be used to
compile and implement a detailed Action Plan specifically related to the reduction of GHG emissions
associated with waste.
The Department of Environmental Affairs (DEA) released a draft National Adaptation Strategy (NAS) for
South Africa in November 2016 for comment. The NAS is intended to:
» Act as the primary guidance document for climate change adaptation efforts in South Africa,
providing direction for all levels of government.
» Inform national, provincial and local development planning.
» Help gauge the degree to which development initiatives at different levels of government integrate
and reflect critical climate change adaptation priorities, and thus inform levels of resource allocation
from revenue streams related to climate change resilience.
» Support South Africa in meeting its international obligations by demonstrating progress on climate
change adaptation, and also serve as South Africa’s national adaptation plan.
» Guide stronger coherence and coordination on climate change adaptation between different
institutions and levels of government.
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The installation of the Clayville Thermal Plant will eliminate the need for small boilers on the off-taker’s site.
It is expected that the removal of individual boilers will reduce emissions within the industrial area. The CFB
boiler will utilise coal fines which are commonly stored as coal dumps and slurry dams and emits CO2 as it is
being stored as a fuel source. By utilising coal fines as a fuel source, emissions will be reduced.
2.3.7 Industrial Policy Action Plan (IPAP), 2016 / 2017 – 2018 / 2019
The Industrial Policy Action Plan (IPAP) 2016/2017 – 2018/2019 represents a significant step forward in
scaling up the country’s efforts to promote long-term industrialisation and industrial diversification. It has
been recognised that the Southern African region is fast transforming into an oil and gas jurisdiction led by
major on and offshore gas finds in Mozambique, Tanzania, Botswana and Namibia. From a South African
perspective, the scale of the natural gas find in neighbouring Mozambique (estimated at between 200-
250tcf) is of particular significance. Accordingly, the plan states that a key industrial growth path is gas-
based industrialisation (Department of Trade and Industry, 2016).
In this quest, the development of the long-term strategic framework to leverage the opportunities
presented by regional oil and gas resources was created. The core purpose of this intervention is to put in
place the necessary institutional infrastructure to implement the long-term strategic programme and
maximise the multiplier effects of recently discovered and potentially forthcoming Southern African natural
gas resources (Department of Trade and Industry, 2016).
As the industrial growth for the country has been identified as being gas-based, the development of the
Clayville Thermal Plant utilising natural gas and/or syngas as a fuel resource, will assist in achieving the
goals of the IPAP.
2.4 Provincial Policy and Planning Context
The following provincial policies are considered to be relevant to the development of the Clayville Thermal
Plant.
2.4.1. Gauteng Provincial Environmental Management Framework (GPEMF) 2014
The Provincial EMF was gazetted on 22 May 2015 and replaces all other environmental management
frameworks in the province. The objective of the GPEMF is to guide sustainable land use management
within the Gauteng Province. The GPEMF provides a strategic and overall framework for environmental
management in Gauteng while aligning sustainable development initiatives with the environmental
resources, developmental pressures, as well as the growth imperatives of Gauteng.
Key objectives identified within the GPEMF are:
» To facilitate the optimal use of current industrial, mining land and other suitable derelict land for the
development of non-polluting industrial and large commercial developments.
» To protect Critical Biodiversity Areas (CBAs as defined in C-Plan version 3.3) within urban and rural
environments.
» To ensure the proper integration Ecological Support Areas (ESAs as defined in C-Plan version 3.3) into
rural land use change and development.
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» To use ESAs as defined in municipal bioregional plans in spatial planning of urban open space corridors
and links within urban areas.
» To focus on the sustainability of development through the implementation of initiatives such as:
Energy efficiency programmes, plans and designs;
Waste minimisation, reuse and recycling;
Green infrastructure in urban areas; and
Sustainable Drainage Systems (SuDS).
The development of the Clayville Thermal Plant will facilitate the optimal use of current industrial land, and
contribute towards the sustainability of developments through waste minimisation, reuse and recycling as
outlined in the GPEMF.
The GPEMF has divided the Gauteng Province into five Environmental Management Zones (EMZs) (refer to
Figure 2.1). The purpose of these zones is to identify specific planning and policy measures associated with
a specific zone to achieve the development objectives of the zone. The GPEMP identifies appropriate,
inappropriate and conditionally compatible activities in various Environmental Management Zones in a
manner that promotes proactive decision-making.
The Clayville Thermal Plant falls within Zone 5, which is the industrial and commercial development focus
zone. The purpose of Zone 5 is to streamline environmental impact management related to non-polluting
industrial and large-scale activities in areas that are already being used for this purpose by identifying
certain listed activities which do not require Environmental Authorisation. A notice to exempt these
activities from environmental authorisation was adopted on 22 May 2018. The Clayville Thermal Plant does
however not trigger any activities which are exempted from applying for Environmental Authorisations.
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Figure 2.1: Environmental Management Zones within Gauteng (obtained from the Gauteng
Environmental Management Framework, 2014).
2.4.2. Gauteng Integrated Waste Management Policy
The Gauteng Province has the greatest industrial density which also generates the largest amount of
waste. The Gauteng Department of Agriculture, Conservation and Environment (GDACE) recognised the
need for a policy which will ensure that waste is effectively managed while preserving human health and
the environment. The Gauteng Integrated Waste Management Policy, 2006 has been adopted in
response to this need. The goal set out by the Gauteng IWM Policy is to “set out the vision, principles and
strategic goals and objectives that the Gauteng Provincial Government will apply to achieve integrated
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and environmentally-sustainable waste management in the Province, thereby ensuring that its obligations
and duties in terms of the South African Constitution and other relevant requirements are effected”.
The Gauteng IWM Policy aims to address issues, problems and needs of the Gauteng Province in terms of
waste and embraces co-operative environmental governance by establishing decision-making principles
on factors that affect the environment including:
» Sustainable development;
» Integrated Environmental Management using the Best Practical Environmental Option;
» The Polluter Pays Principle;
» The Cradle to Grave Responsibility;
» The Precautionary Principle; and
» The involvement of Interested and Affected Parties (IAPs) and stakeholders in environmental decision-
making.
Wastewater produced by Astral Foods are currently being disposed into the municipal sewage system.
The Clayville Thermal Plant will treat wastewater from Astral Foods to a potable standard. The water will
then be piped back to Astral Foods to be reused in their processing plant.
2.4.3. Review of the 2009 Gauteng Air Quality Management Plan (AQMP)(2018)
The Gauteng Department of Agriculture and Rural Development (GDARD) compiled the first provincial Air
Quality Management Plan in 2009 in accordance with Section 15(1) of the National Environmental
Management: Air Quality Act (Act No. 39 of 2004). The Plan identifies seven key air quality management
issues in the province and intervention strategies to address each of these issues. Considering physical
changes to the environment and multiple air quality management activities in the province, the GDARD
have recognised the need to review the 2009 AQMP. The overall objective for the review of the Gauteng
AQMP is to establish the status of air quality in the province and to develop an AQMP with objectives to
ensure prevention of deterioration and improvement in air quality in the province.
The following goals are set out in the Plan:
» Goal 1: Emissions in Gauteng are reduced to improve ambient air quality to comply with the NAAQS.
» Goal 2: The AQMP is incorporated into provincial policy and planning.
» Goal 3: GDARD has the necessary skills to implement the AQMP.
» Goal 4: GDARD has the necessary systems and tools to implement the AQMP.
» Goal 5: GDARD has the necessary incentives to implement the AQMP.
» Goal 6: AQM in Gauteng is supported by participatory decision making.
» Goal 7: Awareness of AQM in Gauteng is inclusive and effective.
The AQMP includes an Implementation Plan which provides strategic input to the Annual Performance
Planning (APP) of executing departments and of other stakeholders and focusses on specific aspects for
each goal. The implementation of the AQMP therefore depends on the Air Quality Directorate and the
input and participation of other stakeholders. The Implementation Plan furthermore provides indicators
which are designed to be easily interpreted and offer a means of measuring progress with implementation
and reporting on progress.
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The installation of the Clayville Thermal Plant will eliminate the need for small boilers on the off-taker’s site.
It is expected that the removal of individual boilers will reduce emissions within the industrial area and
therefore in line with Goal 1 of the AQMP.
2.5 Local Policy and Planning Context
The strategic policies at the district and local level1 have similar objectives for the respective areas, namely
to accelerate economic growth, create jobs, uplift communities and alleviate poverty. As detailed below,
the development of the Clayville Thermal Plant is considered to align with the aims of these policies, even if
contributions to achieving the goals therein are only minor.
2.5.1. Ekurhuleni Metropolitan Municipality Spatial Development Framework (MSDF), 2015
The purpose of the Ekurhuleni Metropolitan Municipality (EMM) SDF of 2015 is to provide the first step
towards guiding future spatial development in Ekurhuleni to achieve a more sustainable metropolitan city
structure, which can lead economic and social development in Gauteng (EMM, 2015).
The MSDF recognises that development is multi-facetted with various sectors such as the economic, social,
physical and institutional sectors that influence each other and provides and overview of these sectors
and how they impact on the spatial development of Ekurhuleni. Considering the economic trends and
tendencies of Ekurhuleni, it is evident that the area is characterised by growing unemployment and
increasing job losses. Approximately 58% of the population in Gauteng is economically active of which the
highest unemployment rate are currently found in the Ekurhuleni Metropolitan Area. The Clayville Thermal
Plant will result in the creation of job opportunities within Ekurhuleni.
The MSDF also identifies seven major concentrations of industrial activity which includes approximately 20
industrial areas. Amongst these are the Olifantsfontein and Clayville industrial areas which consist
predominantly of heavy industrial activities. The Clayville Thermal Plant will be situated within the centre of
the Clayville industrial area and will be consistent with the existing industrial character of the area.
2.5.2 Ekurhuleni Growth and Development Strategy, 2025
The Ekurhuleni Metropolitan Municipality Growth and Development Strategy (EMM GDS) takes guidance
from the NDP and responds thereto by including programmes that would address the results planned in
the NDP, and also the unique challenges Ekurhuleni is facing on its development trajectory (IDP & SDBIP
2013/2014). Therefore, the purpose of the EMM GDS is to translate the NDP into a detailed implementation
plan at a metropolitan level.
The EMM GDS identifies key focus areas within the Metropolitan Municipality as follows:
» The local economy requires a greater degree of sustainable diversification;
1 The uThungulu District Municipality was renamed King Cetshwayo District Municipality in July 2016.
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» As elsewhere in South Africa, unemployment is high, and policies to promote labour absorption and job
creation will be of crucial importance to the future of the city;
» The improvement of skills levels to attract and support local economic growth is of critical importance;
» Ekurhuleni is a gateway into Africa and opportunities for tourism promotion and development locally
should be taken advantage of;
» No city can survive without new investment (in physical, economic and social infrastructure) and
investment promotion and facilitation will therefore be a key focus area; and
» The greatest portion of the wealth in the city is still in the hands of a small elite, and broad-based
economic transformation as well as entrepreneurial activity will therefore be promoted at every
opportunity.
The proposed project will result in the creation of job opportunities, sustainability, and strategic
infrastructure for social and economic growth which will contribute, albeit to a limited extent, towards
reducing poverty and inequality in Gauteng. This development will therefore assist the municipality in
achieving the aims of the EMM GDS to some extent.
2.5.3 Ekurhuleni Metropolitan Municipality Integrated Development Plan (IDP), 2013/2014
The Ekurhuleni Metropolitan Municipality IDP is the principal strategic planning instrument which guides and
informs all planning, budgeting, management and decision making processes in the municipality and
recognises the importance of stakeholder involvement. The purpose of the IDP is to identify key
development priorities; formulate a clear vision, mission and values for the municipality; formulate
appropriate strategies; develop the appropriate organisational structure and systems to realise the vision
and mission; and align resources with the development priorities (EMM, 2013).
The development of the Clayville Thermal Plant will create employment opportunities which will contribute
towards strengthening the current socio-economic conditions of the area, as well as improving the
standard of living.
2.5.4 Ekurhuleni Metropolitan Municipality Regional Spatial Development Framework (RSDF): Region B,
2015
The Ekurhuleni Metropolitan Municipality’s Regional Spatial Development Framework (RSDF) has been
developed in response to spatial issues and challenges experienced within the Municipality and to provide
direction in terms of development within the Municipality. The RSDF divided the Municipality into six regions
to provide a better understanding of the spatial structure of each region, making it easier to respond to
critical issues, to plan appropriately and to develop an SDF that will be practical and implementable.
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The project site falls within Region B as defined within the RSDF. The vision of the Municipality for Region B
includes major urban growth due to the proximity to the OR Tambo International Airport and its expected
growth as an aerotropolis2. As part of this vision, the Municipality proposed to:
» Unleash areas for urban development;
» Identify areas where selective densification is required;
» Identify areas of transition; and
» Capitalise on the untapped agricultural potential of the region.
Although the Municipality has a vision for major urban growth within Region B, the RSDF categorised the
Olifantsfontein/Clayville area as one of five focus areas for industrial and commercial development. The
other areas include the R21 development corridor, Sebenza, Eastleigh and Chloorkop.
2.6 International Policy
2.6.1 United Nations Framework Convention on Climate Change (UNFCCC) and Conference of the Party
(COP) 21 – Paris Agreement
Climate change is one of the major global challenges of the 21st century that requires global response.
The adverse impacts of climate change include persistent drought and extreme weather events, rising sea
levels, coastal erosion and ocean acidification, further threatening food security, water, energy and
health, and more broadly efforts to eradicate poverty and achieving sustainable development.
Combating climate change would require substantial and sustained reductions in greenhouse gas (GHG)
emissions, which together with adaptation, can limit climate change risks. The convention responsible for
dealing with climate change is the United Nations Framework Convention on Climate Change (UNFCCC).
The UNFCCC was adopted in 1992 and entered into force in 1994. It provides the overall global policy
framework for addressing the climate change issue and marks the first international political response to
climate change. The UNFCCC sets out a framework for action aimed at stabilizing atmospheric
concentrations of GHGs to avoid dangerous anthropogenic interference with the climate system.
The UNFCCC has established a variety of arrangements to govern, coordinate and provide for oversight of
the arrangements described in the documentation. The oversight bodies take decisions, provide regular
guidance, and keep the arrangements under regular review in order to enhance and ensure their
effectiveness and efficiency. The Conference of Parties (COP), established by Article 7 of the Convention,
is the supreme body and highest decision-making organ of the Convention. It reviews the implementation
of the Convention and any related legal instruments, and takes decisions to promote the effective
implementation of the Convention.
COP 21 was held in Paris from 30 November to 12 December 2015. From this conference, an agreement to
tackle global warming was reached between 195 countries. This Agreement is open for signature and
2 According to the Ekurhuleni Metropolitan Municipality’s RSDF for of 2015 for Region B, aerotropolis refers to a new urban form that
has commenced with evolving around airports. It consists of the traditional metropolis made up of a central city and its rings of
commuter heavy suburbs.
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subject to ratification, acceptance or approval by States and regional economic integration organisations
that are Parties to the Convention from 22 April 2016 to 21 April 2017. Thereafter, this Agreement shall be
open for accession from the day following the date on which it is closed for signature. The agreement can
only enter into force once it has been ratified by 55 countries, representing at least 55% of emissions.
This Agreement, in enhancing the implementation of the Convention, including its objective, aims to
strengthen the global response to the threat of climate change, in the context of sustainable
development and efforts to eradicate poverty, including by:
(a) Holding the increase in the global average temperature to well below 2 °C above pre-industrial levels
and to pursue efforts to limit the temperature increase to 1.5 °C above pre-industrial levels, recognising
that this would significantly reduce the risks and impacts of climate change.
(b) Increasing the ability to adapt to the adverse impacts of climate change and foster climate resilience
and low GHG emissions development, in a manner that does not threaten food production.
(c) Making finance flows consistent with a pathway towards low GHG emissions and climate-resilient
development.
In order to achieve the long-term temperature goal set out in Article 2 of the Agreement, Parties aim to
reach global peaking of GHG emissions as soon as possible, recognising that peaking will take longer for
developing country Parties, and to undertake rapid reductions thereafter in accordance with the best
available science, so as to achieve a balance between anthropogenic emissions by sources and
removals by sinks of GHGs in the second half of this century, on the basis of equity, and in the context of
sustainable development and efforts to eradicate poverty.
The Paris Agreement requires all Parties to put forward their best efforts through “nationally determined
contributions” (NDCs) and to strengthen these efforts in the years ahead. This includes requirements that
all Parties report regularly on their emissions and on their implementation efforts. In 2018, Parties will take
stock of the collective efforts in relation to progress towards the goal set in the Paris Agreement and to
inform the preparation of NDCs. There will also be a global stocktake every 5 years to assess the collective
progress towards achieving the purpose of the Agreement and to inform further individual actions by
Parties.
South Africa signed the Agreement in April 2016, and ratified the agreement on 01 November 2016. The
Agreement was assented to by the National Council of Provinces on 27 October 2016, and the National
Assembly on 1 November 2016. The Agreement came into force on 04 November 2016, thirty days after
the date on which at least 55 Parties to the Convention accounting in total for at least an estimated 55%
of the total global greenhouse gas emissions have deposited their instruments of ratification, acceptance,
approval or accession with the Depositary.
The development of the Clayville Thermal Plant will eliminate the need for off-takers to produce their own
steam using small boilers located on the off-taker’s site within the Clayville industrial area. It is expected
that the removal of individual boilers will reduce emissions within the industrial area. Furthermore, the CFB
boiler will utilise coal fines which is considered to be a waste by-product from coal mining as a feedstock.
These coal fines are commonly stored as coal dumps and slurry dams and emits CO2 as it is being stored.
By utilising this waste by-product as a fuel source, emissions will be reduced.
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CHAPTER 3 PROJECT DESCRIPTION
3.1 Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended)
This chapter of this final EIA report includes the following information required in terms of Appendix 3:
Content of Environmental Impact Assessment reports:
Requirement Relevant Section
3(d)(ii) a description of the scope of the proposed
activity, including a description of the associated
structures and infrastructure related to the development.
A description of the Clayville Thermal Plant is included
within Section 3.4.
3(f) a motivation for the need and desirability for the
proposed development, including the need and
desirability of the activity in the context of the preferred
development footprint within the approved site as
contemplated in the accepted scoping report.
The need and desirability of the development of the
Clayville Thermal Plant within the project site is included
in Section 3.2.
3(g) a motivation for the preferred development
footprint within the approved site as contemplated in
the accepted scoping report.
A motivation for the preferred development footprint
within the project site is included in Section 3.3.2.
3(h)(i) details of the development footprint considered. The details of the development footprint are included in
Section 3.4, Table 3.1.
3(h)(ix) if no alternative development footprints for the
activity were investigated, the motivation for not
considering such.
No development footprint alternative were considered.
The motivation for not considering a footprint alternative
is included in Section 3.3.2.
3(h)(x) a concluding statement indicating location of
the preferred alternative development footprint within
the approved site as contemplated in the accepted
scoping report.
A concluding statement for the preferred development
footprint within the project site is included in Section
3.3.2.
3.2 Need and Desirability for the Clayville Thermal Plant
There are a number of industries within the Clayville Industrial area which make use of steam in various
processes. Some of these industries currently make use of coal-fired boilers, diesel, HFO or gas on their site
to produce steam. The central steam generation facility will make use of CFB technology which can utilise
a number of fuel sources (including waste coal fines and gas), and which will be more efficient. A central
steam generation facility (or thermal plant) in the Clayville industrial area is considered to be desirable as a
result of:
» Zoning of the site;
» Utilising a more efficient technology to raise steam for various purposes compared to existing
technologies currently being used in the Clayville industrial area, thus reducing overall air emissions in
the industrial area;
» Utilising a range of fuel sources (including waste coal fines and gas) for the production of steam,
reducing reliance on heavy fuels and lower efficiency small boilers;
» Availability of wastewater for treatment and use within the plant and other industrial companies in the
area; and
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» Providing employment opportunities.
Zoning of the site:
The proposed development site is zoned industrial and is located within a formal industrial area. The
Clayville Thermal Plant also falls within Zone 5 of the GPEMG (2014), which is the industrial and commercial
development focus zone. The development is therefore considered to be compatible with the current
land use of the property and surrounding area, as well as with development planning for the area.
Reducing CO2 emissions:
Coal fines are typically defined as coal with a particle size below 6mm and has traditionally been
considered as waste and an unwanted by‐product in the coal mining industry. These fines have presented
a major disposal challenge to the mining industry throughout South Africa. South Africa produces
approximately 300 million tons of coal per year of which up to 20% consist of coal fines
(http://minerestoration.co.za/business-segments/coal-briquetting-project/).
These coal fines are generally stored as coal dumps and slurry dams. According to Cook and Lloyd (2012),
when coal is exposed to air, oxidation takes place until the temperature is high enough for combustion to
occur. Combustion can occur when waste coal dumps still contain sufficient coal matter and therefore
these coal dumps can emit CO2. These dumps and slurry dams become a liability to mines when
rehabilitation upon mine closure is required. The coal fines also have a fairly low calorific value and
cannot be utilised for blending coal or by Eskom for power generation purposes within their current power
stations. As CFB boilers are able to utilise a variety of fuel sources (including coal fines), this provides a
viable fuel source for the proposed project. By using coal fines as part of the feedstock for the thermal
plant, the project converts a mining liability into a revenue stream.
In addition, several of the potential off-takers within the Clayville industrial area already make use of coal-
fired boilers on their site to produce steam to use in various direct and indirect processes within their plants.
Other fuel sources used by off-takers include diesel, HFO and gas. The installation of the Clayville Thermal
Plant will eliminate the need for small boilers on the off-taker’s sites and will therefore reduce different
emission sources from the various boilers within the area.
Furthermore, the CFB boiler combustion provides operators with greater flexibility in burning a range of
coal and other fuels without compromising efficiency and at the same time reducing emissions. By utilising
not only coal fines as a feedstock for the CFB boiler, but also natural gas and/or syngas, less coal and
heavy fuels will be required and therefore an overall decrease in emissions is expected within the Clayville
industrial area.
Recycling of wastewater:
Astral Foods, a poultry producer located adjacent to the project site, produces large volumes of
wastewater. The Clayville Thermal Plant will be recycling 6 000kl of Astral Foods’ (Festive’s) effluent
wastewater per day during the operation phase. The water used by Astral is currently supplied by the
municipality on a daily basis. The recycled water will be of a potable standard and will be piped back to
Astral Foods to be used in their processing plant. This will result in a reduction of wastewater being
disposed of to the municipal system, thereby reducing the pressure on these systems and impacts on the
environment. This will also decrease demand to the municipality for the supply of water to the largest
industrial user in the area.
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Employment opportunities:
Service delivery, infrastructure development, socio-economic development, poverty and unemployment
have been identified as key focus areas for the Ekurhuleni Metropolitan Municipality. The Ekurhuleni
Growth and Development Strategy, 2025 acknowledges the high unemployment rate in the municipality
and recognises that labour absorption and job creation will be of crucial importance to the future of
Gauteng.
The development of the Clayville Thermal Plant (including the wastewater treatment plant) would
contribute towards employment creation, both directly and indirectly. While only 14-25 job opportunities
are expected to be created during the operation of the plant, this is expected to contribute somewhat
towards reducing unemployment and poverty levels within the municipality.
3.3 Project Alternatives
In accordance with the requirements outlined in Appendix 2 of the EIA Regulations 2014 (as amended),
the consideration of alternatives including site, activity, technology, as well as the “do-nothing” alternative
should be undertaken. Therefore, the identification of alternatives is a key aspect of the success of the EIA
process. In relation to a proposed activity “Alternatives” means different ways of meeting the general
purposes and requirements of the proposed activity. The following sections address this requirement in
terms of the project in question.
3.3.1 Site Alternatives
A site selection process was undertaken by Bellmall Energy Project 325 to locate and identify potential sites
for the development of the thermal plant. Due to the nature of the development, the location of the
project site is largely dependent on several factors which includes:
» Location in relation to potential off-takers;
» Size of the property to facilitate a thermal plant;
» Avaialbility of the site for development.
» Proximity to a coal resource;
» Proximity to a gas resource (natural gas);
» Availability of wastewater;
» Zoning of the property; and
» Accessibility to major road infrastructure.
Based on the above criteria, Bellmall Energy Project 325 identified the Clayville Industrial area as the most
suitable area for the development of the Central Thermal Plant. Several potential sites in the Clayville
industrial area were considered for the development of the proposed thermal plant. These include:
» Erf 432 (Festive / Astral Foods) situated east of the project site;
» Erf 457;
» Erf 459;
» Erf 472 and Erf 469 located north of the project site;
» Erf R4316 (CloverSA) situated north west of the project site; and
» Portion 12 of Erf 508.
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The viability or feasibility of the use of the land parcels was further considered by the project developer.
The following was concluded:
» Erf 432 was eliminated from the process due to the property being too small to accommodate the
footprint of the Clayville Thermal Plant. Furthermore, there is also the possibility that Astral Foods would
expand their operations and would then require Erf 432.
» Erf R4316 was eliminated due the property being too small to accommodate the Clayville Thermal
Plant.
» Erf 472/469 was eliminated as an agreement could not be reached in purchasing the property.
» Erf 457, Erf 459 and Portion 12 of Erf 508 were identified as the most suitable. This is referred to as the
project site within this report and has been considered within this EIA process.
The project site adheres to the characteristics considered in the site selection process in the following ways:
» The project site is considered to be large enough to accommodate the central plant and
infrastructure associated with the plant.
» The project site is located within the centre of the Clayville industrial area, and is surrounded by
potential off-takers. Due to the close proximity of off-takers to the site, steam reticulation will be more
efficient compared to off-takers situated further away. This also leads to a smaller network of steam
pipes.
» An existing Sasol pipeline is situated along Spanner Road which is directly adjacent to the western
boundary of the project site.
» A major factor which has influence on the development of a thermal plant that utilises coal fines is the
availability of a viable coal fine resource. The location of coal resources and its associated transport
considerations therefore played a significant role in determining the broader regional area within
which a thermal plant utilising coal fines as a feedstock may be developed. Mines in the Delmas and
Middelburg areas were selected as preferred sources due to the distance between the thermal plant
and the coal fine resource.
» The project site is located adjacent to Astal Foods which can supply the thermal plant with sufficient
volumes of wastewater.
» Accessibility to the site is possible via the N1 and N14. These national routes connect to various other
national routes within the country allowing for widespread accessibility. Access to the site is also
possible via the regional road (R21), which is located approximately 1.9km to the east of the site. The
R562, also known as Olifantsfontein Road located south of the site connects to the R21 and to Old
Pretoria Main Road located to the west and can be used for access to the site.
» The project site is zoned as Industrial 1.
» All three properties are available for purchase by the project developer.
The Clayville Thermal Plant project site was the only site identified as being technically feasible and viable
to take forward to further investigation from an environmental perspective.
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3.3.2 Layout Alternatives
The project site was subjected to an environmental screening and fatal flaw analysis prior to the EIA
process in order to identify potential fatal flaws, impacts and risks associated with the activity and how
these activities will impose on the project site and surrounding areas through the life of the activity. The
Environmental Screening and Fatal Flaw Analysis approach served as a site risk assessment tool from an
environmental acceptability perspective – that is, a process to highlight or red-flag potential
environmental issues of concern within the project site prior to initiating a full EIA process. This study has
been informed by specialist screening studies and sensitivity mapping. It was concluded that the area
surrounding the project site is already disturbed by other industrial uses and infrastructure and that no
environmental fatal flaws have been identified to be associated with the thermal plant. The Clayville
Thermal Plant project site was the only site identified as being technically feasible and viable to take
forward to further investigation in support of an application for authorisation by way of EIA. This is referred
to as the preferred project site throughout this EIA Report.
A typical mitigation hierarchy was utilised for the consideration of the suitability of the site for the proposed
project during the EIA process.
1. First Mitigation: avoidance of adverse impacts as far as possible by use of preventative measures.
2. Second Mitigation: Further minimisation or reduction of adverse impacts.
3. Third Mitigation: remedy or compensation for adverse residual impacts, which are unavoidable and
cannot be reduced further.
Through the Scoping Phase a number of potential sensitive features surrounding the project site have been
identified which could be affected by the development of the Clayville Thermal Plant. No sensitivities
were identified within the project site itself. The following is of note:
» According to the Gauteng C-Plan, an ESA is situated adjacent to the western boundary of the project
site and a CBA is located south of the project site. No ESA or CBA have been identified within the
project site.
» The downwind sector from the thermal plant is predominantly east-southeast to west-southwest of the
facility, i.e. downwind under the prevailing west-northwest to east-northeast. There are two residential
areas in close proximity to the project site and includes Clayville East (1.1km north east) and Tswelapele
(1.8km to the west). A risk exists that emissions from the Clayville Thermal Plant may result in ambient
concentrations of the air pollutants in the nearby residential areas that exceeds the health based
NAAQS. The project site is located in an industrial area which provides a buffer between the thermal
plant and the residential areas.
No areas of environmental sensitivity or no-go areas which would affect the positioning of the facility within
the broader site were identified through the Scoping Phase studies. Therefore, the most suitable layout of
the facility from a technical perspective was determined (refer to Figure 3.1). This is the layout considered
within this EIA Report. No other layout alternatives are considered.
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
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Figure 3.1: Map showing the layout for the Clayville Thermal Plant and associated infrastructure located within Erf 457, Erf 459 and Portion 12
of Erf 508 (refer to Appendix J for A3 maps).
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3.3.3 Technology Alternatives
The generation of stream by utilising CFB boiler technology is considered to be an advanced conversion
technology that has the ability to produce a clean, high-calorific value steam from a wide variety of fuel
streams (e.g. coal and gas in this instance). The development of the Clayville Thermal Plant utilising a CFB
boiler has been identified by Bellmall Energy Project 325 as the most feasible technology alternative for the
generation of steam within the Clayville industrial area. The use of this technology has been considered as
the most efficient, economical and environmentally friendly technology compared to other technologies
available. This technology is considered to be a ‘tried and tested’ technology due to the numerous similar
plants being constructed and successfully operated internationally. As such, no steam generation
technology alternatives are being considered for this development within the Clayville industrial area.
3.3.4 Cooling Technology alternatives
Dry Cooling
Dry cooling by air cooled condensers (ACC) consists of large sections of finned air cooled heat
exchangers (with mechanical draft), and the exhaust steam passes through the heat exchangers forming
condensate. This arrangement uses no cooling water, and therefore requires no makeup for evaporation
losses. ACC cooling can considerably reduce the total make-up water demand, leaving only the process
consumption and service water as major users, but is limited by its sensitivity to ambient temperature. This is
the cooling technology that is preferred for the development of the Clayville Thermal Plant, due to the
location of the site which will not be able to house the extensive piping required for once-through cooling.
This is also consistent with the Department of Water and Sanitation requirements, which require a reduction
in use of water. Therefore only dry-cooling technology is considered within this EIA process.
3.3.5 The ‘Do-Nothing’ Alternative
The “do-nothing” alternative is the option of not constructing the proposed Clayville Thermal Plant. This
alternative is assessed within Chapter 6 of this report.
3.4 Description of the Proposed Project
Bellmall Energy 325 (Pty) Ltd proposes the development of the Clayville Thermal Plant on a site located
near Olifantsfontein within the Clayville industrial area in Gauteng Province. The thermal plant (also
referred to as the central plant) is proposed on Erf 457, Erf 459 and Portion 12 of Erf 508 which is situated
within the Ekurhuleni Metropolitan Municipality. The area under investigation is approximately 1.76ha in
extent (refer to Table 3.1).
Table 3.1: Project Site Details
Province Gauteng Province
Municipality Ekurhuleni Metropolitan Municipality
Ward number(s) 1
Nearest Town Clayville East (~1.1km east), Tswelapele (~1.8km west) and Clayville
(~1.95km north west)
Farm Names and Numbers Erf 457
Erf 459
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Portion 12 of Erf 508
SG 21 Digit Code
T0JR00360000045700000
T0JR00360000045900000
T0JR00360000050800012
Current Zoning Industrial Use – The affected properties are located within the Clayville
Industrial Area and are zoned as Industrial 1.
Site Extent
Erf 457 0.74ha
Erf 459 0.21ha
Portion 12 of Erf 508 0.81ha
TOTAL 1.76ha
Site Co-ordinates
Latitude: Longitude:
Northern-most extent 25°58’8.65’’ S 28°14’5.71’’ E
Eastern-most extent 25°58’10.33’’ S 28°14’7.01’’ E
Southern-most extent 25°58’15.93’’ S 28°13’59.47’’ E
Western-most extent 25°58’14.26’’ S 28°13’58.17’’ E
Centre point 25°58’12.35’’ S 28°14’ 2.40’’ E
The construction of a thermal plant utilising a Circulating Fluidised Bed (CFB) boiler will provide steam to off-
takers in the industrial area. Fuel feedstock will be a combination of coal fines, (i.e. waste coal from coal
mines), syngas and/or natural gas. The following is relevant regarding fuel supply and storage:
» Coal fines will be sourced from 2-3 mines located in the Delmas and Middelburg areas and will be
transported to the project site via road transport and stored on-site. Coal fines from the immediate
area will be procured should a source become available.
» Natural gas will be obtained via an existig Sasol pipeline situated along Spanner Road in the Clayville
industrial area. No natural gas will be stored on-site but will be supplied to the central plant as
required.
» Syngas will be sourced from the Bellmall Energy Syngas Plant situated at remote locations and will be
transported to site via trucks.
» 660 Tons / day of fuel will be delivered to the site by truck. There will be 22-25 trucks per day, 32 metric
tons each (truck and trailer configuration).
» Fuel Storage will be on the same site as the Central Site. This will entail 3 days capacity, i.e. 2000 tons.
The thermal plant will combine high-efficiency combustion of various solid fuels with low emissions, even
when burning fuels with completely different calorific values simultaneously. The steam plant will generate
up to 240 tons of steam per hour which will be an equivalent of up to 60 MWe.
Potential process steam off-takers include (refer to Figure 1.3 for a map indicating where the off-takers are
situated within the Clayville industrial area):
» Aspen;
» Astral Foods;
» Clover SA;
» Sasko; and
» Nestle R&R Ice cream.
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3.4.1 Infrastructure
The main infrastructure associated with the facility includes the following:
» CFB Boiler,
» Steam supply pipes from the central plant to various off-takers within the Clayville industrial area,
» Steam condensate return pipes to the central plant from various off-takers within the Clayville industrial
area,
» Exhaust stack located adjacent to the central plant,
» Condenser on site for the conversion of steam back to water,
» Wastewater treatment plant with a capacity of 6 000kl per day for the disinfection of water,
» Effluent pipes and clean water supply pipes connected from the central plant to 5 off-takers within the
Clayville industrial area.
» Holding tanks for the storage of water,
» Storage of diesel within permanent immobile liquid tanks,
» Silos for the storage of bottom ash, fly ash and limestone,
» Gas cylinders for the storage of syngas;
» Dome for the storage of coal fines;
» Feedstock holding and processing area, and
» Maintenance building / office and control room.
Table 3.2 provides details of the proposed thermal plant, including the main infrastructure and services.
Table 3.2: Details of the Clayville Thermal Plant and associated infrastructure
Component Description/ Dimensions
Steam Generating
capacity
240 tons of steam per hour ( equivalent of up to 60MWe)
Proposed technology Thermal Plant utilising Circulating Fluidised Bed (CFB) boiler technology
Stack dimensions Exhaust stack height will be ~55m in height with a diameter of ~2m.
Feedstock holding area
(coal fines) (area where
coal fines will be
temporarily stored before
being processed)
» Total area of ~1859m2
» The coal fines will be stored in a purpose made dome with removable covers to the
top of the tank. Size of tanks to be 25m x 45m.
» The height of the stockpile will approximately be 20m.
» A maximum of 2600m3 per day of coal fines will stored on-site during the operation
phase.
Feedstock holding area
(syngas) (area where
syngas will be temporarily
stored before being
processed)
» Forty 22 650 litre gas cylinders (made of steel and/or stainless steel)
» 112,720 GJ of Syngas will be stored in cylinders during the operation phase (3 day
supply).
Feedstock processing
area (where feedstock
will be processed before
being fed into the CFB
boiler, if required)
» ~893m2
Fuel storage » Storage of diesel will be required for a backup generator. Less than 80m³ of diesel
will be stored in a tank during operation.
» Other dangerous goods will also be stored and handled on site, including
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Component Description/ Dimensions
flammable oils (i.e. lubricant oils, solvents etc.) and chemicals for the water
treatment plant.
Gas supply » Natural gas will not be stored on site but will be supplied as required via the Sasol
gas pipeline situated along Spanner Road in the Clayville industrial area.
» Syngas will be sourced from the Bellmall Energy Syngas Plant situated at remote
locations and will be transported to site via trucks.
Pipeline (steam pipeline
to different off-takers
within the Clayville
industrial area)
» Length of the pipeline will be 3,200m.
» Internal diameter will be 300mm.
Storage of bottom ash » Will be stored in a silo (5m diameter x 18m high)
» 1-3 tonnes of bottom ash is expected to be produced an hour, which will be
removed form site on a daily basis.
Storage of fly ash » Will be stored in a silo (10m diameter x 24m high)
» 3-12 tonnes of fly ash is expected to be produced an hour, which will be removed
form site on a daily basis.
Storage of limestone » Will be stored in a silo (5m diameter x 18m high)
» The limestone consumption is expected to be 43 800 tonnes per year.
Wastewater treatment
plant
» The footprint of the wastewater treatment plant will be ~1218,69m2. No wastewater
will be discharged. The treated wastewater will be returned to the off-taker. The
capacity of the plant will be 6 000 m³ per day.
» Waste from the treatment process can be either used in a biogas plant or used for
fertilizer.
Access roads » Approximately 341m in length and 4m wide
Site access » Main access to the project site will be via existing roads - Spanner Road adjacent
to the western boundary of the project site and Industrial Road adjacent to the
eastern boundary of the project site.
Services required » Waste disposal - all waste material generated from the development, will be
collected by a contractor and the waste will be disposed of at a licensed waste
disposal site off site. This service will be arranged with the municipality when
required.
» Wastewater utilised in the central plant will be by disposed of by means of
evaporation by utilising excess heat from the boiler. The wastewater will be
transferred across the heated coils and form steam which will then evaporate.
» Sanitation – during construction, chemical toilets will be used. All sewage waste will
be collected by a contractor to be disposed of at a licensed waste disposal site.
This service will be arranged with the municipality when required. During operation,
the facility will be connected to the municipal sewer system.
» Water – Water is to be sourced from the Ekurhuleni Metropolitan Municipality Water
Works during the construction phase. The Clayville Thermal Plant will require 100kl of
water per day for a period of up to 36 months. During the operation phase of the
thermal plant, water will be sourced from both the Ekurhuleni Metropolitan
Municipality and waste water from the off-taker’s sites. Water volumes of
approximately 50-70kl per day are expected to be required for the operation of the
project.
» Electricity: the electricity requirements for this facility are to be obtained from the
municipality. This service will be arranged with the municipality when required.
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Component Description/ Dimensions
No agreement or confirmation for the above services have been obtained as yet.
3.4.2 Overview CFB Boiler Technology
The thermal plant will be designed to combine high-efficiency combustion of various solid fuels with low
emissions, even when simultaneously burning fuels with completely different calorific values. The Clayville
Thermal Plant will generate steam by utilising coal fines, syngas and/or natural gas. The steam generation
plant will generate up to 240 tons of steam per hour (an equivalent of up to 60 MWe). Figure 3.2 illustrates
how steam is typically produced at a thermal plant utilising Circulating Fluidised Bed (CFB) technology.
Figure 3.2: Illustration of a thermal plant utilising CFB technology
(http://www.brighthubengineering.com/power-plants/26549-differences-of-a-circulating-
fluidized-bed-boiler-and-a-pulverised-coal-boiler/).
The boiler furnace which is located at the bottom of the CFB boiler, contains a bed of inert material
(typically sand), which is heated and “fluidised” using jets of air. The feedstock will be spread out on the
bed to allow for combustion within the CFB boiler. Fluidised air at high pressure will lift the bed material
and the feedstock and keep it in suspension, ensuring that the gas and solid particles mix together
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turbulently for better heat transfer and chemical reactions. Fuel combustion takes place in this suspended
condition at a temperature of 760˚C to 927˚C to prevent the formation of nitrogen oxide (NO). Co-
combustion is an environmentally benign method of combining excellent reliability and availability with a
potential to optimise operational costs by allowing several fuel alternatives to be used.
The combustion of coal fines results in the generation and release of various emissions (i.e. particulate
matter (including trace metals), gases (including SO2, nitrogen oxides (NOx = NO + NO2), carbon
monoxide (CO), organics (volatile organic compounds (VOC), polycyclic organic matter (PAH, PCDD,
etc.)) and trace elements (mercury, arsenic, etc.)). Fine particles of partly burned fuel, ash and bed
material are carried along with the flue gases to the upper areas of the furnace and then into a cyclone.
Ash generated by the combustion process will be removed from the boilers (i.e. bottom ash) and flue
gases (i.e. fly ash) and will be transported via trucks back to the mines from where coal fines are to be
sourced
In the cyclone the heavier particles separate from the gas and fall into the hopper. The circulating bed
material flows together with flue gas through the furnace, after which it is separated from the gas and
returned back to the lower part of the furnace with cyclones3. This ensures an even combustion
temperature profile, which is optimal for handling a wide variety of fuel properties, such as heating value,
moisture, ash content and a number of low melting point ash components. This also ensures low primary
emissions with high combustion efficiency and an excellent utilisation of additives for sulphur removal and
other special purposes. Sorbents such as limestone are injected directly into the bed of CFB boiler to
neutralise sulphur released during the combustion process, resulting in low sulphur dioxide (SO2) emissions.
Gases that are released from the combustion process accumulate in the boilers or furnaces, and are
filtered and released into the atmosphere via a smoke stack. The stack exit temperature is expected to be
100 - 130°C.
The hot gases from the cyclone pass to the heat transfer surfaces and go out of the boiler. The heat from
the combusting feedstock is absorbed by water filled tubes, in the various heater components, which line
the boiler and flue gas path, to produce steam under very high pressures. The high pressure steam will be
piped to various off-takers’ steam turbines located on the project site and low pressure steam will be piped
to various off-takers’ within the Clayville Industrial Area to be used for a variety of processes (i.e. direct
heat, process steam etc.). The pipelines is likely to be situated either within the road reserves where
possible or within the servitude at certain areas. The pipelines will be installed above ground on the off-
taker sites and below ground when installed within the road reserve and/or servitudes.
When the spent steam comes into contact with the condenser tubes, condensation of the steam takes
place, and it is converted back into a liquid state (i.e. water). The steam will be returned from the Astral
Foods’ site and other process steam off-takers to the central plant in the form of heated water. This water
will then be pumped back to the boiler at the central plant for reheating and re-used in the closed loop
system.
3 High-efficiency cylindrical cyclones constructed of membrane walls covered by a light refractory for erosion protection. No hot
expansion joints between the furnace and the cyclone are needed.
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Steam generated at the central plant will also be utilised to generate power via steam turbines. In
accordance with the requirements of NERSA, individual turbines for each industrial off-taker being supplied
with steam from the central plant will be located within the central site itself. These turbines will be owned
by the various off-takers, and each turbine will be sized to each off-taker’s requirements. Should the
electricity output of an individual turbine exceed 10MW, an Environmental Authorisation (EA) in
accordance with Section 24(5) of the National Environmental Management Act (No. 107 of 1998) (NEMA),
and the 2014 Environmental Impact Assessment (EIA) Regulations (GNR 326) will be required to be
obtained. Separate applications for authorisation will be undertaken once the details of these turbines are
fully defined.
Potential steam off-takers include:
» Coca-Cola Beverages SA;
» Actom-Wilec;
» Adcock Ingram;
» Aspen;
» Astral Foods;
» Clover SA;
» Nampac;
» Nestle R&R Ice cream;
» RSC Steel;
» Spar;
» Tiger Brands;
» Sasko; and
» Hulamin.
3.4.3 Recycling of wastewater
The proposed central plant will be developed as a Zero Liquid Effluent Discharge (ZLED) facility. All
wastewater and effluent generated during the project’s operations, as well as wastewater from Astral
Foods, will be treated via an onsite wastewater treatment plant (WWTP) and will be reused onsite and
piped back to Astral Foods for reuse.
The wastewater treatment works will include:
» Dissolved Air Flotation System (DAF)
» Static Screen
» Aerobic reactor ~3200 m3
» Filtration tank with submerged MBR modules ~500 m3
» Desludge system
» MBR Permeate holding tanks
» Reverse Osmosis 1, low pressure; 80 % recovery of MBR Permeate
» Reverse Osmosis 2, high pressure; 60 % recovery of RO1 Brine
» Disinfection of RO Permeate
» RO Permeate Storage and Transfer
Effluent wastewater will be pumped from Astral Foods via a double-channelled launder system fitted with
a channel screen to remove coarse solids (>10mm). The screened water will then be filtered by removing
finer solids (above 2mm) which is a prerequisite for the DAF and MBR reactors. Approximately 6000kl per
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day of wastewater obtained from Astral Foods and will be stored in holding tanks onsite which will act as a
one day buffer required to handle the incoming flows, with auto overflow to drain the wastewater during
maintenance. The waste removed will be transported to a biogas plant. Alternatively, the waste can be
utilised as a fertiliser.
The filtered water will be subject to the DAF treatment to reduce fog’s and floats of sludge. After
treatment, the water from the DAF unit will be suitable to introduce to the MBR reactors. The MBR reactors
make use of membrane technology to reduce Chemical Oxygen Demand (COD), Biological Oxygen
Demand (BOD), Solids, Phosphorus and Nitrogen in the water. Sludge from the MBR reactors will be
treated by use of a press filter and dried along with all other solid streams.
Water from the MBR reactors will be pumped at a high pressure through tight membranes capable of
stripping constituents at a molecular level through Reverse Osmosis (RO), producing a high quality
permeate. Brine4 produced from the RO will be concentrated into disposable crystallised solids via low
energy evaporators. Ozone will be required for upstream pre-oxidation and for final disinfection of the RO
permeate.
The solids extracted from the brine will consist of the following salts:
Should the wastewater from Astral not be sufficient for the operation of the central plant at any given time
during operation, municipal water will be utilised.
3.5 Life-cycle Phases of the Thermal Plant
3.5.1 Construction Phase
Construction of the thermal plant and associated infrastructure (including the wastewater treatment
facility) is expected to take approximately 36 months. The construction activities involve the following:
4 The brine will be a in a liquid form which will be reduced to cake and crystallization form by removing most of the moisture through
an evaporator process, where the water is then recirculated into the recycling process. It is expected that 604kg of solids will be
extracted from the brine generated daily. The balance of the brine will consist of water which is reintroduced into the water
recycling system.
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» Prior to initiating construction, a number of surveys will be required including, but not limited to, a
comprehensive geotechnical survey, site survey and confirmation of the thermal plant footprint.
» Access roads will need to be established onsite, specifically taking into consideration the use of
abnormal vehicles.
» Site preparation activities will include clearance of any remaining vegetation within Erf 457 and Portion
12 of Erf 508 and excavations for foundations within the project site.
» Civil works will take place, including concrete works for structures such as foundations, the thermal
plant, the stack, cooling towers and associated infrastructure.
» Mechanical and electrical work will then follow.
» Ancillary infrastructure such as guard house, admin building, workshops and a warehouse will be
established.
» As construction is completed in a certain area within the project site, the construction equipment will
be removed from that specific area.
Water requirements:
During construction, water will be sourced from the Ekurhuleni Metropolitan Municipality. It is anticipated
that a maximum of 100kl of water per day would be required during the construction phase. Water is
expected to be supplied via a direct tie-in into the municipal water supply pipeline. The development will
utilise solar water heating and heat pumps to heat any hot water requirements on-site.
Storage and Handling of Hazardous substances:
The construction phase will require the handling and storage of materials including fuel, water treatment
additives and chemicals. The combined capacity of storage containers will not exceed 80m³.
Employment:
Employment opportunities will be created during the construction phase of the project which will include
highly skilled, skilled and semi-skilled positions. Highly skilled positions will be limited. Approximately 200
employment opportunities will be created which will include ~30 unskilled and semi-skilled positions, ~150
skilled positions and ~20 skilled positions will be available over the 36 month construction phase. No
employees will reside on the project site.
3.5.2 Operation Phase
The thermal plant is expected to be operational for more than 35 years. It is anticipated that there will be
full-time security, maintenance and control room staff required at the site. Maintenance will be
undertaken when and if required. Key elements of the Operation and Maintenance plan include
monitoring and reporting the performance of the project, conducting preventative and corrective
maintenance, receiving visitors, and maintaining security of the facility.
Fuel sources:
Coal fines will be sourced from up to three mines in the Delmas and Middelburg areas. Approximately
2600m³ of coal fines will be stored onsite at any one time in a dome located within the coal fines feedstock
holding area. The consumption of coal fines are expected to be 420 480 tonnes per year. Natural gas will
be supplied via the existing Sasol pipeline situated along Spanner Road and Syngas will be sourced from
the Bellmall Energy Syngas Plant situated at remote locations and will be transported to site via trucks.
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Ash Disposal:
Ash generated by the combustion process will be removed from the boilers (i.e. bottom ash) and flue
gases (i.e. fly ash) and will be transported via trucks back to the mines from where coal fines are to be
sourced. Here it will be utilised as part of rehabilitation and mine backfilling. The ash can also be used in
the manufacture of concrete, cement clinker, aggregate substitute cement blocks and larger granules of
bottom ash can be used for construction of roads.
Storage and Handling of Hazardous substances:
During the operation phase, the handling and storage of materials will include diesel, water treatment
additives and chemicals. The combined capacity of storage containers will not exceed 80m³.
Limestone:
Limestone will be transported to site via road transport from Pretoria and Vereeniging, and will be
transferred and stored within a silo adjacent to the central plant. The limestone will be transferred via
conveyors to the limestone bunkers in the boiler-house, as required. The limestone consumption is
expected to be 43 800 tonnes per year.
Employment:
The proposed facility will create between 14 and 25 permanent employment positions during operation.
The permanent employment positions will include highly skilled, skilled and semi-skilled positions.
Water requirements:
Approximately 50-70kl of water per day will be required during the operation phase. The water will be
obtained from Astral Foods’ effluent wastewater, as well as through return water from the various off-takers
within the industrial area. Approximately 6000kl per day of wastewater will be stored in holding tanks
onsite. Water will be treated to the required standard for use in the steam generation plant within a waste
water treatment works which will be developed on the site of the Clayville Thermal Plant. Should the
wastewater from Astral not be sufficient at any given time during operation, municipal water will be
utilised. In addition, the applicant will harvest rainfall on the site as much as possible, and treat it via the
wastewater treatment plant before utilising the water within the steam producing process. The
development will utilise heat from the CFB boiler to heat any hot water requirements on-site. Prior to the
operation of the CFB boiler, solar water heating and heat pumps will be utilised.
3.5.3 Decommissioning Phase
The lifespan of the Clayville Thermal Plant will be more than 35 years. Equipment associated with this
facility would only be decommissioned once it has reached the end of its economic life or if it is no longer
required.
Decommissioning activities will involve disassembly of the steam generation units and ancillary
infrastructure, demolishing of buildings and rehabilitation of the site to the desired end-use. As far as
possible, components will be broken down and recycled.
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CHAPTER 4: APPROACH TO UNDERTAKING THE EIA PHASE
In terms of the EIA Regulations of December 2014 (published in terms of the National Environmental
Management Act (NEMA; No. 107 1998), as amended, the construction and operation of the proposed
Clayville Thermal Plant is a listed activity requiring environmental authorisation. This EIA process for the
proposed Clayville Thermal Plant is being undertaken in accordance with the Section 24 (5) of the National
Environmental Management Act (No 107 of 1998). This EIA process aims at assessing the impacts
associated with the proposed project and identifying appropriate mitigation measures for the minimisation
of the impacts. This was achieved through an assessment of the proposed project involving ground-
truthed specialist inputs, as well as a consultation process with the Interested and Affected Parties (I&APs),
the decision making authorities, directly impacted landowners/occupiers, adjacent
landowners/occupiers, relevant organs of state departments, the ward councillor and other key
stakeholders. This chapter serves to outline the process which was followed during the EIA Phase of the EIA
process.
The EIA process culminates in the submission of an EIA Report (including an Environmental Management
Programme (EMPr) to the competent authority for decision-making. The EIA process is illustrated below:
Figure 4.1: The Phases of an EIA Process
4.1. Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended)
This chapter of the final EIA Report includes the following information required in terms of Appendix 3:
Content of Environmental Impact Assessment Reports:
Requirement Relevant Section
3(d)(i) a description of the scope of the proposed
activity, including all listed activities triggered and being
applied for.
The listed activities triggered due to the development of
the Clayville Thermal Plant is included in Section 4.2,
Table 4.1 and Table 4.2.
3(h)(ii) details of the public participation process
undertaken in terms of regulation 41 of the Regulations,
including copies of the supporting documents and
inputs.
The details of the public participation process
undertaken for the Clayville Thermal Plant is included in
Sections 4.3 and 4.4. Evidence of the Public Participation
Process is included in Appendix C.
3(h)(iii) a summary of the issues raised by interested and A summary of the issues raised to date are included in
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Requirement Relevant Section
affected parties, and an indication of the manner in
which the issues were incorporated, or the reasons for not
including them.
Section 4.4.4. A summary of issued raised during the EIA
Report 30-day review period are included in this final EIA
Report as Appendix C – Comments and Responses
Report.
3(h)(vi) the methodology used in determining and
ranking the nature, significance, consequences, extent,
duration and probability of potential environmental
impacts and risks.
The methodology for the assessment of the impacts has
been included in Section 4.4.5.
3(p) a description of any assumptions, uncertainties, and
gaps in knowledge which relate to the assessment and
mitigation measures proposed.
A descriptions of the assumptions and limitation
associated with the assessment of the Clayville Thermal
Plant is included in Section 4.4.6.
4.2. Relevant legislative permitting requirements
The legislative permitting requirements applicable to the Clayville Thermal Plant and associated
infrastructure identified at this stage in the process are identified below.
4.2.1. National Environmental Management Act (No. 107 of 1998) (NEMA)
Listed Activities are activities identified in terms of Section 24 of NEMA which are likely to have a
detrimental effect on the environment, and which may not commence without Environmental
Authorisation (EA) from the competent authority. EA required for Listed Activities is subject to the
completion of an environmental assessment process (either a Basic Assessment (BA) or full Scoping and
Environmental Impact Assessment (S&EIA)).
Error! Reference source not found. contains the Activities identified in terms of the EIA Regulations (i.e. GN
R324, GN R325 and GN R327) which may be triggered by the project, and for which an EA has been
applied through means of an application for EA. The table also includes a description of those project
activities which relate to the applicable Listed Activities.
Table 4.1: Listed activities triggered by the Clayville Thermal Plant
Indicate the number
and date of the
relevant notice:
Activity No (s) (in terms
of the relevant notice) :
Describe each listed activity as per project description
GN 327, 08 December
2014 (as amended on
07 April 2017)
25 The development and related operation of facilities or
infrastructure for the treatment of effluent, wastewater or sewage
with a daily throughout capacity of more than 2 000 cubic metres
but less than15 000 cubic metres.
A water treatment plant associated with the thermal plant will
treat up to 6 000 cubic metres of effluent wastewater per day.
GN 325, 08 December
2014 (as amended on
07 April 2017)
6 The development of facilities or infrastructure for any process or
activity which requires a permit or licence or an amended permit
or licence in terms of the national or provincial legislation
governing the generation or release of emissions, pollution or
effluent.
An Air Emissions Licence is required to be obtained for the
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Indicate the number
and date of the
relevant notice:
Activity No (s) (in terms
of the relevant notice) :
Describe each listed activity as per project description
development of the Clayville Thermal Plant in terms of the NEM:
Air Quality Act.
4.2.2. National Environmental Management: Air Quality Act (No. 39 of 2004) (NEM:AQA)
The List of Activities which Result in Atmospheric Emissions (GNR 893) are activities identified in terms of
Section 21 of the National Environmental Management: Air Quality Act (No. 39 of 2004) (NEM:AQA) which
result in atmospheric emissions and which have or may have a significant detrimental effect on the
environment, including health, social conditions, economic conditions, ecological conditions or cultural
heritage; and which may not commence without an Atmospheric Emission License (AEL).
An applicant wishing to undertake an activity identified in terms of the List of Activities which result in
Atmospheric Emissions (GNR 893) must apply for an Atmospheric Emissions License (AEL) by lodging an
online application with the Atmospheric Emissions Licensing Authority (AELA), in this instance the Ekurhuleni
Metropolitan Municipality). The process of applying for an AEL is required to be supported by an
Atmospheric Impact Report, and will only be completed once the EIA process has been finalised and
Environmental Authorisation (EA) has been obtained for the project.
Table 4.2 contains activities identified in terms of NEM:AQA and the List of Activities which Result in
Atmospheric Emissions (GNR 893) of 22 November 2013 which may be triggered by the proposed project,
and for which an AEL is required. The table also includes a description of those project activities which
relate to the applicable Atmospheric Emission Activities.
Table 4.2: Activities identified in terms of the List of Activities which result in Atmospheric Emissions (GNR
893) published under NEM:AQA on 22 November 2013.
Notice No. Activity No : Description of Atmospheric Emission Activity:
GNR 893
22
November
2013
Category 1
Combustion
Installations
Subcategory 1.1:
Solid Fuel
Combustion
Installations
Description: Solid fuels combustion installations used primarily for steam
raising or electricity generation.
Application:
All installations with design capacity equal to or greater than
50MW heat input per unit, based on the lower calorific value
of the fuel used.
Substance or mixture of
substances Plant
Status
mg/Nm³ under normal
conditions of 10% O2, 273
Kelvin and 101.3 kPa. Common
Name
Chemical
Symbol
Particulate
Matter N/A
New 50
Existing 100
Sulphur
dioxide SO2
New 500
Existing 3500
Oxides of
nitrogen
NOX expressed
as NO2
New 750
Existing 1100
The operation of the proposed project will burn coal fines, a solid fuel in a
combustion process to generate steam.
GNR 893 Category 1 Description: Gas combustion (including gas turbines burning natural gas)
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Notice No. Activity No : Description of Atmospheric Emission Activity:
22
November
2013
Combustion
Installations
Subcategory 1.4:
Gas Combustion
Installations
used primarily for steam raising or electricity generation.
Application:
All installations with design capacity equal to or greater than
50MW heat input per unit, based on the lower calorific value
of the fuel used.
Substance or mixture of
substances Plant
Status
mg/Nm³ under normal
conditions of 10% O2, 273
Kelvin and 101.3 kPa. Common
Name
Chemical
Symbol
Particulate
Matter N/A
New 10
Existing 10
Sulphur
dioxide SO2
New 400
Existing 500
Oxides of
nitrogen
NOX expressed
as NO2
New 50
Existing 300
The operation of the proposed project will use gas as a feedstock in a
combustion process to generate steam.
4.2.3. EIA Regulations, 2014 as amended (GNR326)
On the basis of the above listed activities, a Scoping and EIA Process has been undertaken for the Clayville
Thermal Plant. This process comprised two phases as follows:
» The Scoping Phase included the identification of potential issues associated with the project through a
desktop study and consultation with interested and affected parties and key stakeholders. Areas of
sensitivity within the project site were identified and delineated in order to identify any environmental
fatal flaws, and sensitive or no go areas. Following a 30-day review period of the draft report, this
phase culminated in the submission of a final Scoping Report and Plan of Study for EIA to the GDARD.
Acceptance of the Scoping Report was received in December 2017.
» The EIA Phase involves a detailed assessment and ground-thruthing of potentially significant positive
and negative impacts (direct, indirect, and cumulative) identified in the Scoping Phase. This phase
includes detailed specialist investigations and public consultation. Following the review period of the
draft report, this phase culminates in the submission of a final EIA Report and an Environmental
Management Programme (EMPr), including recommendations of practical and achievable mitigation
and management measures, to the GDARD for review and decision-making.
4.3. Scoping Phase
A Scoping Study was undertaken in accordance with the requirements of the EIA Regulations. The
Scoping Study provided I&APs with the opportunity to receive information regarding the project,
participate in the process, and submit comments on the Scoping Report. The Scoping Report detailed the
nature and extent of the project, identifying potential issues associated with the Thermal Plant, and
defined the extent of studies required within the EIA Phase. This was achieved through an evaluation of
the project, involving the project proponent, review of existing information, and a consultation process
with key stakeholders that included both relevant government authorities and I&APs.
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A Scoping Report was released for review from 26 September 2017 – 26 October 2017 for a 30-day
comment period. Following the review period, a final Scoping Report was submitted to GDARD in
November 2017. This together with the Plan of Study for the EIA was accepted by the GDARD, as the
competent authority, in December 2017. In terms of this acceptance, an EIA is required to be undertaken
for the Clayville Thermal Plant.
Following this, the applicant consulted with the National Energy Regulator of South Africa (NERSA) in order
to confirm compliance of the proposed project with relevant legislation and to confirm the feedstock type
and source. Confirmation in this regard was received in March 2018. The EIA project schedule was
therefore delayed, and the applicant and specialist consulting team were not in a position to provide the
Competent Authority with all the information requested within the prescribed timeframes. Subsequently,
the applicant requested that the file be closed on 18 May 2018. In terms of Regulation 21(2) of the EIA
Regulations of 2014 (as amended), the findings of the scoping report remain valid and the environmental
context has not changed. Therefore, the EIA process is proceeding from the EIA Phase following the
submission of a new application form.
4.4. EIA Phase
The EIA Phase aims to achieve the following:
» Provide a comprehensive assessment of the social and biophysical environments affected by the
Clayville Thermal Plant.
» Assess potentially significant impacts (direct, indirect, and cumulative, where required) associated with
the project.
» Comparatively assess any feasible alternatives put forward as part of the project.
» Identify and recommend appropriate mitigation measures for potentially significant environmental
impacts which cannot be avoided.
» Undertake a fully inclusive public participation process to ensure that I&APs are afforded the
opportunity to participate, and that their comments are recorded.
This final EIA Report assesses potential direct, indirect, and cumulative impacts (both positive and
negative) associated with all phases of the project including design, construction, operation and
decommissioning. In this regard this final EIA Report aims to provide the relevant authorities with sufficient
information to make an informed decision regarding the Clayville Thermal Plant.
4.4.1. Tasks completed during the EIA Phase
The EIA Phase for the Clayville Thermal Plant has been undertaken in accordance with the EIA Regulations,
2014, as amended in April 2017, in terms of NEMA. Key tasks undertaken within the EIA phase included:
» Consultation with relevant decision-making and regulating authorities (at National, Provincial and
Local levels).
» Undertaking of independent specialist studies in accordance with Appendix 6 of Government Notice
R326 of the EIA Regulations, 2014, as amended.
» Preparation of an EIA Report in accordance with Appendix 3 of Government Notice R326 of the EIA
Regulations, 2014, as amended.
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» Undertaking a public participation process throughout the EIA process in accordance with Chapter 6
of Government Notice R326 of the EIA Regulations, 2014 (as amended) in order to record comments
associated with the Clayville Thermal Plant.
» Preparation of a Comments and Response Report including all comments received from I&APs and
Organs of State as part of the EIA Process.
These tasks are discussed in detail below.
4.4.2. Authority Consultation
As the project is located in the Gauteng Province, the competent authority responsible for the decision
making regarding the authorisation of the project is the provincial department, the Gauteng Department
of Agriculture and Rural Development (GDARD). Consultation with the relevant authority has been
undertaken throughout the Scoping process. Authority consultation has included the following:
» Pre-application consultation meeting held on 29 August 2017.
» Submission of the application for authorisation to GDARD;
» Submission of the Scoping Report for review by the competent and commenting authority from 26
September 2017 – 26 October 2017.
» Submission of the final Scoping Report for the Clayville Thermal Plant submitted in November 2017 to
GDARD and accepted in December 2017.
» Consultation with GDARD throughout the EIA process.
» Consultation with the AEL Authority, the City of Ekurhuleni Metropolitan Municipality, on 17 November
2017.
» Consultation with the AEL Authority, the City of Ekurhuleni Metropolitan Municipality, on 12 February
2018.
» Submission of new application to GDARD following lapsing of previous process.
» The EIA Report were made available to the GDARD for a 30-day review period from 26 June 2018 to 26
July 2018.
The following have also been undertaken as part of this EIA Phase:
» Notification and consultation with Organs of State (refer to Table 4.3) that may have jurisdiction over
the project, including:
Provincial Departments;
Parastatals and Non-Governmental Organisations;
The City Ekurhuleni Metropolitan Municipality.
» Submission of a final EIA Report to GDARD following the 30-day public review period of the EIA Report
and the receipt of the comments from the GDARD on the Report. This final EIA Report include all
comments and issues raised by I&APs and the responses of the EAP and the project development
team.
» If required, an opportunity for GDARD representatives to visit and inspect the proposed project site.
A record of all authority consultation in the EIA and AEL processes is included within Appendix C.
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4.4.3. Public Participation Process
The aim of the public participation process is primarily to ensure that:
» Information containing all relevant facts in respect of the project is made available to potential
stakeholders and I&APs.
» Participation by potential I&APs is facilitated in such a manner that all potential stakeholders and I&APs
are provided with a reasonable opportunity to comment on the project.
» Comments received from stakeholders and I&APs are recorded and incorporated into the EIA process.
In order to accommodate the varying needs of stakeholders and I&APs within the study area, as well as
capture their comments regarding the development of the Clayville Thermal Plant, various opportunities
for stakeholders and I&APs to be involved in the EIA Phase of the process have been provided, as follows:
» Opportunity for review of the EIA Report for a 30-day period from 26 June 2018 – 26 July 2018.
Comments received from I&APs during this period have been captured within a Comments and
Response Report, which are included within this Final EIA Report, for submission to the GDARD for
decision-making.
» Focus Group Meetings: Focus group meetings were held with the City of Ekurhuleni, and key
representatives including the Greater Midstream Forum and Olifantsfontein Business Forum in July 2018.
The purpose of these focus group meetings was to present the findings of the EIA Report, to facilitate
and record comments on the EIA Report. The minutes of these meetings are included in this final EIA
Report submitted to the GDARD.
» Telephonic Consultation Sessions: Telephonic consultation will be held with I&APs, including Organs of
State Departments and key stakeholders to capture issues, comments and concerns regarding the
project and to follow-up on the submission of comments on the EIA Report.
» Written, faxed or e-mail correspondence.
In compliance with the requirements of Chapter 6 of the EIA Regulations, 2014, the following summarises
the key public participation activities conducted to date (also see Table 4.4).
(i) Placement of Site Notices
Placement of site notices announcing the EIA process at visible points along the boundary of the project
site on 05 September 2017, in accordance with the requirements of the EIA Regulations. Photographs and
the GPS coordinates of the site notices are contained in Appendix C2.
(ii) Identification of I&APs and establishment of a database
Identification of I&APs was undertaken by Savannah Environmental through existing contacts and
databases, recording responses to site notices and newspaper advertisements, as well as through the
process of networking from the commencement of the EIA process. The key stakeholder groups identified
include authorities, the metropolitan municipality, organs of state departments, state-owned companies
and non-governmental organisations (refer to Table 4.3 below).
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Table 4.3: Summary of Stakeholders identified for inclusion in the project database during the Public
Participation Process of the Clayville Thermal Plant EIA Process
Organs of State
National Government Departments
Department of Agriculture, Forestry and Fisheries (DAFF)
Department of Rural Development and Land Reform (DRDLR)
Department of Water and Sanitation (DWS)
Government Bodies and State Owned Companies
Sentech
South African Civil Aviation Authority (CAA)
South African Heritage Resources Agency (SAHRA)
South African National Roads Agency Limited (SANRAL)
Telkom SA Ltd
Transnet
Provincial Government Departments
Gauteng Department of Agriculture and Rural Development (GDARD)
- Sustainable Use of Environment Directorate
- Climate Change and Information Management Directorate
- Agriculture Department
Gauteng Department of Roads and Transport
Provincial Heritage Resources Authority Gauteng (PHRAG)
Local Government Departments
Ekurhuleni Metropolitan Municipality
Landowners
Olifantsfontein Business Forum
Affected landowners and tenants
Neighbouring landowners and tenants
As per Regulation 42 of the EIA Regulations of 2014 (as amended) all relevant stakeholder and I&AP
information has been recorded within a register of I&APs (refer to Appendix C for a listing of recorded
parties). While I&APs were encouraged to register their interest in the EIA process from the onset, the
identification and registration of I&APs has been on-going for the duration of the EIA process.
(iii) Advertisements and Notifications
» Placement of advertisements announcing the EIA process for the project and inviting members of the
public to register themselves as I&APs on the project database and announcing the availability of and
inviting comment on the Scoping Report were placed in the Midrand Reporter on 22 September 2017,
at the commencement of the 30-day review period (refer to Appendix C2).
» Compilation of a background information document (BID) for the project in order to provide
information regarding the Clayville Thermal Plant project and the EIA process (refer to Appendix C3).
The BID has been distributed to identified stakeholders and I&APs.
» Distribution of an EIA process notification letter regarding the Clayville Thermal Plant project and of the
availability of the Scoping Report for review, together with stakeholder reply forms. This letter was
distributed to organs of state, potentially affected and neighbouring landowners as well as registered
stakeholders/I&APs via email and registered post on 26 September 2017. I&APs have been
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encouraged to view the Scoping Report and submit written comment thereon. Proof of distribution is
contained in Appendix C5.
» Distribution of CD and hard copy versions of the Scoping Report to Organs of State via courier at the
commencement of the review period. The evidence of distribution of the Scoping Report have been
included in Appendix C.
» A letter notifying I&APs of the lapsing of the file which was distributed on 20 May 2018 via email. The
evidence of this distribution is included in Appendix C4 and Appendix C5.
» An advertisement announcing the re-commencement of the EIA process (including new EIA
Reference Number) and the availability of the EIA Report and inviting comment was placed in the
Midrand Reporter on 28 June 2018. The tear sheet of the newspaper advert is included in Appendix C2
of this final EIA Report, once received from the newspaper.
» Letters notifying registered I&APs of the re-commencement of the EIA process (including new EIA
Reference Number) and the availability of the Clayville Thermal Plant EIA Report for review were
distributed to registered I&APs via email on 26 June 2018 and registered post on the onset of the review
period.
» Copies of the EIA Report were couriered to Organs of State Departments at the onset of the review
period.
» A hard copy of the EIA Report was placed at the Olifantsfontein Library (c/o Pearce & Mason Avenue,
Olifantsfontein, Kempton Park) and at the Winnie Mandela Library (Margaret Zyma Street, Tembisa) for
members of the public to view. The evidence of the distribution of the EIA Report is contained in
Appendices C4 and C5.
(iv) Public Involvement and Consultation
In order to accommodate the varying needs of stakeholders and I&APs, the following opportunities have
been provided for I&AP issues to be recorded and considered through the EIA process as outlined in Table
4.4 below:
Table 4.4: Consultation undertaken with I&APs in the Clayville Thermal Plant EIA Process
Scoping
Phase
Activity Date
Presentation to the Olifantsfontein Business Forum 03 August 2017
The EIA process was advertised in the Midrand Reporter newspaper. 22 September 2017
Placement of site notices, on-site and in public places. 05 September 2017
Distribution of process notification letters (including notification of the
availability of the Scoping Report) and background information
documents to organs of state departments, ward councillors,
landowners within the study area, neighbouring landowners and
stakeholder groups.
26 September 2017
Distribution of the Scoping Report and notification letters inviting
comment on the report via courier to organ of state departments.
26 September 2017
Review period for the Scoping Report for public comment. 26 September 2017 – 26
October 2017
Focus Group Meetings:
» Key stakeholders focus group meeting
» Ward Councillor of Ward 1 of the Ekurhuleni Metropolitan
Municipality
17 October 2017
EIA Phase Distribution of letters announcing the re-commencement of the EIA
process (including new EIA Reference Number) and the availability of
26 June 2018
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the EIA Report for review for a 30-day comment period and the dates
and venues of the Public Meetings. These letters have been distributed
to organs of state departments, ward councillors, landowners within the
study area, neighbouring landowners and key stakeholder groups.
The re-commencement of the EIA process (including new EIA
Reference Number) and the availability of the EIA Report has been
advertised in the Midrand Reporter newspaper.
28 June 2018
30-day review period of the EIA Report for public comment. 26 June 2018 – 26 July
2018
Public Participation meetings to be held during the 30-day comment
period:
Focus Group Meetings:
» City of Ekurhuleni;
» Greater Midstream Forum;
» Olifantsfontein Business Forum
26 June 2018 – 26 July
2018
Records of all consultation undertaken are included in Appendix C.
4.4.4. Identification and Recording of Issues and Concerns
Issues and comments raised by I&APs over the duration of the EIA process have been synthesised into a
Comments and Responses Report and summarised in Table 4.5 below. The Comments and Responses
Report includes detailed responses from members of the EIA project team and the applicant. This is
included in Appendix C.
Table 4.5: Summary of issues raised through the Public Participation Process
Issue Raised By: Summary of main issues raised by
I&APs
Summary of response from EAP
Paul Claassen
Greater
Midstream
Forum
Any project or any project extension
needs to be considered within the
context of the relevant policy and the
successful implementation thereof by
the authorities.
The assessment of the proposed project will consider
relevant policy and legislation. An Air Emissions
License (AEL) will be required for the project,
application for which will be submitted to the
Ekurhuleni Metropolitan Municipality after the EIA
process has been concluded.
Paul Claassen
Greater
Midstream
Will a Water Use License be required for
this project?
According to the activities being triggered, a Water
Use License is not required for this project as the
amount of water to be stored on site is below the
threshold.
Paul Claassen
Greater
Midstream
Forum
There are many problems relating to
sinkholes in this area.
The EMPr submitted as part of the final EIA Report
recommends that a Geotechnical Assessment be
undertaken before the project commences (Section
4, Objective 1). According to the comments received
from the City of Ekurhuleni Municipality dated 27 July
2018, the project site has geotechnical development
constraints with a low sensitivity rating.
Paul Claassen
Greater
Midstream
Forum
Mercury is a constituent of coal, but in
trace amounts. It was not considered
in the Air Quality Impact Assessment
because a relatively small amount of
It is noted that mercury has in earlier years been a
significant concern in the area and communities.
Although Mercury is a component of coal, it is in trace
amounts. It was not considered in the Air Quality
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Issue Raised By: Summary of main issues raised by
I&APs
Summary of response from EAP
coal will be used initially, and then the
plant will be operated using Syngas or
natural gas.
Impact Assessment as a relatively small amount of
coal will be used. If mercury is to be assessed, there is
no regulatory emission requirements for mercury to
measure the results against and therefore no
conclusion could be drawn regarding the
acceptability of any impact. Without a standard to
measure Mercury against, there is no way to assess
compliance. The ambient mercury concentration is
unknown, which makes it very difficult to assess
impacts.
Paul Claassen
Greater
Midstream
Forum
No positive impacts in terms of
reduction of individual boilers can be
assumed in the EIA Report without
stipulating at the very least what boilers
and to what extent air pollution will be
reduced.
The positive impacts associated with the
decommissioning of other current air polluting
activities were not included as no commitment from
emitters have been obtained at this stage in the
process. The Air Quality Impact Assessment has
however assessed the “worst case scenario” where no
polluting activities will be decommissioned, and the
risk associated with the proposed development from
an air quality and human health risk perspective is
considered to be of low significance and acceptable.
Should some polluting activities be decommissioned
due to the operation of the Clayville Thermal Plant,
there will be a reduction of different emission sources
from the various boilers within the area and emissions
will be concentrated to one source. The commitment
from the individual off-takers to decommission their
small boilers on-site will form part of the contractual
agreement.
Paul Claassen
Greater
Midstream
Forum
The time period for the use of coal fines
as the initial fuel is not specified or
committed to.
Coal fines will be used to initiate the project. The
applicant cannot commit to timelines for the use of
syngas or natural gas due to current market prices
which are considered to be economically unfeasible.
The central plant can use gas in the project's next
stage if Sasol’s gas price reduces or an alternative
affordable gas source becomes available. The
recommendation in the EIA (section 8.7) is that the
plant be designed to ultimately cater for the use of
syngas and natural gas as a fuel source.
Barend Deminey
Divisional Head:
Functional
Planning
Roads and
Stormwater
Department
City of Ekurhuleni
Municipality
The department requires that provision
should be made for a deceleration
lane on the north-bound approach
along Industry Road into the proposed
development, given that the proposed
ingress throat length only caters for one
interlink.
The applicant takes note of the Department’s
requirement to make provision for a deceleration
lane. The traffic specialist has recommended that a
deceleration lane should be constructed on Industry
Road to accommodate left-turn vehicles entering the
development, or introduce a second entry lane at the
site access on Industry Road (refer to Traffic Impact
Assessment (refer to Appendix F) and EMPr).
Alternatively, additional access to the site can be
obtained via Spanner Road, to improve on-site
manoeuvrability, to reduce right-turn exit movements
at the development access and to reduce traffic
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Issue Raised By: Summary of main issues raised by
I&APs
Summary of response from EAP
impact on Industry Road.
JA Zeederberg
Chairperson
& Mr P Claassen
Great Midstream
Forum
The proposed activity may contribute
to deteriorating ambient air quality
(cumulative impact) in the area. It
may also release gaseous emissions or
vapours (even at low concentrations).
As detailed in the Scoping Report, impacts on air
quality during the construction phase will relate to
dust pollution. The significance of this impact is
expected to be low as low-level sources generally
impact close to the source. The impact can be
mitigated through optimisation of dust control
measures which will be included in the Environmental
Management Programme during the EIA phase.
Emissions of gaseous pollutants and particulates from
the stack as a result of operational activities has been
considered. The significance of the potential impact
is expected to be low as elevated stack emissions
generally disperse effectively resulting in low ground-
level concentrations. The impact can be mitigated
through optimisation of emission abatement. The
significance of the impacts will be confirmed during
the EIA Phase when air dispersion modelling will be
undertaken to predict ambient concentrations of air
pollutants.
JA Zeederberg
Chairperson
& Mr P Claassen
Great Midstream
Forum
The Regional Spatial Development
Framework of the Ekurhuleni
Metropolitan Municipality, 2015,
earmarked the areas directly to the
north and west of the
Olifantsfontein/Clayville industrial areas
as Urban Development zones that
excludes industrial development as a
land use. The general area is further
earmarked for infill and urban
densification with several high density
social housing projects in the
immediate vicinity of the
Olifantsfontein/ Clayville industrial area.
The industrial growth direction
indicated in the RSDF is towards the
south-south-east in the general
direction of the OR Tambo International
Airport and in line with the Aerotropolis
initiative of the Ekurhuleni Metropolitan
Municipality.
As per the Regional Spatial Development Framework
of the Ekurhuleni Metropolitan Municipality, 2015, the
Clayville Industrial Area falls within Region B. Although
it is the vision of the municipality that this area will be
subject to major urban growth due to the proximity to
the airport and its expected growth as an
aerotropolis, the Framework recognises the
Olifantsfontein area as a focus area for industrial
development. Furthermore, the Gauteng Provincial
Environmental Management Framework of 2014
provides a strategic and overall framework for
environmental management in Gauteng while
aligning sustainable development initiatives with the
environmental resources, developmental pressures, as
well as the growth imperatives of Gauteng. The
GPEMF has divided the Gauteng Province into five
Environmental Management Zones (EMZs). The
purpose of these zones is to identify specific planning
and policy measures associated with a specific zone
to achieve the development objectives of the zone.
The Clayville Thermal Plant falls within Zone 5 which is
the industrial and commercial development focus
zone indicating that the area is earmarked for the
development of industrial industries. It can therefore
be expected that various industrial developments will
take place in addition to the already industrial nature
of the area.
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4.4.5. Assessment of Issues Identified through the Scoping Process
As detailed in the accepted Plan of Study for EIA, the following issues were identified through the Scoping
Study as not requiring further investigation within the EIA, and no further or detailed assessment is required:
» Impacts on palaeontology – due to the lack of fossil heritage within the project site and the low
significance of the impact on the palaeontological resources, no further Palaeontological Impact
Assessment is required for the EIA Phase.
» Impacts on the social environment – the majority of impacts are expected to be localised and
restricted to the site. Positive impacts associated with employment creation and skills development will
be managed through appropriate recruitment mechanisms. Only potential impacts associated with
increased traffic are required to be further investigated within the EIA Phase of the process.
Issues which require investigation within the EIA Phase as identified through the Scoping Study, as well as
the specialists involved in the assessment of these impacts are indicated in Table 4.6 below.
Table 4.6: Specialist studies required for the Clayville Thermal Plant project
Specialist Study Specialist Refer Appendix
Air Quality Mark Zunckel of uMoya-NILU Appendix D
Heritage Jaco van der Walt of Heritage Contracts and
Archaeological Assessments (HCAC)
Appendix E
Traffic Stephen Fautley of Techso Appendix F
Specialist studies considered direct and indirect environmental impacts associated with the development
of all components of the Clayville Thermal Plant. Issues were assessed in terms of the following criteria:
» The nature, a description of what causes the effect, what will be affected, and how it will be affected.
» The extent, wherein it is indicated whether the impact will be local (limited to the immediate area or
site of development), regional, national or international. A score of between 1 and 5 is assigned as
appropriate (with a score of 1 being low and a score of 5 being high).
» The duration, wherein it is indicated whether:
The lifetime of the impact will be of a very short duration (0–1 years) – assigned a score of 1;
The lifetime of the impact will be of a short duration (2-5 years) - assigned a score of 2;
Medium-term (5–15 years) – assigned a score of 3;
Long term (> 15 years) - assigned a score of 4;
Permanent - assigned a score of 5.
» The magnitude, quantified on a scale from 0-10, where a score is assigned:
0 is small and will have no effect on the environment;
2 is minor and will not result in an impact on processes;
4 is low and will cause a slight impact on processes;
6 is moderate and will result in processes continuing but in a modified way;
8 is high (processes are altered to the extent that they temporarily cease);
10 is very high and results in complete destruction of patterns and permanent cessation of
processes.
» The probability of occurrence, which describes the likelihood of the impact actually occurring.
Probability is estimated on a scale, and a score assigned:
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Assigned a score of 1–5, where 1 is very improbable (probably will not happen);
Assigned a score of 2 is improbable (some possibility, but low likelihood);
Assigned a score of 3 is probable (distinct possibility);
Assigned a score of 4 is highly probable (most likely);
Assigned a score of 5 is definite (impact will occur regardless of any prevention measures).
» The significance, which is determined through a synthesis of the characteristics described above (refer
formula below) and can be assessed as low, medium or high.
» The status, which is described as either positive, negative or neutral.
» The degree to which the impact can be reversed.
» The degree to which the impact may cause irreplaceable loss of resources.
» The degree to which the impact can be mitigated.
The significance is determined by combining the criteria in the following formula:
S = (E+D+M) P; where
S = Significance weighting
E = Extent
D = Duration
M = Magnitude
P = Probability
The significance weightings for each potential impact are as follows:
» < 30 points: Low (i.e. where this impact would not have a direct influence on the decision to develop in
the area);
» 30-60 points: Medium (i.e. where the impact could influence the decision to develop in the area unless
it is effectively mitigated);
» > 60 points: High (i.e. where the impact must have an influence on the decision process to develop in
the area).
As per the requirements of the EIA Regulations, specialist studies are required to assess the cumulative
impacts. The role of the cumulative assessment is to test if such impacts are relevant to the project in the
proposed location (i.e. whether the addition of the project in the area will increase the impact). This
section should address whether the construction of the Clayville Thermal Plant together with all the projects
proposed or existing in the area will result in:
» Unacceptable risk;
» Unacceptable loss;
» Complete or whole-scale changes to the environment or sense of place; and
» Unacceptable increase in impact.
As the developer has the responsibility to avoid or minimise impacts and plan for their management (in
terms of the EIA Regulations), the mitigation of significant impacts are required to be recommended.
Assessment of impacts with mitigation is made in order to demonstrate the effectiveness of the proposed
mitigation measures. An Environmental Management Programme (EMPr) is included as Appendix H.
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4.4.6. Assumptions and Limitations
The following assumptions and limitations are applicable to the studies undertaken within this EIA Phase:
» All information provided by the developer and I&APs to the environmental team was correct and valid
at the time it was provided.
» It is assumed that the development site identified by the developer represents a technically suitable
site for the establishment of Clayville Thermal Plant.
» Studies assume that any potential impacts on the environment associated with the Clayville Thermal
Plant will be avoided, mitigated, or offset.
» This report and its investigations are project-specific, and consequently the environmental team did
not evaluate any other technology alternatives.
Refer to the specialist studies in Appendices D – F for specialist study specific limitations.
4.5. Legislation and Guidelines that have informed the preparation of this Environmental Impact
Assessment Report
The following legislation and guidelines have informed the scope and content of this final EIA report:
» National Environmental Management Act (Act No. 107 of 1998);
» EIA Regulations of December 2014, published under Chapter 5 of NEMA (as amended in GNR R326 in
Government Gazette No 40772 of April 2017);
» International guidelines – the Equator Principles and the International Finance Corporation and World
Bank Guidelines.
Several other Acts, standards or guidelines have also informed the project process and the scope of issues
evaluated in this EIA report. A listing of relevant environmental legislation, as well as the compliance
requirements applicable to the Clayville Thermal Plant in terms of this legislation is provided in Table 4.7.
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Table 4.7: Review of the relevant environmental policies, legislation, guidelines and standards applicable to the Clayville Thermal Plant
Legislation Applicable Sections Relevant Authority Compliance Requirements
National Legislation
Constitution of the Republic of
South Africa (Act No 108 of 1996)
» Bill of Rights (S2)
» Environmental Rights (S24) – i.e. the right to an
environment which is not harmful to health and well-
being
» Rights to freedom of movement and residence (S22)
» Property rights (S25)
» Access to information (S32)
» Right to just administrative action (S33)
» Recognition of international agreements (S231)
Applicable to all
authorities
There are no permitting requirements associated
with this Act.
The application of the Environmental Right
however implies that environmental impacts
associated with proposed developments are
considered separately and cumulatively. It is
also important to note that the “right to an
environment clause” includes the notion that
justifiable economic and social development
should be promoted, through the use of natural
resources and ecologically sustainable
development.
National Environmental
Management Act (Act No 107 of
1998)
» National environmental principles (S2), providing
strategic environmental management goals and
objectives of the government applicable throughout
the Republic to the actions of all organs of state that
may significantly affect the environment
» NEMA EIA Regulations (GN 324 – 327 of December
2014, as amended in April 2017)
» The requirement for potential impact on the
environment of listed activities must be considered,
investigated, assessed and reported on to the
competent authority (S24 – Environmental
Authorisations)
» Duty of Care (S28) requiring that reasonable measures
are taken to prevent pollution or degradation from
occurring, continuing or recurring, or, where this is not
possible, to minimise & rectify pollution or degradation
of the environment
Gauteng Department
of Agriculture and
Rural Development
(GDARD)
In terms of the EIA Regulations, 2014 (as
amended) - GN R325, GN R326 and GN R327 - a
scoping and EIA process is required to be
undertaken for the development of the Clayville
Thermal Plant. The Scoping report was
accepted by GDARD in December 2017. This EIA
Report will be submitted to the competent
authority in support of the application for
authorisation.
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Legislation Applicable Sections Relevant Authority Compliance Requirements
» Procedures to be followed in the event of an
emergency incident which may impact on the
environment (S30)
» Appeals against decisions made by authorities (S43)
National Environmental
Management Act (Act No 107 of
1998)
» In terms of the Duty of Care provision in S28(1) the
project proponent must ensure that reasonable
measures are taken throughout the life cycle of this
project to ensure that any pollution or degradation of
the environment associated with this project is
avoided, stopped or minimised.
» In terms of NEMA, it has become the legal duty of a
project proponent to consider a project holistically,
and to consider the cumulative effect of a variety of
impacts.
National Department
of Environmental Affairs
(as the regulator of
NEMA).
While no permitting or licensing requirements
arise directly, this section finds application during
the EIA phase and will continue to apply
throughout the life cycle of the project.
Environment Conservation Act
(Act No 73 of 1989)
» National Noise Control Regulations (GN R154 dated 10
January 1992)
Ekurhuleni Metropolitan
Municipality
Noise impacts are expected to be associated
with the construction and operation phases of
the project and are not likely to present a
significant intrusion to the local community.
There is therefore no requirement for a noise
permit in terms of the legislation.
National Heritage Resources Act
(Act No 25 of 1999)
» Stipulates assessment criteria and categories of
heritage resources according to their significance (S7)
» Provides for the protection of all archaeological and
palaeontological sites, and meteorites (S35)
» Provides for the conservation and care of cemeteries
and graves by SAHRA where this is not the
responsibility of any other authority (S36)
» Lists activities which require developers any person
who intends to undertake to notify the responsible
heritage resources authority and furnish it with details
regarding the location, nature and extent of the
proposed development (S38)
» South African
Heritage
Resources Agency
(SAHRA)
» Provincial Heritage
Resources
Authority Gauteng
(PHRAG)
An Archaeological Impact Assessment
(Appendix E) has been undertaken and
concluded that the development of the
Clayville Thermal Plant will have an impact of
low significance on archaeological heritage
resources.
In terms of Section 35 of the NHRA no significant
archaeological sites were identified. No further
mitigation prior to construction is recommended
in terms of Section 35 of the NHRA for the
proposed development to proceed.
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Legislation Applicable Sections Relevant Authority Compliance Requirements
» Requires the compilation of a Conservation
Management Plan as well as a permit from SAHRA for
the presentation of archaeological sites as part of
tourism attraction (S44)
In terms of the built environment of the area
(Section 34 of the NHRA) no standing structures
older than 60 years occur within the study area.
In terms of Section 36 of the NHRA no burial sites
were recorded.
The project site is located in an industrial area
away from main tourist routes and the Clayville
Thermal Plant will not impact negatively on
significant heritage viewscapes.
A Palaeontological Scoping Study was
undertaken as part of the Scoping Phase. The
study concluded that due to the lack of fossil
heritage within the project site and the low
significance of the impact on the
palaeontological resources no further study is
required. Therefore, the findings of the
Palaeontological Assessment (Appendix E of the
Scoping Report) are considered to be sufficient
and no further Environmental Palaeontological
Impact Assessment is required for the EIA Phase.
National Environmental
Management: Biodiversity Act
(Act No 10 of 2004)
» Provides for the MEC/Minister to identify any process or
activity in such a listed ecosystem as a threatening
process (S53)
» A list of threatened and protected species has been
published in terms of S 56(1) - Government Gazette
29657.
» Three government notices have been published, i.e.
GN R 150 (Commencement of Threatened and
Protected Species Regulations, 2007), GN R 151 (Lists of
Gauteng Department
of Agriculture and
Rural Development
(GDARD)
Through the undertaking of the Ecological Study
(Appendix G of the Scoping Report), which
included the undertaking of a field survey no
species of conservation concern in terms of
NEMBA were identified. Due to the natural
indigenous vegetation within the project site
being severely limited and due to the fact that
this area is so isolated, unstable and small in size,
no Environmental Ecological Impact Assessment
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Legislation Applicable Sections Relevant Authority Compliance Requirements
critically endangered, vulnerable and protected
species) and GN R 152 (Threatened or Protected
Species Regulations).
» Provides for listing threatened or protected
ecosystems, in one of four categories: critically
endangered (CR), endangered (EN), vulnerable (VU)
or protected. The first national list of threatened
terrestrial ecosystems has been gazetted, together
with supporting information on the listing process
including the purpose and rationale for listing
ecosystems, the criteria used to identify listed
ecosystems, the implications of listing ecosystems, and
summary statistics and national maps of listed
ecosystems (National Environmental Management:
Biodiversity Act: National list of ecosystems that are
threatened and in need of protection, (G 34809, GN
1002), 9 December 2011).
» This Act also regulates alien and invader species (GN
37885).
is required for the EIA Phase.
National Environmental
Management: Air Quality Act
(Act No 39 of 2004)
» S18, S19 and S20 of the Act allow certain areas to be
declared and managed as “priority areas”.
» Declaration of controlled emitters (Part 3 of Act) and
controlled fuels (Part 4 of Act) with relevant emission
standards.
» The Act provides that an air quality officer may require
any person to submit an atmospheric impact report if
there is reasonable suspicion that the person has failed
to comply with the Act.
» Dust control regulations promulgated in November
2013 may require the implementation of a dust
management plan.
» Government Gazette 33064 of 31 March 2010 provides
Ekurhuleni Metropolitan
Municipality
An Air Emissions License is required to be
obtained from the Metropolitan Municipality for
the Clayville Thermal Plant in terms of the NEM:
Air Quality Act.
Solid fuel combustion installations using solid fuel
for steam generation is Listed Activity (Category
1: Sub-category 1.1) and gas combustion
installations using gas for steam generation is
Listed Activity (Category 1: Subcategory 1.4) in
term of Section 21 of NEM:AQA.
Therefore an AEL must be obtained for the
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Legislation Applicable Sections Relevant Authority Compliance Requirements
a list of activities which require an Air Emissions License
and provides the thresholds that need to be complied
with
project.
Conservation of Agricultural
Resources Act (Act No 43 of
1983)
» Prohibition of the spreading of weeds (S5)
» Classification of categories of weeds & invader plants
(Regulation 15 of GN R1048) & restrictions in terms of
where these species may occur.
» Requirement & methods to implement control
measures for alien and invasive plant species
(Regulation 15E of GN R1048).
Department of
Agriculture, Forestry
and Fisheries (DAFF).
The project site is in a disturbed and transformed
state, with most of the vegetative species
comprising of weeds (i.e. Argemone
ochroleuca), pioneers and Invasive Alien Plants
(IAPs)
Measures for the control of invasive vegetation
has been included in the EMPr which is provided
in Appendix H.
National Water Act (Act No 36 of
1998)
» Under S21 of the Act, water uses must be licensed
unless such water use falls into one of the categories
listed in S22 of the Act or falls under the general
authorisation.
» In terms of S19, the project proponent must ensure that
reasonable measures are taken throughout the life
cycle of the project to prevent and remedy the
effects of pollution to water resources from occurring,
continuing, or recurring.
» National Government is the public trustee of the
Nation’s water resources (S3)
» Entitlement to use water (S4) – entitles a person to use
water in or from a water resource for purposes such as
reasonable domestic use, domestic gardening, animal
watering, fire-fighting and recreational use, as set out
in Schedule 1
» Duty of Care to prevent and remedy the effects of
pollution to water resources (S19)
» Procedures to be followed in the event of an
emergency incident which may impact on a water
Department of Water
and Sanitation (DWS)
The development of the Clayville Thermal Plant
will not require a Water Use License or General
Authorisation in terms of the National Water Act
(Act No 36 of 1998) as no water uses will be
triggered.
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Legislation Applicable Sections Relevant Authority Compliance Requirements
resource (S20)
» Definition of water use (S21)
» Requirements for registration of water use (S26 and
S34)
» Definition of offences in terms of the Act (S151)
National Environmental
Management: Waste Act (Act
No 59 of 2008)
The Minister may by notice in the Gazette publish a list of
waste management activities that have, or are likely to
have, a detrimental effect on the environment.
The Minister may amend the list by –
» Adding other waste management activities to the list.
» Removing waste management activities from the list.
» Making other changes to the particulars on the list.
In terms of the Regulations published in terms of this Act
(GNR 912), a Basic Assessment or Environmental Impact
Assessment is required to be undertaken for identified listed
activities.
Any person who stores waste must at least take steps,
unless otherwise provided by this Act, to ensure that:
» The containers in which any waste is stored, are intact
and not corroded or in
» any other way rendered unlit for the safe storage of
waste.
» Adequate measures are taken to prevent accidental
spillage or leaking.
» The waste cannot be blown away.
» Nuisances such as odour, visual impacts and breeding
of vectors do not arise; and
» Pollution of the environment and harm to health are
Gauteng Department
of Agriculture and
Rural Development
(GDARD)
No waste management activities listed are
associated with the proposed Clayville Thermal
Plant, therefore no permit is required in this
regard.
Waste handling, storage and disposal during
construction and operation is required to be
undertaken in accordance with the
requirements of the Act, as detailed in the EMPr
(refer to Appendix H).
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Legislation Applicable Sections Relevant Authority Compliance Requirements
prevented.
National Forests Act (Act No 84
of 1998)
» According to this Act, the Minister may declare a tree,
group of trees, woodland or a species of trees as
protected. The prohibitions provide that ‘no person
may cut, damage, disturb, destroy or remove any
protected tree, or collect, remove, transport, export,
purchase, sell, donate or in any other manner acquire
or dispose of any protected tree, except under a
license granted by the Minister’.
» GN 908 of 21 November 2014 provides a list of
protected tree species.
» Department of
Agriculture,
Forestry and
Fisheries (DAFF).
» Gauteng
Department of
Agriculture and
Rural
Development
(GDARD)
A permit or license is required for the destruction
of protected tree species and/or indigenous tree
species. No protected tree species have been
identified within the project site and therefore no
permit is required from DAFF.
The Hazardous Substances Act
No. 15 of 1973
» This Act was promulgated to provide for the control of
substances which may cause injury or ill-health to, or
death of, humans by reason of their toxic, corrosive,
irritant, strongly sensitising or flammable nature.
» The Hazardous Substances Act also provides for
matters concerning the division of such substances or
products into groups in relation to the degree of
danger, the prohibition and control of the importation,
manufacture, sale, use, operation, application and
disposal of such substances and products.
» Department of
Health
» Ekurhuleni
Metropolitan
Municipality.
It is necessary to identify and list all the Group I, II,
III and IV hazardous substances that may be
utilised on the Clayville Thermal Plant project site
and in what operational context they are used,
stored or handled. If applicable, a license is
required to be obtained from the Department of
Health and/or the Ekurhuleni Metropolitan
Municipality.
Provincial Legislation
Gauteng Noise Control
Regulations (1999)
Acknowledges the role of the Gauteng Province to take
effective measures to support local government. The
document aims to:
» Provide a uniform minimum standard for noise
regulation in the Province;
» Accommodate the specific circumstances of different
neighbourhoods and areas; and
» Create new mechanisms for effective enforcement in
neighbourhoods.
Ekurhuleni Metropolitan
Municipality.
Noise impacts are expected to be associated
with the construction and operation phases of
the project and are not likely to present a
significant intrusion to the local community,
which is located more than 1 km from the site.
There is therefore no requirement for a noise
permit in terms of the legislation.
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Legislation Applicable Sections Relevant Authority Compliance Requirements
In the Gauteng Noise Control Regulations of 1999, a
disturbing noise refer to a noise level that causes the
ambient noise level to rise above the designated zone
level, or if no zone level has been designated, the typical
rating levels for ambient noise in districts, indicated in table
2 of SABS 0103.
Gauteng Provincial
Environmental Management
Framework (2014)
The Gauteng Provincial Environmental Management
Framework is a legal instrument in terms of the
Environmental Management Framework Regulations, 2010.
The purpose of the regulations is to assist environmental
impact management including EIA processes, spatial
planning and sustainable development.
The objective of the framework is to promote efficient
urban development (including associated service
infrastructure) in defined selected areas with lower
environmental concerns and high development demand.
Gauteng Department
of Agriculture and
Rural Development
(GDARD)
The development of the Clayville Thermal Plant
will aid in the promotion of sustainable
development within an area where there are
low environmental concerns (i.e. highly
transformed industrialised area) and high
development demand. The Clayville Thermal
Plant falls within Zone 5 which is the industrial and
commercial development focus zone. The
development is therefore compliant with the
relevant planning for the area. No further
compliance requirements are applicable.
Service Delivery Charter and
Standards for the Gauteng
Department of Agriculture,
Conservation and Environment
(2014)
The following strategic objectives must be implemented:
» The facilitation of sustainable development in Gauteng
by ensuring sustainable land uses (including
infrastructure development) and land use patterns.
» To contribute to sustainable development and quality
of life by promoting a safe and healthy living
environment.
Gauteng Department
of Agriculture and
Rural Development
(GDARD)
The Clayville Thermal Plant will be developed on
a project site zoned for Industrial Use.
Guideline Documents / Standards / Plans
SANS 69 - South African National
Standard - Framework for setting
& implementing national
ambient air quality standards,
SANS 1929 - South African
National Standard - Ambient Air
» The South African Bureau of Standards (SABS), through
a technical committee, developed ambient air quality
limits based on international best practice for
particulate matter less than 10 µm in aerodynamic
diameter (PM10), dust fallout, sulphur dioxide, nitrogen
dioxide, ozone, carbon monoxide, lead and benzene.
Ekurhuleni Metropolitan
Municipality
The recommendations that the standards make
are likely to inform decisions by authorities, but
non-compliance with the standards will not
necessarily render an activity unlawful.
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Legislation Applicable Sections Relevant Authority Compliance Requirements
Quality - Limits for common
pollutants.
These ambient limits were derived from international best
practice and what was regarded to be achievable in the
South African context, taking both the natural environment
and socio-economic status into account. The SANS limits
informed the newly promulgated SA Standards
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4.5.1 International Guidelines
i. The Equator Principles III (June, 2013)
The Equator Principles (EPs) III constitute a financial industry benchmark used for determining, assessing,
and managing projects environmental and social risks. The EPs are primarily intended to provide a
minimum standard for due diligence to support responsible risk decision-making. The EPs are applicable to
large infrastructure projects and apply globally to all industry sectors.
The EPs comprise the following principles:
Principle 1: Review and Categorisation
Principle 2: Environmental and Social Assessment.
Principle 3: Applicable Environmental and Social Standards.
Principle 4: Environmental and Social Management System and Equator Principles Action Plan
Principle 5: Stakeholder Engagement
Principle 6: Grievance Mechanism
Principle 7: Independent Review
Principle 8: Covenants
Principle 9: Independent Monitoring and Reporting
Principle 10: Reporting and Transparency.
When a project is proposed for financing, the Equator Principle Financial Institution (EPFI) will categorise it
based on the magnitude of its potential environmental and social risks and impacts.
Projects can be categorised as follows:
Category A: Projects with potential significant adverse environmental and social risks and/or impacts
that are diverse, irreversible or unprecedented.
Category B: Projects with potential limited adverse environmental and social risks and/or impacts that
are few in number, generally site-specific, largely reversible and readily addressed through mitigation
measures.
Category C: Projects with minimal or no adverse environmental and social risks and/or impacts.
Category A and Category B projects require that an assessment process be conducted to address the
relevant environmental and social impacts and risks associated with the project. Such an assessment may
include the following where applicable:
» An assessment of the baseline environmental and social conditions.
» Consideration of feasible environmentally and socially preferable alternatives.
» Requirements under host country laws and regulations, applicable international treaties and
agreements.
» Protection and conservation of biodiversity (including endangered species and sensitive ecosystems in
modified, natural and Critical Habitats) and identification of legally protected areas.
» Sustainable management and use of renewable natural resources (including sustainable resource
management through appropriate independent certification systems).
» Use and management of dangerous substances.
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» Major hazards assessment and management.
» Efficient production, delivery and use of energy.
» Pollution prevention and waste minimisation, pollution controls (liquid effluents and air emissions), and
solid and chemical waste management.
» Viability of Project operations in view of reasonably foreseeable changing weather patterns/climatic
conditions, together with adaptation opportunities.
» Cumulative impacts of existing Projects, the proposed Project, and anticipated future Projects.
» Respect of human rights by acting with due diligence to prevent, mitigate and manage adverse
human rights impacts.
» Labour issues (including the four core labour standards), and occupational health and safety.
» Consultation and participation of affected parties in the design, review and implementation of the
Project.
» Socio-economic impacts.
» Impacts on Affected Communities, and disadvantaged or vulnerable groups.
» Gender and disproportionate gender impacts.
» Land acquisition and involuntary resettlement.
» Impacts on indigenous peoples, and their unique cultural systems and values.
» Protection of cultural property and heritage.
» Protection of community health, safety and security (including risks, impacts and management of
Project’s use of security personnel).
» Fire prevention and life safety.
Such an assessment should propose measures to minimise, mitigate, and offset adverse impacts in a
manner relevant and appropriate to the nature and scale of the proposed Project. In terms of the EPs
South Africa is a non-designated country, and as such the assessment process for projects located in South
Africa evaluates compliance with the applicable IFC PSs on Environmental and Social Sustainability and
the World Bank Group (WBG) EHS Guidelines.
The Clayville Thermal Plant is currently being assessed in accordance with the requirements of the
amended 2014 EIA Regulations (GNR 326), published in terms of Section 24(5) of the National
Environmental Management Act (No. 107 of 1998) (NEMA), which is South Africa’s national legislation
providing for the authorisation of certain controlled activities. Through this assessment, all potential social
and environmental risks have been identified and assessed, and appropriate mitigation measures
proposed.
ii. International Finance Corporation (IFC) Performance Standards on Environmental and Social
Sustainability (January 2012)
The International Finance Corporation’s (IFC) Performance Standards (PS) on Environmental and Social
Sustainability were developed by the IFC and were last updated on 1 January 2012. The overall objectives
of the IFC PS are:
» To fight poverty.
» To do no harm to people or the environment.
» To fight climate change by promoting low carbon development.
» To respect human rights;
» To Promote gender equity;
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» To provide information prior to project development, free of charge and free of external manipulation;
» To collaborate with the project developer to achieve the PS;
» To provide advisory services; and
» To notify countries of any Trans boundary impacts as a result of a Project.
The PS comprise of the following:
Performance Standard 1: Assessment and Management of Environmental and Social Risks and
Impacts.
Performance Standard 2: Labour and Working Conditions.
Performance Standard 3: Resource Efficiency and Pollution Prevention.
Performance Standard 4: Community Health, Safety and Security.
Performance Standard 5: Land Acquisition and Involuntary Resettlement.
Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural
Resources.
Performance Standard 7: Indigenous Peoples.
Performance Standard 8: Cultural Heritage.
Performance Standard 1 establishes the importance of:
i). Integrated assessment to identify the social and environmental impacts, risks, and opportunities of
projects.
ii). Effective community engagement through disclosure of project-related information and consultation
with local communities on matters that directly affect them.
iii). The management of social and environmental performance throughout the life of a project through
an effective Environmental and Social Management System (ESMS).
PS 1 requires that a process of environmental and social assessment be conducted, and an ESMS
appropriate to the nature and scale of the project and commensurate with the level of its environmental
and social risks and impacts be established and maintained. PS 1 is the overarching standard to which all
the other standards relate. PS 2 through 8 establish specific requirements to avoid, reduce, mitigate or
compensate for impacts on people and the environment, and to improve conditions where appropriate.
While all relevant social and environmental risks and potential impacts should be considered as part of the
assessment, PS 2 through 8 describe potential social and environmental impacts that require particular
attention in emerging markets. Where social or environmental impacts are anticipated, the developer is
required to manage them through its Environmental and Social Management System (ESMS) consistent
with PS 1.
iii. The IFC Environmental Health and Safety (EHS) Guidelines
The IFC EHS Guidelines are technical reference documents with general and industry specific examples of
Good International Industry Practice (GIIP). The IFC EHS General Guideline has relevance to the proposed
project.
The General EHS Guidelines are designed to be used together with the relevant Industry Sector EHS
Guidelines. The EHS Guidelines’ general approach to air quality states that projects should prevent or
minimise impacts by ensuring that:
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» Emissions do not result in pollutant concentrations that reach or exceed the relevant national ambient
air quality guidelines and standards, or in their absence, the current World Health Organisation (WHO)
Air Quality Guidelines (AQG) or other internationally recognised sources;
» Emissions do not contribute a significant portion to the attainment of relevant ambient AQG or
standards. The Guideline suggests 25% of the applicable ambient air quality standards to allow
additional, future development in the same airshed.
The IFC EHS Guidelines contain the performance levels and measures normally acceptable to the IFC and
are generally considered to be achievable in new facilities at reasonable costs. When host country
regulations differ from the levels and measures presented in the EHS Guidelines, projects are expected to
achieve whichever standard is more stringent.
The General EHS Guidelines state that at project level, impacts should be estimated through qualitative or
quantitative assessments by the use of baseline air quality assessments and atmospheric dispersion models.
The dispersion model should be internationally recognised and able to take into account local
atmospheric, climatic and air quality data as well as the effects of downwash, wakes or eddy effects
generated by structures and terrain features.
The General EHS Guidelines also provides guidance with respect to:
» Projects located in degraded airsheds or ecologically sensitive areas;
» Points sources and stack heights;
» Emissions from small combustion facilities (3 to 50 MWth rated heat input capacity);
» Fugitive sources;
» Ozone depleting substances;
» Land based mobile sources;
» Greenhouse gases;
» Monitoring; and
» Air emissions prevention and control technologies
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CHAPTER 5: DESCRIPTION OF THE RECEIVING ENVIRONMENT
This section of the EIA Report provides a description of the environment that may be affected by the
Clayville Thermal Plant. This information is provided in order to assist the reader in understanding the
receiving environment within which the proposed development is situated. Aspects of the biophysical,
social and economic environment that could be directly or indirectly affected by, or could affect, the
proposed development have been described. This information has been sourced from both existing
information available for the area as well as collected field data, and aims to provide the context within
which this EIA is being conducted. A comprehensive description of each aspect of the affected
environment is included within the specialist reports contained within the Appendices D - F.
5.1 Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended)
This chapter of this final EIA Report includes the following information required in terms of Appendix 3:
Content of the Environmental Impact Assessment Report:
Requirement Relevant Section
(h)(iv) the environmental attributes
associated with the development footprint
alternatives focusing on the geographical,
physical, biological, social, economic,
heritage and cultural aspects
The environmental attributes associated with the development of
the Clayville Thermal Plant is included as a whole within this chapter.
A comprehensive description of each aspect of the affected
environment is included within the specialist reports contained within
the Appendices D - F.
5.2 Regional Setting: Location of the Project Site
The Gauteng Province is the smallest province in South Africa covering an area of approximately
18 178 km² and supporting approximately 13 million people. The province shares the boundaries with the
Mpumalanga, Limpopo, North West and Free State Provinces. The proposed development falls within the
Clayville industrial area near Olifantsfontein under the jurisdiction of the Ekurhuleni Metropolitan
Municipality. It is one of three metropolitan municipalities that form part of the Gauteng Province.
Erf 459 is currently used for industrial purposes (i.e. offices and ware-housing) and is devoid of natural
vegetation. Erf 457 and Erf 12 of 508 are currently vacant land and are in a disturbed and transformed
state, with most of the vegetative species comprising of weeds, pioneers and Invasive Alien Plants (IAPs).
All three properties are currently zoned as Industrial 1.
The broader study area within the Clayville Industrial Area is bordered by mixed-use of industrial
developments as well as open areas. There are two residential areas situated near the project site, i.e.
Clayville East (~1.1km east) and Tswelapele (~1.8km west). The regional road, R562, is situated
approximately 500m south east of the project site. The N1, situated west of the project site, carries
significant traffic each day. A railway line servitude traverses the centre of the project site. The railway line
has however been decommissioned and is no longer in use. There are three substations within a 700m
radius of the proposed site (i.e. the Clayglass 88/11kV Substation, the Consol 88kV Substation and the
Clayville Four 88/11/6.6kV Substation), which adds to the industrial nature of the area and the project site.
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Agricultural activities, mainly relating to cultivation are located ~3,5km east and 4km north-west of the
project site.
5.3 Climatic Conditions
Temperature:
Specific data related to Olifantsfontein and Clayville was unavailable during the time this report was
compiled, and therefore data from OR Tambo International Airport (located 18km south from the site) was
used to represent the climatic conditions of the project site and surrounding area.
This region of Gauteng experiences a temperate Highveld climate with warm summers and mild winters.
Rainfall predominantly occurs in summer. The climate of this region of Gauteng has the following
characteristics i) the mean annual rainfall is about 60mm, with January typically being the wettest month,
averaging at about 125mm, and July being the driest with an average of only 4mm; ii) the average annual
temperature in this area is 16°C, with January being the warmest (ave. 20.1°C) and June being the coldest
(ave. 10.1°C).
Wind conditions:
Winds within this region are considered to be light to moderate and are typically less than 8 m/s but
stronger winds can occur. A windrose is used to depict the frequency of occurrence of wind from the 16
cardinal wind directions as well as define wind speed classes (refer to Figure 5.1). The wind direction is
predominantly west-northwest to east-northeast.
Dispersion:
The dispersion potential of an area experiences both diurnal and seasonal variation. During the day,
radiation is stronger in the summer than in winter and the dispersion potential is generally better on summer
days than winter days. Thermal turbulence disappears when the sun sets, and mechanical turbulence
decreases as the wind speeds drops at night. At night, as the surface temperature inversion develops, the
lowest layer of the atmosphere becomes more and more stable, reaching a maximum stability at sunrise
when the inversion is strongest and deepest. As a result, the dispersion potential is inhibited during the
night and the poorest dispersion conditions generally occur at sunrise. Pollutants tend to accumulate near
the point of release under these conditions, particularly when released close to ground level. The
dispersion potential is generally poorer during winter nights than summer nights.
Over Gauteng, the dispersion potential is relatively poor and particularly so in winter. Anticyclonic
circulation prevails and the associated subsidence is conducive to the formation of elevated temperature
inversions with base heights between 2000 m and 3000 m above ground level in summer and 1700 m
above ground level in winter (Tyson et al, 1988). The anticyclonic conditions are ideal for the formation of
surface-based temperature inversions. Tyson et al (1976) indicated winter surface inversions varying from 5
to 7°C in strength and 300 to 500 m in depth over the Highveld. In summer, the depths are similar to winter
but the strength seldom exceeded 2°C.
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Figure 5.1: Windrose depicting annual wind direction and speed at OR Tambo in m/s (obtained from
Meteoblue https://www.meteoblue.com/). Wind speed is given in m/s, and each arc
represents a frequency of occurrence of 500 hours. There are 8 760 hours in a year.
5.4 Biophysical Characteristics of the Study Area
5.4.1 Geology
The oldest rocks in the area are the basement rocks of the Johannesburg Dome to the west of the project
site. These rocks include ultramafic rocks, gneiss, migmatite and granodiorite. To the east, north and south
of the project site are a variety of ancient rocks of the Witwatersrand Supergroup and the Pretoria Group,
ranging in age from 3340 to 2150 Ma (million years). These rocks are all volcanic (produced by early
volcanic activity, i.e. igneous rock that came up to the surface) or plutonic (igneous rock that solidified far
below the earth’s surface) in origin.
Figure 5.2 provides an illustration of the geology of the surrounding area and the project site. To the south
east of the project site is an outlier of the Karoo Supergroup sediments, namely sandstones, shales and
coals of the Early Permian Ecca, Vryheid Formation.
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Figure 5.2: Geological map of the area around Clayville Thermal Plant (indicated by black circle).
Map enlarged from the Geological Survey 1: 1 000 000 map 1984. Abbreviations of the rock
types are explained in Table 5.1 below.
According to regional geological mapping, the project site falls within the Malmani Subgroup
(Chuniespoort Group, Transvaal Supergroup), which consists of variable weathered dolomite. The
weathered dolomite is commonly intruded by syenite sills and dykes. It is expected that the project site is
likely to be underlain by chert-rich dolomite Monte Christo Formation of the Malmani Subgroup, as
opposed to the chert-poor dolomite of the Lyttleton Formation. Due to the geological setting of the
project site, there is a risk of sinkholes forming anywhere on-site.
Table 5.1: Explanation of symbols for the geological map and approximate ages (Barbolini et al., 2016;
Erikssen et al., 2006. Johnson et al., 2006; McCarthy, 2006; van der Westhuizen et al., 2006).
SG = Supergroup; Fm = Formation.
Symbol Group/Formation Lithology Approximate Age
Jd Jurassic dolerite dykes Dolerite Ca 180 Ma
Pv Vryheid Fm, Ecca Group Sandstone, shale, coal Early Permian 296-269 Ma
C-Pd Dwyka Tillite, sandstone, mudstone,
shale
Upper Carboniferous, Early
Permian 295-290 Ma
Vsi Silverton Fm, Pretoria Group Basalt, tuff, shale Ca 2150 Ma
Vhd Dwaalheuvel, Strubenkop and
Daspoort Fms; Pretoria Group
Andesite, sandstone, shale
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Symbol Group/Formation Lithology Approximate Age
Vh Hekpoort Fm, Pretoria Group Basaltic andesite, pyroclastic
rocks
2224 Ma
Vti Timeball Hill and Rooihoogte
Fm, Pretoria Group
Shale, quartzite, conglomerate,
breccia, diamictite
Ca 2420 Ma
Vm Malmani subgroup,
Chuniespoort Group
Dolomite, chert 2642 – 2500 Ma
Vbr Black Reef Fm Quartzite, conglomerate, shale,
basalt
>2642 Ma
Vdi Diabase Diabase
Rk Klipriviersberg Group,
Ventersdorp Supergroup
Mafic and felsic lavas,
quartzites, shales
conglomerates
Late Archaean
>2700 Ma
Rw Witwatersrand Supergroup
(undifferentiated)
Quartzite, shale Ca 2950 – 2750 Ma
Rt Turfontein Subgroup, Central
Rand Group, Witwatersrand SG
Conglomerate, quartzite
Rjo Johannesburg Subgroup,
Central Rand group,
Witwatersrand SG
Quartzite, conglomerate, shale
Rg Government Subgroup, West
Rand Group, Witwatersrand SG
Quartzite, shale
Rh Hospital Hill, West Rand Group,
Witwatersrand SG
Shale, quartzite
Z, Zhh Basement complex of the
Johannesburg Dome
Gneiss, migmatite, granodiorite 3340 Ma
5.4.2 Soils and Agricultural Potential
Soil within the study area is expected to be clayey silty sand of an Aeolian/hillwash origin with a colluvial
pebble marker separating the transported and residual profile. Thick chert-rich residuum consisting of small
through large boulders in a clayey silty sand matrix, underlain by highly and deeply weathered and
leached, dolomite bedrock which is penitentially intruded by syenite.
The land capability for the project site is classified as land type Class III (unsuitable for crop production).
The area south-west of the project site is classified as having severe limitations regarding crop production
(Class VI). No agricultural activities are being undertaken within the broader study area or within the
project site.
5.4.3 Ecological Profile
Protected and conservation areas:
According to the Gauteng Conservation Plan Version 3.3 the proposed project site does not fall within any
CBA areas. The project site however borders a narrow strip of open space classified as an Ecological
Support Area (ESA). An ESA is also present south east of the affected properties. The closest CBA area is
located approximately 900m to the east of the affected properties (east of the Clayville East residential
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area and the M57 Road). This CBA is regarded as an Important Area due to the potential habitat
provided for Red Listed plant species as well as the presence of primary vegetation within this area.
Vegetation:
The project site is situated in the Grassland biome and Dry Highveld Grassland Bioregion. The vegetation in
and surrounding the project site is Carletonville Dolomite Grassland (Gh15). This vegetation type has been
classified as Vulnerable, although it is not included within the National List of Ecosystems that are
Threatened and in need of protection (GN1002 of 2011), published under the National Environment
Management: Biodiversity Act (Act No. 10 of 2004).
A species list from POSA (http://posa.sanbi.org, Grid reference 2528CC) containing the species that have
been recorded to date in the area was obtained. A total of 894 indigenous species have been recorded
in the 2528CC Quarter Degree Grid according to the SANBI database.
The proposed project site are situated within a relative dense industrial area, with most of the landscape
being transformed, comprising of hard surfaces and largely built up areas. Erf 457 is in a similar condition
comprising out of standing infrastructure, hard surfaces and areas devoid of natural vegetation. This
property contains no natural elements and furthermore likely do not sustain any natural biodiversity and
ecological services. Erf 459 and Portion12 of Erf 508 are currently not developed and contain some form of
vegetation. These two properties cumulatively cover an area of approximately 0.96ha. These properties
are in a disturbed and transformed state, with most of the vegetative species comprising of weeds (i.e.
Argemone ochroleuca), pioneers and Invasive Alien Plants (IAPs). Bare patches, devoid of vegetation, are
also present within these two properties and has resulted in soil compaction and some sheet erosion.
Building rubble have also been dumped within these areas.
The natural indigenous vegetation within the project site is severely limited and due to the fact that this
area is so isolated, unstable and small in size it is highly unlikely that at any time in the future this area will
naturally re-establish a satisfactory natural vegetation cover, sustaining natural biodiversity and processes.
Fauna:
Of the 50 species recorded within the degree grid, 5 species are highly likely and 6 species are likely to
occur within and/or within the immediate surroundings. Six species have a slight potential to occur within
this area. Most of these species that are likely to occur within the project site will most likely not reside
permanently within the project site but rather move through the area. None of these species likely to be
found within the area are Red List species. The only potential red list mammal species that may inhabit the
surrounding environment is the South African Hedgehog – Atelerix frontalis (Near Threatened) although no
suitable habitat is present within the affected properties and the occurrence of this species within these
properties is highly unlikely. Most likely mammals to inhabit the project site as well as immediate
surrounding environment include mostly cosmopolitan (introduced) species such as domestic cat – Felis
catus; Mauritian Tomb Bat – Taphozous mauritianus; Geoffroy’s Horseshoe Bat – Rhinolophus clivosus,
Yellow-bellied House Bat – Scotophilus dinganii, House mouse – Mus musculus and House rat – Rattus rattus.
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5.5 Access and Transport Routes in the Region
The Clayville industrial area is located between the R562 (also referred to as the Olifantsfontein Road) to
the south of the project site, South View Road to the north of the project site and the M18 (Main Road) to
the east of the project site. These two-lane arterial roads are characterised by signalised intersections and
provide access links to the broader road network as below:
» The R562 forms an important road link between the N1 to the west of the Clayville industrial area and
the R21 to the east of Clayville industrial area.
» The M18 is a north-south orientated route, with mostly industrial related traffic in the vicinity of the
Clayville industrial area and lighter traffic volumes north of South View Road. The M18 provides access
to the R562 situated to the south and to Nellmapius Drive to the north of the Clayville industrial area.
» South View Road is a connector link between the R562 and the M18. A high percentage of traffic on
this road link is generated by Clayville industrial area.
» The Clayville industrial area road network in the vicinity of the project site is typical to many industrial
developments, comprising 8m wide two-lane roads centrally located in 25 metres wide road reserves.
These roads are characterised by a high number of site accesses, unkept road verges and a lack of
pedestrian facilities, apart from Nut Avenue that provides a paved sidewalk for pedestrians (along the
northern road edge).
Access to the site is possible via Spanner Road situated west of the project site and from Industrial Road
situated east of the project site. These north-south orientated roads junction with South View Road,
approximately 1km to the north of the project site. Nut Avenue and Nail Avenue provide east-west
orientated links between Spanner and Industry Roads.
5.6 Air Quality
The identification of current sources of emissions in the area and the characterisation of existing ambient
pollutant concentrations is fundamental to understand the current air quality of the area. The Ekurhuleni
Metropolitan Municipality (EMM) covers an extensive area from Germiston in the west to Springs and Nigel
in the east. There are nearly 180 recorded industrial facilities in the EMM that operate Listed Activities.
Traffic in the municipality is significant with highway connections to major cities such as Johannesburg,
Tshwane and Durban. OR Tambo International Airport is situated within the eastern part of Johannesburg
within the EMM. There are also mining activities within the municipality. Air pollution sources specifically in
the Clayville industrial area include industrial activity and motor vehicle emissions.
The municipality operates eleven (11) ambient air quality monitoring stations, including a monitoring
station at Olifantsfontein. These monitoring stations collect hourly data on pollutants including SO2, NO2
and particulates. Ambient PM10 concentrations exceed the National Ambient Air Quality Standard
(NAAQS) throughout the municipality, while there are frequent exceedances of the NAAQS for NO2.
Figure 5.3 illustrates hourly NO2 and SO2 concentrations at Olifantsfontein in parts per billion (ppb). The
annual average SO2 concentrations at the Olifantsfontein monitoring station are well below the National
Ambient Air Quality Standards (NAAQS) of 19 ppb since 2014. The annual average NO2 concentrations at
Olifantsfontein are relatively high and exceeded the NAAQS of 19 ppb in 2014 and 2016. Table 5.2
indicates the annual average concentrations of SO2 and NO2 concentrations at Olifantsfontein measured
in ppb.
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Figure 5.3: Illustrate hourly NO2 (left) and SO2 (right) concentrations at Olifantsfontein in ppb. The limit
value of the NAAQS is shown by the red lines.
Table 5.2: Annual average concentrations of SO2 and NO2 concentrations.
NO2 SO2
2014 35.1 8.8
2015 5.3
2016 21.9 6.2
2017 12.0 4.0
Sensitive receptors:
Residential areas are commonly classed as sensitive receptors as people generally spend more time at
home than elsewhere. Potentially sensitive receptors to the Clayville Thermal Plant are therefore any
residential areas relatively close to the facility, and particularly those in the downwind sector that may be
affected by emissions from the proposed thermal plant. The downwind sector from the thermal plant is
predominantly east-southeast to west-southwest of the facility, i.e. downwind under the prevailing west-
northwest to east-northeast wind conditions.
There are two residential areas relatively close to the project site in the downwind zone. These include
Clayville East which is situated 1.1km to the east and north east, and Tswelapele, ranging from
approximately 1.8km to the north west of the plant. The town of Clayville is located approximately 1.8km to
the north-northeast, upwind of the proposed thermal plant.
5.7 Heritage features of the region
5.7.1 Heritage and archaeology
South Africa has a long and complex Stone Age sequence of more than 2 million years. The broad
sequence includes the Later Stone Age, the Middle Stone Age and the Earlier Stone Age. Each of these
phases contains sub-phases or industrial complexes, and within a regional variation regarding
characteristics and time ranges can be expected. The three main phases can be divided as follows:
» Later Stone Age (LSA); associated with Khoi and San societies and their immediate predecessors.
Recently to ~30 thousand years ago.
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» Middle Stone Age (MSA); associated with Homo sapiens and archaic modern humans. 30-300
thousand years ago.
» Earlier Stone Age (ESA); associated with early Homo groups such as Homo habilis and Homo erectus.
400 000-> 2 million years ago.
Stone Age:
Remains dating to all three of these phases were recorded at the Boulders Shopping Centre
approximately 10km south west of the proposed project site, by Mason (1997). The Melville Koppies is a
MSA site and is located ~34km from the project site (Bergh 1999: 4). This broader area was also considered
to be significant to Iron Age communities, since these people had smelted and worked iron ore at the
Melville Koppies site since the year 1060, by approximation (Bergh 1999: 7, 87). MSA and LSA material was
also recorded at Glennferness cave in Johannesburg. Evidence that the larger area was utilised by Stone
Age communities includes ESA and MSA tools, which were recorded along the Kliprivier.
Iron Age:
The Iron Age of the region consists of Tswana speaking people who settled in the area from the early 16th
century. The Iron Age is characterised by the ability of early people to manipulate and work Iron ore into
implements that assisted them in creating a favourable environment to make a better living.
The Smelting Site at Melville Koppies was excavated by Professor Mason from the Department of
Archaeology of the University of Witwatersrand in the 1980s. Extensive stone-walled sites are also recorded
further south at Klipriviers Berg Nature Reserve belonging to the Late Iron Age period. These sites are now
collectively referred to as Klipriviersberg (Huffman, 2007). The settlements are complex in that aggregated
settlements are common, the outer wall sometimes includes scallops to mark back courtyards, there are
more small stock kraals, and straight walls separate households in the residential zone. These sites date to
the 18th and 19th centuries and was built by people in the Fokeng cluster.
In this area, the Klipriviersberg walling would have ended at approximately AD 1823, when Mzilikazi
entered the area (Rasmussen, 1978). This settlement type may have lasted longer in other areas because
of the positive interaction between Fokeng and Mzilikazi.
The Difaqane (Sotho), or Mfekane was a time of bloody upheavals in KwaZulu-Natal and in the Highveld,
which occurred around the early 1820’s until the late 1830s. This was in response to heightened
competition for land and trade, and caused population groups like gun-carrying Griquas and Shaka’s
Zulus to attack other tribes. In 1827, Mzilikazi’s Ndebele started moving through the area where
Johannesburg is located today. This group went on raids to various other areas in order to expand their
area of influence (Bergh, 1999). These settlements are complex in that aggregated settlements are
common, and the outer wall sometimes includes scallops to mark back courtyards. There are also small
stock kraals and straight walls separate households in the residential zone. These sites date to the 18th and
19th centuries and was built by people in the Fokeng cluster. In this area, the Klipriviersberg walling would
have ended at about AD 1823, when Mzilikazi entered the area (Rasmussen, 1978). This settlement type
may have lasted longer in other areas due to the positive interaction between Fokeng and Mzilikazi.
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Historical Information:
During the time of the Difaqane, a northwards migration of white settlers from the Cape was taking place.
Some travellers, missionaries and adventurers had gone on expeditions to the northern areas in South
Africa as early as the 1720s. It was however only by the late 1820s that a mass-movement of Dutch
speaking people in the Cape Colony started advancing into the northern areas. This was due to feelings
of mounting dissatisfaction caused by economical and other circumstances in the Cape. This movement
later became known as the Great Trek. This migration resulted in a massive increase in the extent of that
proportion of modern South Africa dominated by people of European descent (Ross, 2002). By 1939 to
1940, farm boundaries were drawn up in an area that includes the present-day Johannesburg and
Krugersdorp (Bergh, 1999).
The first settlers moved within the Midrand area in the 1820s, and included hunters, traders, missionaries and
other travellers. Voortrekker farmers such as Frederik Andries Strydom and Johannes Elardus Erasmus
established the farms Olifantsfontein and Randjesfontein respectively around the 1840’s and this indicated
permanent occupation of the area by white settlers. These early settlers and their descendants were often
buried on their farms and formal and informal graves and graveyards can be expected anywhere on the
landscape (Van Schalkwyk, 1998).
The Anglo-Boer War (1899-1902) also impacted the Midrand area as the area was a key focus of the British
war effort for a short period of time when the British forces under Lord Roberts advanced through Midrand
from Johannesburg while travelling to Pretoria. Pretoria was occupied on 5 June 1900. Some British military
units were stationed close to the project site which now includes the Eskom Academy of Learning (~8km
south west). No major battles took place in Midrand and conflict in the area was defined by the Boer
attempts to sabotage the railway line as well as attacks on troop trains. A notable incident was the
successful Boer demolition of the railway culvert near the Pinedene Station (Van Schalkwyk, 1998). During
this time, there was also a Black Concentration Camp built by the British near Olifantsfontein
station/railway (Bergh, 1999).
The general area under investigation has a wealth of heritage sites and a cultural layering including LSA
scatters and numerous grave sites and cemeteries. None of these sites are located within or close to the
project site but provides an indication of sites that can be expected in the area.
5.7.2 Palaeontology (Fossils)
The Black Reef Formation and Malmani Subgroup contain banded ironstone and dolomites, which were
formed by the chemical activities of ancient algae, photosynthesis and oxygen production. This formation
aren’t known to have preserved fossil algae near Olifantsfontein. Some formations within the ancient
Pretoria Group represent marginal marine or lacustrine deposits with trace fossils of microbial mats and
some ripple marks, for example the Daspoort and Magaliesberg Formations, but not the particular
formations occurring in the Olifantsfontein area.
The Dwyka Formation represents the receding glacial deposits from the Upper Carboniferous and Early
Permian, a time period when land plants were abundant in the warmer regions to the far north of Brakpan.
Rare Dwyka fossils (Glossopteris leaves, Stigmaria roots, lycopods and sphenophytes) have been reported
from near Vereeniging, about 75-100km southwest of Olifantsfontein. No fossil plants of the Glossopteris
flora have been reported from the Vryheid Formation around Olifantsfontein. All these rock formations are
too old for vertebrate body fossils.
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There is a possibility that there are refractory clays at the base of the Vryheid Formation, especially given
the name of the area, similar to the ones recorded to the south west and south east of the Rand. Although
clay deposits are fairly common, they seldom preserve fossil plants, the exception being the Lawley brick
quarry near Lenasia (Bredell, 1978, Anderson and Anderson, 1985).
5.8 Social and Economic Characteristics of the Project Site and Surrounding Areas
The EMM is considered to be one of the most densely populated areas in the province and in the country
and includes Germiston in the west and Springs and Nigel in the east. Other cities/towns included in the
municipality include Alberton, Edenvale, Kempton Park and Tembisa. The EMM covers an area of over
975km² and is regarded as the transportation hub of the country as it is home to OR Tambo International
Airport, South Africa's largest railway hub; several modern freeways and expressways and the Maputo
Corridor Development (Municipalities of South Africa, 2012-2017).
The Ekurhuleni Metropolitan Municipality is classified as a Category A municipality which means that the
municipality governs major city regions. Approximately 23% of the economy consists of manufacturing,
22% of finance and business services, 19% of community services and 11% of transport. The diverse
economy in the region accounts for almost a quarter of the province’s economy and is often referred to
as “Africa’s Workshop”. Key projects in the municipality include:
» Ekurhuleni Aerotropolis Development;
» Revitalisation of the manufacturing sector;
» Integrated Rapid Public Transport System (IRPTN);
» Digital City; and
» Revitalisation of township economies.
Baseline Characteristics of the Ekurhuleni Metropolitan Municipality:
General baseline characteristics and challenges of the ULM are as follows (Statistics South Africa, 2011):
» The municipality has a population of ~3 178 470.
» Of the ~3 178 470 population, about 48.79% are female, while 51.21% are male.
» More than 78% of the population comprise the Black African ethnic group and 15.8% comprise the
white ethnic group.
» The municipality has a growth rate of 2.47%.
» The level of education influences growth and economic productivity of a region. In the municipality
3% of the population have no schooling, 35.8% had some form of primary education, 19.4% have
completed matric and only 3.8% of the population have higher education. This means that majority of
the population have a low-skill level and would need job employment in low-skill sectors.
» The unemployment rate is high at 28.8% (in 2011).
» The Economically Active Population (EAP) (individuals that are aged 15-64 that are either employed or
actively seeking employment) accounts for 71.7% of the entire population.
CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE
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Assessment of Impacts Page 83
CHAPTER 6: ASSESSMENT OF POTENTIAL IMPACTS
This chapter serves to assess the significance of the positive and negative environmental impacts (direct
and indirect) expected to be associated with the development of the Clayville Thermal Plant and
associated infrastructure. Cumulative environmental impacts associated with the development of the
project are assessed separately within Chapter 7. This assessment has been undertaken for all the phases
of the project’s development and for all the project components which include the following:
» CFB Boiler;
» Steam supply pipes from the central plant to various off-takers within the Clayville industrial area;
» Steam condensate return pipes to the central plant from various off-takers within the Clayville industrial
area;
» Exhaust stack located adjacent to the central plant;
» Condenser on-site for the conversion of steam back to water;
» Wastewater treatment plant with a capacity of 6 000kl per day;
» Effluent pipes and clean water supply pipes connected from the central plant to 5 off-takers within the
Clayville industrial area;
» Holding tanks for the storage of water;
» Storage of diesel within permanent immobile liquid tanks;
» Silos for the storage of bottom ash, fly ash and limestone;
» Gas cylinders for the storage of syngas;
» Dome for the storage of coal fines;
» Feedstock holding and processing area;
» Ancillary infrastructure including access roads, maintenance building, access control facilities and
office.
The full extent of the project site was considered through the Scoping Phase of the EIA process. On-site
sensitivities and potential impacts were identified through the review of existing information, desktop
evaluations, on-site inspections of impacts identified by specialists and field work. Following the
recommendations from the scoping phase, the development footprint for the Clayville Thermal Plant was
confirmed. The specialist assessments undertaken within this EIA phase have considered the 1.76ha
project site as well as the project development footprint (refer to Figure 6.1).
The development of the Thermal Plant will comprise the following phases:
» Pre-Construction and Construction – will include pre-construction surveys; site preparation;
establishment of ancillary infrastructure such as access roads, guard house, admin building, workshops,
warehouse and transportation of components/construction equipment to site. The construction phase
for the Thermal Plant is expected to take approximately 36 months.
» Operation – will include the operation of the Clayville Thermal Plant and the generation of steam
which will be provided to several off-takers located within the Clayville industrial area. The operation
phase of the project is expected to be more than 35 years.
» Decommissioning – depending on the economic viability of the Thermal Plant, the length of the
operation phase may be extended beyond a 35 year period. Decommissioning activities will involve
disassembly of the production units and ancillary infrastructure, demolishing of buildings and
rehabilitation to the desired end-use. As far as possible components will be broken down and
recycled. Note that impacts associated with decommissioning are expected to be similar to those
associated with construction activities.
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Assessment of Impacts Page 84
Figure 6.1: Map showing the layout for the Clayville Thermal Plant and associated infrastructure located within Erf 457, Erf 459 and Portion 12
of Erf 508 (refer to Appendix J for A3 maps).
Clayville Thermal Plant in the Clayville Industrial Area, Gauteng Province
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6.1 Legal Requirements as per the EIA Regulations for the undertaking of a Environmental Impact
Assessment (EIA) Report, 2014 (as amended)
This chapter of this final EIA report includes the following information required in terms of Appendix 3:
Content of Environmental Impact Assessment reports:
Requirement Relevant Section
(h)(v) the impacts and risks identified including the
nature, significance, consequence, extent, duration and
probability of such identified impacts, including the
degree to which these impacts (aa) can be reversed
(bb) may cause irreplaceable loss of resources and (cc)
can be avoided, managed or mitigated.
The potential impacts associated with the construction
and operation of the Clayville Thermal Plant are
identified and evaluated within section 6.2 to section 6.5.
Further detail is provided in the specialist studies
contained in Appendix D – F.
(h)(vii) positive and negative impacts that the proposed
activity and alternatives will have on the environment
and on the community that may be affected focusing
on the geographical, physical, biological, social,
economic, heritage and cultural aspects
The positive and negative impacts associated with the
development of the Clayville Thermal Plant are
summarised in section 6.2 to section 6.5. Further detail is
provided in the specialist studies contained in Appendix
D – F.
(h)(viii) the possible mitigation measures that could be
applied and level of residual risk
Recommendations regarding the development of the
Thermal Plant are included in section 6.2 and section 6.5.
Further detail is provided in the specialist studies
contained in Appendix D – F.
(i) a full description of the process undertaken to identify,
assess and rank the impacts the activity and associated
structures and infrastructure will impose on the preferred
development footprint on the approved site as
contemplated in the accepted Scoping Report through
the life of the activity, including (i) a description of all
environmental issues and risks that were identified during
the environmental impact assessment process, (ii) an
assessment of the significance of each issue and risk and
an indication of the extent to which the issue and risk
could be avoided or addressed by the adoption of
mitigation measures.
A description of the environmental issues and risks that
were identified during the environmental impact
assessment process and an assessment of the
significance of each issue and risk and an indication of
the extent to which the issue and risk could be avoided
or addressed by the adoption of mitigation measures are
included in sections 6.2.2, 6.2.3, 6.3.2, 6.3.3, 6.4.2, 6.4.3,
6.5.1 and 6.5.2.
(j) an assessment of each identified potentially significant
impact and risk, including (i) cumulative impacts, (ii) the
nature, extent, and consequences of the impact and
risk, (iii) the extent and duration of the impact and risk,
(iv) the probability of the impact and risk occurring, (v)
the degree to which the impact and risk can be
reversed, (vi) the degree to which the impact and risk
may cause irreplaceable loss of resources and (vii) the
degree to which the impact and risk can be mitigated.
An assessment of each potentially significant impact and
risk including the, the nature, extent, and consequences
of the impact and risk, the extent and duration of the
impact and risk, the probability of the impact and risk
occurring, the degree to which the impact and risk can
be reversed, the degree to which the impact and risk
may cause irreplaceable loss of resources and the
degree to which the impact and risk can be mitigated is
included in sections 6.2.3, 6.3.3, 6.4.3 and 6.5.2. A
separate cumulative assessment is included in Chapter 7.
(m) based on the assessment, and where applicable,
recommendations from the specialist reports, the
recording of proposed impact management outcomes
for the development for inclusion in the EMPr as well as
for inclusion as conditions for authorisation.
Recommendations from the specialists and mitigation
measures from the specialist reports for inclusion in the
EMPr are discussed within sections 6.2.3, 6.3.3, 6.4.3 and
6.5.2 and within the EMPr, which is included as Appendix
H. The EMPr also includes the recording of the
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Requirement Relevant Section
management objective and the impact management
outcomes.
6.2. Potential Impacts on Ambient Air Quality
Potential impacts on the ambient air quality and associated risks to human health, and the relative
significance of the impacts associated with the development and operation of the Clayville Thermal Plant
are summarised below (refer to Appendix D – Air Quality Impact Assessment Report for more details).
In the Clayville Industrial Area air pollution sources include industrial activity and motor vehicle emissions.
Fuel burning in nearby residential areas may also influence air quality. Several sensitive receptors have
been identified within close proximity to the project site and include:
» Clayville East (~1km east of the project site);
» Tswelapele (~1km west of the project site);
» Tembisa Provincial Hospital (~1.3km south of the project site);
» Clayville (~1.5 km north of the project site); and
» Olifantsfontein residential (~1.5 km south east of the project site).
These are areas where the occupants are more susceptible to the adverse effects of exposure to toxic
chemicals, pesticides and other pollutants.
6.2.1 Results of Impact Assessment
South Africa has established National Ambient Air Quality Standards (NAAQS) for criteria pollutants, i.e.
SO2, NO2, CO, PM10, PM2.5, ozone (O3), lead (Pb) and benzene (C6H6) (DEA, 2009 and, 2012). National dust
control regulations were published on 1 November 2013 (DEA, 2013b), setting limits for acceptable dustfall
rates for residential and non-residential areas.
The NAAQS consists of a ‘limit’ value and a permitted frequency of exceedance. The limit value is the
fixed concentration level aimed at reducing the harmful effects of a pollutant on human health. The
permitted frequency of exceedance represents the acceptable number of exceedances of the limit
value expressed as the 99th percentile. Compliance with the ambient standard implies that the frequency
of exceedance of the limit value does not exceed the permitted tolerance. Being a health-based
standard, ambient concentrations below the standard imply that air quality poses an acceptable risk to
human health, while exposure to ambient concentrations above the standard implies that there is an
unacceptable risk to human health.
To assess the impact of emissions from the proposed Clayville Thermal Plant on ambient air quality and
human health, a dispersion modelling study was undertaken to predict ambient concentrations of
pollutants resulting from the emissions.
Three scenarios were modelled for the Clayville Thermal Plant in order to predict the potential operation
impacts. These include
» Coal-fines only Scenario;
» Syngas only Scenario; and
» Natural gas only Scenario.
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The predicted ambient concentrations are assessed against the NAAQS for PM10, SO2, NOX and CO.
i. Sulphur Dioxide (SO2)
The source of SO2 from the proposed Clayville Thermal Plant includes the CFB boiler stack. The current
ambient SO2 concentrations in Olifantsfontein are relatively low compared with the NAAQS. The
implication is that the SO2 emissions from the proposed Clayville Thermal Plant will have a marginal
additive effect on existing ambient concentrations and they are highly likely to remain considerably below
the NAAQS of 50 µg/m3, for the coal fines-only option. For Syngas and natural gas, SO2 concentrations are
very low. No exceedance of the NAAQS is predicted within the proposed project site or in any residential
and sensitive receptor areas surrounding the project site.
ii. Nitrogen Dioxide (NO2)
The source of NO2 from the proposed Clayville Thermal Plant includes the CFB boiler stack. The current
ambient NO2 concentrations in Olifantsfontein are relatively high compared with the NAAQS and are
attributed mostly to motor vehicle emissions. The predicted ambient NO2 concentrations resulting from
emissions from the proposed Clayville Thermal Plant are highest for the coal fines-only option but are very
low overall and will have a marginal additive effect on existing ambient concentrations. There will
therefore be some additive effect to the existing NO2 concentrations. For the Syngas and natural gas
options, NO2 concentrations are very low. No exceedance of the NAAQS is predicted within the proposed
project site or in any residential and sensitive receptor areas surrounding the project site.
iii. Carbon Monoxide (CO)
The source of CO from the proposed Clayville Thermal Plant includes the CFB stack. The predicted
ambient CO concentrations are well below the NAAQS of 10 000 µg/m3; and no exceedance of the
NAAQS is predicted within the project site or in any residential and sensitive receptor areas around the site.
The predicted CO concentrations therefore comply with the NAAQS in the ambient environment.
iv. Particulate Matter PM10
The main source of PM10 from the proposed Clayville Thermal Plant is the CFB boiler stack. The predicted
PM10 concentrations resulting from the Clayville Thermal Plant emissions are very low for the coal fines - only
scenario. The additive effect for this scenario will be marginal. For the Syngas and natural gas options, the
concentration of PM10 is negligible. The predicted ambient concentrations are well below the NAAQS of
40 µg/m3; and no exceedance of the NAAQS is predicted within the proposed Clayville Thermal Plant site
or in any residential and sensitive receptor areas surrounding the project site.
6.2.2 Description of Impacts
The effects of air pollutants on human health occur in several ways with short-term, or acute effects, and
chronic, or long-term, effects. Different groups of people are affected differently, depending on their level
of sensitivity, with the elderly and young children being more susceptible. Factors that link the
concentration of an air pollutant to an observed health effect are the concentration and the duration of
the exposure to that particular air pollutant.
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The key issues associated with the construction, operation and decommissioning phases of the Clayville
Thermal Plant include:
Construction and decommissioning phase:
Construction work will entail building of new infrastructure and heavy construction work with concrete,
steel, piping, etc. Dust emissions during construction result mainly from earth moving activities (scraping,
compacting, excavation, grading), movement of construction vehicles and back-fill operations. Dust
emissions during decommissioning result from the demolition of structures, earth moving activities (scraping,
compacting, excavation, grading), movement of construction vehicles and back-fill operations.
All aspects of the construction and decommissioning inherently generate dust, but the movement of
construction vehicles on paved and unpaved surfaces at the construction site are generally the largest
source of dust. Construction vehicles will be in operation for the duration of the construction and
decommissioning. Dust is also easily entrained from exposed areas by the wind.
The impact of dust is considered to be more of a nuisance nature and does not typically pose a health risk
due to its typically coarse size. The impact of dust from the construction and decommissioning activities on
air quality is relatively short lived, i.e. limited to the duration of the construction or decommissioning
activities. The impacts are also expected to be localised and limited to the area adjacent to the activity.
Operation phase:
For the coal fines-only scenario, the ambient SO2, NO2, CO and PM10 concentrations resulting from the CFB
boiler stack emissions are predicted to be significantly below the NAAQS and no exceedances of the
respective standards are predicted. The significance of the impact on ambient air quality and human
health for the coal fines-only scenario is considered to be low.
For the Syngas and natural gas scenarios, the ambient SO2, NO2 and CO concentrations resulting from the
CFB boiler stack emissions are predicted to be significantly lower than the coal fines-only scenario and are
therefore well below the NAAQS and no exceedances of the respective standards are predicted. The
significance of the impact on ambient air quality and human health for the Syngas and natural gas
scenarios are considered to be low.
Several of the potential off-takers within the Clayville industrial area already make use of coal-fired boilers
on their site to produce steam to use in various direct and indirect processes within their plants. Other fuel
sources used by off-takers include diesel, HFO and gas. The installation of the Clayville Thermal Plant will
eliminate the need for small boilers on the off-taker’s sites and will therefore reduce different emission
sources from the various boilers within the area. This is considered to be a benefit in terms of air quality in
the area.
6.2.3 Impact table summarising the significance of impacts on the ambient air quality during
construction and operation (with and without mitigation)
Construction/Decommissioning Phase Impacts
Impact on ambient air quality and human health
Nature:
The impact of dust generated from construction and decommissioning activities do not typically pose health risks. It is
rather a nuisance impact due the typically coarse particle size. Due to relatively short duration of the activities, the
impact on ambient air quality and health is expected to be localised and limited to the construction or
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decommissioning period.
Without mitigation With mitigation
Extent Local (2) Site specific (1)
Duration Short term (1) Short term (1)
Magnitude Low (4) Low (4)
Probability Probable (3) Improbable (2)
Significance Low (21) Low (12)
Status (positive or negative) Negative Negative
Reversibility Low High
Irreplaceable loss of resources? No No
Can impacts be mitigated? Yes Yes
Mitigation:
» A dust management programme should be implemented during the construction and decommissioning phases of
the project. The programme should include dust control during construction and decommissioning such as
implementing appropriate dust suppression on unpaved site roads and open areas, sweeping paved areas, and
speed enforcement on-site.
Residual Risks:
The residual risk is of low significance, reversible with no loss of resources.
Operation Phase Impacts
The coal-fines only Scenario is considered to be the worst-case scenario and therefore any combination of
fuel sources which reduces the reliance on coal fines would result in emissions lower than those predicted
for the coal-fines only Scenario, resulting in a lower impact.
Impact on ambient air quality and human health
Nature:
The impact of emissions from the CFB boiler will increase ambient concentrations of PM10, SO2, NO2 and CO which
pose risk to human health.
Without mitigation With mitigation
Coal Fines Scenario Syngas Scenario Natural Gas Scenario All Scenarios
Extent Local (2) Local (2) Local (2) Local (2)
Duration Long term (4) Long term (4) Long term (4) Long term (4)
Magnitude Low (4) Minor to Low (3) Minor to Low (3) Minor to Low (3)
Probability Probable (3) Improbable (2) Improbable (2) Improbable (2)
Significance Medium (30) Low (18) Low (18) Low (18)
Status (positive
or negative)
Negative Negative Negative Negative
Reversibility Low Low Low High
Irreplaceable
loss of
resources?
No No No No
Can impacts
be mitigated?
Yes
Mitigation:
» The installation and operation of an Electrostatic Precipitator (ESP) for particulate reductions;
» The use of sorbent for SO2 reduction;
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» The progressive move from initially using coal fines to using clean fuels such as Syngas and natural gas.
» Maintenance of emission abatement devices according to design specifications.
Residual Risks:
The residual risk after the implementation of mitigation measures will be of low significance for the coal fines-only
scenario and lower for the gas scenarios with no loss of resources. rainfall
6.2.4 Implications for Project Implementation
The operation of the Clayville Thermal Plant will generate low emissions which will result in low ambient SO2,
NO2, CO and PM10 concentrations, and low ambient air quality impacts for the construction, operation
and decommissioning phases. The proposed development and associated infrastructure is unlikely to
result in permanent damage to ambient air quality, and poses a low risk to human health. With the
implementation of mitigation measures by the developer, contractors, and operational staff, the severity
of negative impacts can be mitigated to low significance, or avoided. The Clayville Thermal Plant can be
developed and impacts on air quality managed by taking the following into consideration:
» The installation and operation of an Electrostatic Precipitator (ESP) for the reduction of particulates.
» The use of sorbent for the reduction of SO2 emissions.
» The progressive move from initially using coal fines to using clean fuels such as Syngas and natural gas.
6.3. Potential Impacts on Heritage Features
The project site of 1.76ha has been assessed for the development of the Thermal Plant. Negative impacts
on heritage resources will be as a result of loss during construction activities. Potential impacts and the
relative significance of the impacts are summarised below (refer to Appendix E).
6.3.1 Results of Impact Assessment
The eastern section of the project site is occupied by Civcon Engineering Works and other businesses (refer
to Figure 6.2). These businesses occupy several buildings, workshops and storerooms. The remaining
section of the project site is vacant land. The site is considered to be largely disturbed by the
development of numerous modern buildings and infrastructure. No standing structures older than 60 years
were identified within the project site.
Figure 6.2: Built-up areas and existing buildings within the project site.
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The general area under investigation has a wealth of heritage sites and a cultural layering including LSA
scatters and numerous grave sites and cemeteries. No Stone Age or Iron Age artefacts, burial sites or
battlefield sites were identified within the project site. The cultural landscape of the greater area is
characterised by industrial developments and the project will not impact on significant viewscapes.
6.3.2 Description of Impacts
The pre-construction phase involves the removal of topsoil and vegetation (applicable to Erf 457 and
Portion 12 of Erf 508) as well as the establishment of infrastructure needed for the construction phase.
These activities can have a negative and irreversible impact on heritage sites. Impacts include destruction
or partial destruction of non-renewable heritage resources. During the construction phase, the impacts
and effects are similar in nature but more extensive than the pre-construction phase. These activities can
have a negative and irreversible impact on heritage sites and include the destruction or partial destruction
of non-renewable heritage resources.
No heritage features of significance were identified within the project site. The impact on heritage sites by
the development of the Clayville Thermal Plant and associated infrastructure is therefore considered to be
low. Any direct impacts that may occur would be during the construction phase only and would be of
very low significance.
6.3.3 Impact table summarising the significance of heritage impacts (with and without mitigation)
Impact on archaeological heritage resources:
Nature:
During the construction phase activities resulting in disturbance of surfaces and/or sub-surfaces may destroy, damage,
alter, or remove from its original position archaeological material or objects.
Without mitigation With mitigation
Extent Site specific (1) Site specific (1)
Duration Permanent (5) Permanent (5)
Magnitude Low (2) Low (2)
Probability Improbable (3) Improbable (3)
Significance Low (16) Low (16)
Status (positive or negative) Negative Negative
Reversibility Not reversible Not reversible
Irreplaceable loss of resources? No resources were recorded No resources were recorded
Can impacts be mitigated? Yes, a chance find
procedure should be
implemented.
Yes
Mitigation:
» A Chance Find Procedure should be implemented for the project site should any sites be identified during the
construction phase of the project.
Residual Risks:
If sites are destroyed, it will result in the depletion of archaeological record of the area. Should sites be recorded and
preserved or mitigated, it will add to the archaeological record of the area.
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6.3.4 Implications for Project Implementation
The significance of impacts on heritage sites due to the development of the Clayville Thermal Plant are
considered to be low with the implementation of mitigation measures by the developer, contractors, and
operational staff. From the outcomes of the Heritage Impact Assessment undertaken, it can be
concluded that the Thermal Plant can be developed and impacts on heritage resources managed with
the implementation of a Chance Find Procedure should any sites be identified during the construction
phase of the project. No other mitigation will be required.
6.4. Potential Impacts on Traffic
Access to the project site will be via existing roads – i.e. Spanner Road adjacent to the western boundary
of the project site and Industrial Road adjacent to the eastern boundary of the project site. The impact of
the proposed development on traffic from a national, regional and local perspective has been assessed
as of medium significance. Potential impacts and the relative significance of the impacts are summarised
below (refer to Appendix F – Traffic Impact Assessment Report for more details).
6.4.1 Results of Impact Assessment
The following characteristics were assessed as part of the Traffic Impact Assessment for the Clayville
Thermal Plant:
» Visual assessment of the project at the proposed access to the site taking into consideration the road
network and accessibility, road surface, the line markings of the road and the sight distance at the
access point.
» Accessibility to the site includes two-lane arterial roads characterised by signalised intersections that
provide access links to the industrial area as below:
The R562 which forms an important road link between the N1 to the west of Clayville industrial
area and the R21 to the east of Clayville Industrial Area.
The M18 which is considered to be a north-south orientated route, with mostly industrial related
traffic in the vicinity of the Clayville industrial area and lighter traffic volumes north of S View
Road. The M18 also provides access to the R562 to the south and to Nellmapius Drive to the
north of Clayville industrial area.
S View Road is a connector link between the R562 and Hoof Road. A high percentage of
traffic on this road link is generated by Clayville Industrial Area.
The road network in the vicinity of the project site is typical to many of the industrial developments,
comprising 8m wide two-lane roads centrally located in 25m wide road reserves. These roads are
characterised by a high number of site accesses, unkept road verges and a lack of pedestrian facilities,
apart from Nut Avenue that provides a paved sidewalk for pedestrians (along the northern road edge).
The road surfaces are premixed and are generally in a good condition. Some faded road markings are
evident in areas and should be addressed with regular maintenance. The road network in close proximity
to the proposed project site is described below:
» Access to the project site is attained via Spanner and Industry Roads. These north-south orientated
roads intersect with S View Road, some 1,0 km to the north of the project site.
» Nut Avenue and Nail Avenue provides east-west orientated links between Spanner and Industry Roads.
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The transportation routes to the site includes the R42, R50, R25, M57 and R562. Apart from the M57 (a
metropolitan route) the major portion of the route is along Regional (R) Routes. These Regional and
Metropolitan Routes carry mixed traffic and can readily accommodate the traffic impact of the Thermal
Plant.
Traffic counts on the Industry Road/Nut Avenue intersection at the weekday AM and PM peak periods
indicated that there is a fairly high traffic volume and that the traffic volume exceeds the capacity of a
four-way Stop controlled intersection. Traffic counts on the Industry Road/Nail Avenue intersection (three-
way Stop) at indicated low traffic volumes and can more readily accommodate the traffic impact of the
project.
6.4.2 Description of Impacts
Impacts on traffic will be most significant during the construction phase of the Thermal Plant due to an
increase of heavy vehicles on the regional and local road network of the area. However, based on the
expected traffic to be generated by the project, it is considered that the Clayville Thermal Plant
construction, operation and decommissioning traffic volumes are not significant and can be
accommodated on the affected road network with ease. The four-way stop controlled intersection of
Industry Road / Nut Avenue is however already over capacity and it is recommended that the intersection
be signalised. Therefore, it can be concluded that the development of the Clayville Thermal Plant will not
have a detrimental impact on traffic aspects and is appropriate and suitable from a traffic perspective.
6.4.3 Impact table summarising the significance of traffic impacts (with and without mitigation)
The impacts assessed below apply to the development of the Clayville Thermal Plant within the Clayville
industrial area and the associated access roads.
Construction Phase Impacts
Road safety impacts relating to the construction phase of the Thermal Plant
Nature:
During the construction phase (36 months) some heavy and abnormal load vehicles will transport equipment,
machinery and structural elements to site from Johannesburg via the National road network. Heavy and light vehicles
trips will impact on Industry Road in particular. There will be a low increase in traffic volumes impacting on traffic
congestion and road safety.
Without mitigation With mitigation
Extent Local to Regional (3) Local to Regional (3)
Duration Short-term (2) Short-term (2)
Magnitude Minor to low (3) Minor (2)
Probability Definite (5) Definite (5)
Significance Medium (40) Medium (35)
Status (positive or negative) Negative Negative
Reversibility Reversible Reversible
Irreplaceable loss of resources? No No
Can impacts be mitigated? Yes, mitigation should enhance road safety.
Mitigation:
» All construction vehicles must be road worthy.
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» All construction vehicle drivers must have the relevant licenses of the use of the vehicles and need to strictly
adhere to the rules of the road.
» Heavy vehicle and abnormal load vehicles should travel outside of commuter peaks where possible.
» Erect signage warning of construction vehicles at development access.
» Deploy flagmen at the access to enhance road safety when necessary where dealing with abnormal load
vehicles entering or leaving the project site.
Residual Risks:
Minor degradation of the national, metropolitan and regional road network.
Traffic impacts relating to intersection capacity during the construction phase of the Thermal Plant
Nature:
During the construction phase, Industry Road will carry the highest traffic flow to the project site. The intersection of
Industry Road / Nut Avenue is a four-way Stop controlled intersection which is already over capacity. Consequently,
any increase in traffic will have a more significant impact on vehicle delay at this intersection.
Without mitigation With mitigation
Extent Local (2) Local (2)
Duration Short-term (2) Short-term (2)
Magnitude Moderate (6) Minor (2)
Probability Definite (5) Definite (5)
Significance Medium (50) Medium (30)
Status (positive or negative) Negative Negative
Reversibility Reversible Reversible
Irreplaceable loss of resources? No No
Can impacts be mitigated? Yes, capacity improvements are already justified at Industry Road
/ Nut Avenue intersection and should be implemented to improve
the current situation, to the benefit of current road users and the
proposed development traffic as well.
Mitigation:
» Consult with the relevant authority regarding the upgrade of the Industry Road / Nut Avenue Multi-way stop
controlled intersection to a signalised intersection.
Residual Risks:
The traffic signals will attract Operating and Maintenance costs.
Operation Phase Impacts
Road safety impacts relating to the operation phase of the Thermal Plant
Nature:
During the operations phase, the affected road network leading to the project site will include trucks transporting coal
fines from Delmas and Middelburg Areas. There will be an insignificant increase in traffic volumes, including heavy
vehicles, contributing to overall traffic congestion and road safety.
Without mitigation With mitigation
Extent Local (2) Local (2)
Duration Short-term (2) Short-term (2)
Magnitude Minor (2) Minor (2)
Probability Definite (5) Highly probable (4)
Significance Medium (30) Low (24)
Status (positive or negative) Negative Negative
Reversibility Reversible Reversible
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Irreplaceable loss of resources? No No
Can impacts be mitigated? Yes
Mitigation:
» All transport vehicles must be road worthy.
» All vehicle drivers must have the relevant licenses of the use of the vehicles and need to strictly adhere to the rules
of the road.
» Heavy vehicles should travel outside of commuter peaks where possible.
» Trucks to be covered and properly sealed to retain coal fines and prevent it from spilling and blowing into the
roadway during transportation.
» Obtain bulk of Coal Fines from the Delmas Area as opposed to from Middleburg Area.
» Construct a deceleration lane on Industry Road to accommodate left-turn vehicles entering the development, or
introduce a second entry lane at the site access on Industry Road.
» Create additional access to the site via Spanner Road, to improve on-site manoeuvrability, to reduce right-turn
exit movements at the development access and to reduce traffic impact on Industry Road.
Residual Risks:
Minor degradation of the affected road network.
Traffic impacts relating to intersection capacity during the operation phase
Nature:
During the operations phase, Industry Road will carry the highest development traffic flow as it leads directly to the
project site. Industry Road / Nut Avenue intersection is a four-way stop controlled intersection and is already over
capacity. Consequently, any increase in traffic will have a more significant impact on vehicle operating costs (fuel
and maintenance) and vehicle delay (time).
Without mitigation With mitigation
Extent Local (1) Local (2)
Duration Short-term (2) Short-term (2)
Magnitude Moderate (6) Minor (2)
Probability Definite (5) Definite (5)
Significance Medium (45) Low (24)
Status (positive or negative) Negative Negative
Reversibility Reversible Reversible
Irreplaceable loss of resources? No No
Can impacts be mitigated? Yes, capacity improvements are already justified at Industry Road
/ Nut Avenue intersection and should be implemented to improve
the current situation, to the benefit of current road users and the
proposed development traffic as well.
Mitigation:
» Consult with the relevant authority regarding the upgrade of the Industry Road / Nut Avenue Multi-way stop
controlled intersection to a signalised intersection.
Residual Risks:
Operating and maintenance of traffic signals will be required.
Decommissioning Phase Impacts
Road safety impacts relating to the decommissioning phase of the Thermal Plant
Nature:
The road network surrounding the Thermal Plant will be affected. There will be an increase in traffic, impacting on
traffic congestion and road safety (light and heavy vehicles), however the extent of the impact will be of a local
nature. The traffic expected during the decommissioning phase will temporarily add an insignificant traffic volume to
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the road network.
Without mitigation With mitigation
Extent Local (1) Local (1)
Duration Very short duration (1) Very short duration (1)
Magnitude Minor (2) Minor (2)
Probability Highly probable (4) Probable (3)
Significance Low (16) Low (12)
Status (positive or negative) Negative Negative
Reversibility Reversible Reversible
Irreplaceable loss of resources? No No
Can impacts be mitigated? Yes, mitigation should enhance road safety.
Mitigation:
» All construction vehicles must be road worthy.
» All construction vehicle drivers must have the relevant licenses of the use of the vehicles and need to strictly
adhere to the rules of the road.
» Heavy vehicles should travel outside of commuter peaks where possible.
Residual Risks:
Minor degradation of the regional and local road network of the surrounding area.
6.4.4 Implications for Project Implementation
With the implementation of mitigation measures by the developer, contractors, and operational staff, the
severity of traffic impacts of the Thermal Plant can be reduced or avoided. The Thermal Plant can be
developed and impacts on traffic managed by taking the following into consideration:
» Road sign warning of construction vehicles at the development access should be erected on Industry
Road for the construction period.
» The development gate should be located at least 25m from the travelled way to accommodate
larger construction vehicles to and from the project site, and to accommodate access control during
the operational period.
» Abnormal Load Vehicles require Abnormal Load Permits to be obtained by the transport carrier.
» The developer should engage with the relevant authority regarding the installation of traffic signals at
the Industry Road/Nut Avenue intersection to improve the intersection performance.
» If possible, the applicant should obtain the bulk of coal fines from the Delmas Area as opposed to
from the Middleburg Area.
» The applicant should promote the use of public transport to workers during the operation phase.
6.5. Impacts related to the Storage and Handling of Dangerous Goods
During the operation phase, the Thermal Plant will require the storage of materials which may be
considered to be dangerous goods, including chemicals for the wastewater treatment plant and diesel.
"Dangerous goods" is defined under the Listing Notices that deal with the storage, or storage and handling,
of dangerous goods. "Dangerous goods" are defined in the Listing Notices as:
"Goods containing any of the substances as contemplated in South African National Standard No. 10234,
supplement 2008 1.00: designated “List of classification and labelling of chemicals in accordance with the
Globally Harmonized Systems (GHS)” published by Standards South Africa, and where the presence of
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such goods, regardless of quantity, in a blend or mixture, causes such blend or mixture to have one or
more of the characteristics listed in the Hazard Statements in section 4.2.3, namely physical hazards, health
hazards or environmental hazards".
The above definition makes specific reference to SANS 10234. South Africa has implemented the Globally
Harmonized System of Classification and Labelling of Chemicals by issuing this national standard. The
dangerous goods likely to be stored or handled on site would mainly include chemicals and diesel.
6.5.1 Description of Impacts associated with the Storage and Handling of Dangerous Goods
The operation of the Clayville Thermal Plant requires the storage of dangerous goods, including chemicals
and fuels for everyday operation. Infrastructure for storage and handling of a dangerous good will be
located in containers and will not exceed 80m³ (cubic metres). These substances will be stored on-site in
appropriate storage vessels within bunded areas/ on impervious surfaces. The storage and handling of
dangerous goods has the potential to result in soil and/or water contamination should any
spillages/leakages occur. This is considered to be the most significant risk, other than a direct risk to
personnel on site, which is an occupational health and safety issue and is considered in line with the OH&S
Act. While not all materials to be stored on site are considered to be hazardous (or have a hazard rating),
materials such as fuel and oils are flammable and also have the potential to cause fires, explosions,
damage to infrastructure, as well as injuries of staff.
6.5.2 Impact table summarising the significance of the storage and handling of dangerous goods (with
and without mitigation)
Soil and water contamination as a result of spillages and/or leakages
Nature:
Soil and water contamination due to the handling and storage of dangerous goods during the operation phases.
Without mitigation With mitigation
Extent Local (2) Local (2)
Duration Short-term (2) Short-term (2)
Magnitude High (8) Low (4)
Probability Probable (3) Improbable (2)
Significance Medium (36) Low (20)
Status (positive or negative) Negative Negative
Reversibility Reversible Reversible
Irreplaceable loss of resources? No No
Can impacts be mitigated? Yes Yes
Mitigation:
» Any spillages of dangerous substances must be contained as soon as possible, and remedial and clean-up actions
initiated immediately.
» Regular inspections of the permanent bunded areas for storage of dangerous goods must be undertaken
throughout the life cycle of the project.
» Appropriate spill kits must be available on site.
» Maintenance vehicles must have access to spill kits.
» An emergency spill response plan must be developed for implementation during the construction and the
operational phase. Personnel should be suitably trained to attend to any spills that may occur.
» A fire management plan must be developed for implementation during the construction and the operational
phase. Personnel must be suitably trained to manage any fires which may occur on site.
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» Flammable substances must be stored in enclosed containers away from heat, sparks, open flames, or oxidizing
materials.
» Develop a monitoring and leak detection procedure for monitoring of the chemical spillages.
Residual Risks:
If spillages occur and are not cleaned up, contamination can result in impacts which remain after decommissioning of
the project.
6.6. Assessment of the Do Nothing Alternative
The ‘Do-Nothing’ alternative is the option of not constructing the proposed Clayville Thermal Plant. Should
this alternative be selected, there would be no environmental impacts on the site due to the construction
and operation activities of a Thermal Plant utilising CFB boiler technology. In addition, any benefits
associated with the development of the project will also not be realised.
Benefits of the project are expected to include:
» The implementation of the proposed project would utilise an existing waste by-product as a fuel source
to generate steam while reducing emissions within the Clayville industrial area. Coal fines are
considered to be an unwanted waste by‐product from the coal mining industry. These fines have
presented a major disposal challenge to the mining industry throughout South Africa and are currently
being stored as coal dumps and slurry dams, which emit CO2. South Africa produces approximately
300 million tons of coal per year of which up to 20% consist of coal fines. The Clayville Thermal Plant will
utilise 420 480 tonnes per year of this waste by-product as a feedstock for a CFB boiler to produce
steam, therefore providing an opportunity to convert a mining liability into a revenue stream. This is
considered to be a benefit from an environmental perspective as this would result in a reduction of the
amount of coal fines stored, and a subsequent reduction in CO2 emissions associated with this storage.
» Several of the potential off-takers within the Clayville industrial area already make use of coal-fired
boilers on their site to produce steam to use in various direct and indirect processes within their plants.
Other fuel sources used by off-takers include diesel, HFO and gas. The installation of the Clayville
Thermal Plant will eliminate the need for small boilers on the off-taker’s sites and will therefore reduce
different emission sources from the various boilers within the area. This is considered to be a benefit in
terms of air quality in the area.
» The project will result in socio-economic benefits at the local and regional scale through job creation,
procurement of materials and provision of services and other associated downstream economic
development. These will persist during the pre-construction, construction and operational phases of
the project.
» The project is considered to be a suitable land use for the proposed site due to the low potential for
commercial agriculture, the fact that the site is zoned for Industrial Use, the site is located within Zone 5
of the GPEMF which is the industrial and commercial development focus zone, and the proximity to an
existing coal fines and gas resources.
» The recycling of wastewater will result in a reduction of wastewater being disposed of to the municipal
system, thereby reducing the pressure on these systems and impacts on the environment.
» The development of Erf 457 and Erf 12 of 508 provides an opportunity to manage and control the alien
plant species currently present within the site. This would reduce the risk of such species spreading in
the surrounding areas.
The implementation of the project is expected to result in a number of environmental costs, as detailed
within this report, and would include:
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» For the coal fines-only scenario an additive effect to the existing ambient concentrations is predicted
to be of low significance and negligible for the Syngas and natural gas options.
» Impacts on traffic are expected to occur and will be most significant during the construction phase of
the Thermal Plant due to an increase of heavy vehicles on the regional and local road network of
South Africa.
The benefits of the project are expected to occur at a regional and local level. The costs to the
environment occur at a site specific level and can largely be limited through the implementation of
mitigation measures. The no-go alternative will result in the above benefits not being realised and a
subsequent loss of income and opportunities to local people and the opportunity to lower emissions in the
Clayville industrial area. The no-go alternative for the development of the Thermal Plant is therefore not
considered as a desirable alternative.
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Assessment of Cumulative Impacts Page 100
CHAPTER 7: ASSESSMENT OF CUMULATIVE IMPACTS
Cumulative impacts in relation to an activity are defined in the 2014 EIA Regulations (GNR 326) as meaning
“the past, current and reasonably foreseeable future impact of an activity, considered together with the
impact of activities associated with that activity, that in itself may not be significant, but may become
significant when added to the existing and reasonably foreseeable impacts eventuating from similar or
diverse activities.”
The Clayville Thermal Plant may have effects (positive and negative) on the social environment and on the
people living in the broader study area (i.e. Tswelapele and Clayville East). The Thermal Plant is proposed
to be located within the Clayville industrial area, approximately 4,3km south east of Olifantsfontein. The
project site and the greater Clayville industrial area has been identified as an industrial area and falls
within Zone 5 (Industrial and Commercial Development Focus Area) as described by the Gauteng
Provincial Environmental Management Framework, 2014. As the area is earmarked for the development
of industrial industries, it can be expected that various industrial developments will take place in addition
to the already industrial nature of the area. A concentration of industrial development within an area will
ultimately concentrate the impacts (both positive and negative) in one area where the development of
the industrial sector is deemed suitable as well as beneficial for the surrounding communities.
It is important to follow a precautionary approach in accordance with NEMA to ensure that the potential
for cumulative impacts are considered and avoided where possible, even if the cumulative impacts
expected are limited in extent and considered as being of a low significance. This chapter provides an
assessment of the cumulative impacts expected to be associated with the Clayville Thermal Plant when
considered together with other similar industrial developments in the area.
7.1. Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended)
This chapter of the final EIA report includes the following information required in terms of Appendix 3:
Content of Environmental Impact Assessment reports:
Requirement Relevant Section
3(j) an assessment of each identified potentially
significant impact and risk , including (i) cumulative
impacts, (ii) the nature, extent, and consequences of
the impact and risk, (iii) the extent and duration of the
impact and risk, (iv) the probability of the impact and
risk occurring, (v) the degree to which the impact and
risk can be reversed, (vi) the degree to which the
impact and risk may cause irreplaceable loss of
resources and (vii) the degree to which the impact and
risk can be mitigated.
This chapter focuses on the assessment of the
cumulative impacts associated with the Clayville
Thermal Plant as a whole.
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7.2. Approach Taken to Assess Potential Cumulative Impacts
The cumulative impacts that have the potential to be compounded through the development of the
Clayville Thermal Plant and its associated infrastructure in proximity to other similar developments include
impacts such as those listed below. The role of the cumulative assessment is to test if such impacts are
relevant to the proposed project in the proposed location when considered together with other similar
developments. Potential impacts include:
» Unacceptable increase in emissions within the Clayville industrial area.
» Unacceptable risk to human health through impacts on air quality.
» Unacceptable impact on the traffic of the local area.
» Unacceptable loss of heritage resources.
The scale at which the cumulative impacts are assessed is important. For example the significance of the
cumulative impact on the regional or national economy will be influenced by similar developments
throughout South Africa, while the significance of the cumulative impact at a local scale will only be
influenced by industrial developments that are in close proximity to each other, i.e. industrial
developments within the Clayville industrial area in this instance.
The potential for cumulative impacts are summarised in the sections which follow and have been
considered within the detailed specialist studies, where applicable (refer to Appendices D – F).
The cumulative effects or impacts consider:
» Cumulative impacts associated with the location and nature of the project, i.e. a thermal plant
located within the Clayville industrial area on Erf 457, Erf 459 and Portion 12 of Erf 508;
» Cumulative impacts associated with other relevant approved or existing and proposed developments
within the surrounding area of the proposed Clayville Thermal Plant project site (refer to Figure 7.1).
The cumulative impacts of other known developments in the broader area and the Clayville Thermal Plant
are therefore qualitatively assessed in this Chapter. As these cumulative impacts are explored in more
detail, the trade-offs between promoting growth within the industrial sector versus the local and regional
environmental and social impacts and benefits can be considered.
The potential for cumulative impacts that could occur due to the development of the Thermal Plant in
proximity to other existing and proposed developments include impacts such as:
» Impacts on Air Quality and human health;
» Impacts on Archaeology and Heritage;
» Traffic Impacts.
In the sections below the potential cumulative impacts of other similar developments within the region are
assessed (proposed and operational). The discussion and associated conclusions must be understood in
the context of the uncertainty associated with the proposed development and the qualitative nature of
the assessment.
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Figure 7.1: Other relevant existing developments within the surrounding area of the Clayville Thermal Plant project site (refer to Appendix J for A3 Map).
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7.3. Cumulative Impacts Associated with the Development of the Clayville Thermal Plant
In the sections below the potential cumulative impacts of the Clayville Thermal Plant and other
developments are explored.
7.3.1. Potential Cumulative Impacts on Air Quality
The cumulative assessment aims to assess the additive effect of emissions from the proposed Clayville
Thermal Plant on existing ambient air quality in the area. For operations, the cumulative assessment utilised
the modelled (predicted) ambient concentrations for the Clayville Thermal Plant together with the
measured ambient concentrations of SO2, NO2 and PM10 at the Olifantsfontein and Tembisa monitoring
stations. In the absence of other measurements, the monitoring data at these two stations are deemed to
be representative of the assessment area.
v. Sulphur Dioxide (SO2)
The maximum predicted annual average SO2 concentration resulting from emissions from the proposed
Clayville Thermal Plant varies from 0.81 µg/m3 for S content of 1% to 1.62 µg/m3 for S content of 2% for the
coal fines-only scenario. The predicted SO2 concentrations will be negligible for Syngas and natural gas.
The measured ambient SO2 concentrations are relatively low and typically less than 20% of the annual
NAAQS. The SO2 emissions from the Clayville Thermal Plant will add only marginally to the existing ambient
concentrations in the area, and exceedances of the NAAQS are highly unlikely. As clean fuels are
introduced during the operation of the project (i.e. Syngas and natural gas), the impacts of SO2 will
decrease along with the additive effect.
vi. Nitrogen Dioxide (NO2)
The maximum predicted annual average NO2 concentration resulting from emissions from the proposed
Clayville Thermal Plant for the coal fines-only scenario is 0.77 µg/m3, and significantly less for Syngas and
natural gas. In residential areas surrounding the Clayville industrial area the predicted ambient
concentrations are very low relative to the NAAQS. Ambient monitoring at Olifantsfontein indicates
relatively high NO2 concentrations with exceedances of the NAAQS. The monitoring site is located
relatively close to major roads and the ambient concentrations can be attributed mostly to motor vehicle
emissions. At the Olifantsfontein monitoring station the NOX emissions from the Clayville Thermal Plant will
add less than 0.1 µg/m3 to the existing concentrations. At this monitoring site it is likely that exceedances
will continue to occur because of vehicle emissions. In residential areas the added effect due to the
Clayville Thermal Plant will be marginal and exceedances of the NAAQS are highly unlikely.
vii. Particulate Matter PM10
The maximum predicted annual average PM10 concentration resulting from emissions from the proposed
Clayville Thermal Plant for the coal fines-only scenario is very low. In the surrounding residential areas, the
predicted annual average concentrations are less than 0.1 µg/m3. Ambient PM10 is measured in Tembisa
where concentrations are high and exceed the NAAQS. This is mostly attributed to domestic fuel burning.
PM10 emissions from the proposed Clayville Thermal Plant will initially have a marginal additive effect on
existing concentrations. The effect will become negligible as clean fuels are introduced (i.e. Syngas and
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natural gas). Exceedances will continue to occur in Tembisa (and other areas because of domestic fuel
burning) regardless of initial emission of PM10 from the proposed Clayville Thermal Plant.
The risk associated with the Clayville Thermal Plant from an air quality and human health risk perspective is
therefore considered to be low and acceptable.
Nature:
Cumulatively impact is considered to be negative as a result of the increase in ambient concentrations of SO2, NO2
and PM10) due to the project related activities during operation. Elevated ambient concentrations of fine particulates
will likely result in negative human health impacts.
Overall impact of the proposed
project considered in isolation
Cumulative Impact of the project and
other projects in the area
Extent Local (1) Low (2)
Duration Long-term (4) Long-term (4)
Magnitude Minor (2) Minor to Low (3)
Probability Probable (3) Probable (3)
Significance Low (21) Low (27)
Status Negative Negative
Reversibility High Low
Irreplaceable loss of resources? No No
Can impacts be mitigated? Yes N/A
Confidence in findings: High
Mitigation:
ESP for particulates and sorbent injection for SO2 with devices operated and maintained within specification.
Several of the potential off-takers within the Clayville industrial area make use of small boilers on their site to
produce steam to use in various direct and indirect processes within their plants. Fuel sources used by off-
takers include coal, diesel, HFO and gas. The installation of the Clayville Thermal Plant will eliminate the
need for small boilers on the off-taker’s sites and could lead to the decommissioning of these boilers. This
will therefore reduce different emission sources from the various boilers within the area and concentrate it
to one source. This is considered to be a benefit in terms of air quality in the area.
7.3.2. Potential Cumulative Impacts on Archaeology and Heritage
In general, cumulative impacts on heritage resources (i.e. archaeology) are relatively insignificant in this
area as heritage resources are sparsely distributed.
From an archaeological perspective the impact of the development on the heritage landscape and sites
is considered as being of a low significance. No archaeological sites, burial sites, battlefield sites or
significant cultural landscapes or viewscapes were identified to be associated with the development of
the Clayville Thermal Plant. Due to the absence of significant heritage features in the project site and
broader area the development of the Thermal Plant does not present a risk to unacceptable loss of
heritage resources. Therefore, the contribution of the proposed project to the cumulative impact is
expected to be negligible. However, it must be considered that as developments take place within the
area the impact on the heritage landscape and sites of low heritage significance is increased as the sites
are potentially destroyed by the associated construction activities. It still remains important for
development within the area to observe mitigation measures such as a Chance Find Procedure, and to
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protect any sensitive heritage features where possible. Through the implementation of appropriate
mitigation measures for the Clayville Thermal Plant and other developments the cumulative impacts on
archaeological resources within the area can be considered as acceptable, without any unacceptable
loss or risks.
Nature:
The development of the project and other industrial developments within the industrial area may result in disturbance
of surfaces and/or sub-surfaces may destroy, damage, alter, or remove from its original position archaeological
material or objects.
Overall impact of the proposed
project considered in isolation
Cumulative Impact of the project and
other projects in the area
Extent Local (1) Low (1)
Duration Permanent (5) Permanent (5)
Magnitude Minor (2) Minor (2)
Probability Very Improbable (1) Very Improbable (1)
Significance Low (8) Low (8)
Status Negative Negative
Reversibility Not reversible Not reversible
Irreplaceable loss of resources? No No
Can impacts be mitigated? Yes Unknown
Confidence in findings: High
Mitigation:
A Chance Find Procedure should be implemented should any sites be identified.
7.3.3. Potential Cumulative Impacts on Traffic
The project site is situated within the Clayville industrial area which is earmarked for industrial use. It can be
expected that various industrial developments will take place in addition to the already industrial nature of
the area. Considering that the industrial area is an already extensively developed area, the road network
in the industrial area should, by design, be able to accommodate the increase in traffic due to the
expected increase in industrial development of the area.
Cumulative traffic impacts associated with the development of the Clayville Thermal Plant in relation to
future industrial developments is considered acceptable, without an unacceptable increase in impact.
Although the impact of the project in isolation is considered to be of low significance, the cumulative
impact of the project and other projects in the area will be of a medium significance. The industrial area
will require incremental and periodic upgrading of the metropolitan road network (links and intersections),
which is normal to development. It should however be noted that the Industry Road/Nut Avenue multi-
way Stop controlled intersection is already over capacity during peak periods and will require upgrading
(i.e. traffic signals).
Nature:
The road network surrounding the Clayville Thermal Plant will be slightly affected. There will be an increase in traffic
impacting on traffic congestion and road safety (light and heavy vehicles), however the extent of the impact will be
more of a local nature (where development traffic converges on Industry Road). The cumulative traffic impact of this
and future development of the surrounding industrial area will require incremental and periodic upgrading of the
metropolitan road network (links and intersections), which is normal to development.
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Overall impact of the proposed
project considered in isolation
Cumulative Impact of the project and
other projects in the area
Extent Local (1) Low (1)
Duration Permanent (5) Permanent (5)
Magnitude Minor (2) Minor to low (3)
Probability Probable (3) Highly probable (4)
Significance Low (24) Medium (36)
Status Negative Negative
Reversibility Not reversible Not reversible
Irreplaceable loss of resources? No No
Can impacts be mitigated? Yes Unknown
Confidence in findings: High
Mitigation:
» Encourage public transport patronage (employers can incentivise workers to travel by public transport by
subsidising public transport trips). Ideally the Local Authority should provide an attractive public transport service to
lure motorists out of their private vehicles and into public transport.
» Obtain bulk of Coal Fines from the Delmas Area as opposed to from the Middleburg Area.
7.4. Conclusions Regarding Cumulative Impacts
Cumulative impacts and benefits on various environmental receptors will occur to varying degrees with
the development of the industrial sector and other developments within South Africa. The degree of
significance of these cumulative impacts is difficult to predict without detailed studies based on more
comprehensive data/information on each of the receptors and the site specific developments. The
current study assesses the cumulative impacts associated with the Clayville Thermal Plant together with
other industrial developments within the area on the basis of current and best available information, with
precautionary assumptions taken into account.
The development of the Clayville Thermal Plant is considered as acceptable and without any
unacceptable loss or risk to the environmental and social aspects of the project site and the broader area.
The risk associated with the Clayville Thermal Plant from an air quality and human health risk perspective is
also considered to be of low significance.
As the project site is located within an industrial area and within Zone 5 (Industrial and Commercial
Development Focus Area) as described by the Gauteng Provincial Environmental Management
Framework 2014, it can be expected that various developments within this area will be taking place in
future as the area was identified as being suitable for these types of developments.
Considering the findings of the specialist assessments undertaken for the project, the cumulative impacts
for the Clayville Thermal Plant will be acceptable, without any unacceptable loss or risks and the majority
are rated as being of low significance.
Table 7.1 provides a summary of the expected cumulative impacts associated with the proposed Clayville
Thermal Plant on the identified project site.
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Table 7.1: Summary of the cumulative impact significance for the Clayville Thermal Plant
Specialist assessment Cumulative Impact Significance
(proposed project in isolation)
Cumulative Impact Significance
(proposed project and other
projects)
Air Quality Low Low
Archaeology Low Low
Traffic Low Medium
The role of the cumulative assessment is to test if such impacts are relevant to the Clayville Thermal Plant in
the proposed location. Considering the cumulative assessments undertaken for air quality, archaeology
and traffic, it can be concluded that the development of the Clayville Thermal Plant and other proposed
developments in the region are acceptable and will not result in an unacceptable loss or risk or an
increase of the impacts. The following can be concluded considering the Thermal Plant:
» The construction and operation of the proposed project will not result in an unacceptable risk to
human health through impacts on air quality, as is evidenced by the absence of exceedances of the
NAAQS for the various pollutants under consideration. The anticipated cumulative impacts of the
proposed project are therefore considered to be within acceptable limits from an air quality
perspective.
» The construction and operation of the proposed project will not result in an unacceptable loss of
archaeological or heritage resources, largely due to the absence of such sites within the development
area. The anticipated cumulative impacts of the proposed project are therefore considered to be
within acceptable limits from an archaeological and heritage perspective.
» The construction and operation of the proposed project will not result in an unacceptable impact on
the traffic of the local area, largely as a result of the location of the development site within an
industrial area. The Clayville Thermal Plant is considered acceptable when considering the potential
for impacts to traffic, and will not significantly impact on the national and regional road network of
South Africa and the areas surrounding the project site.
Based on a detailed evaluation, the cumulative impacts associated with the construction and operation
of the Clayville Thermal Plant and other developments in the region are considered to be acceptable.
The low potential for cumulative impacts and risks makes the location of this project site a desirable
location for further consideration provided that environmental impacts are mitigated to suitable standards
by strict control and implementation of the EMPr, as recommended within this final EIA Report.
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CHAPTER 8 CONCLUSIONS AND RECOMMENDATIONS
Bellmall Energy Project 325 (Pty) Ltd is proposing the installation of a thermal plant utilising a Circulating
Fluidised Bed (CFB) boiler in the Clayville industrial area near Olifantsfontein. The thermal plant, also
referred to as the central plant, is proposed on Erf 457, Erf 459 and Portion 12 of Erf 508 which is situated
within the Ekurhuleni Metropolitan Municipality. The proposed project is to be known as the Clayville
Thermal Plant and the development footprint of the facility will be appropriately placed within the project
site of approximately 1.76ha in extent.
The purpose of the central plant would be to provide steam to off-takers in the industrial area, thereby
eliminating the need for each of the off-takers to produce their own steam for use in various processes on
their various sites (including industrial production, power generation, etc.). It is proposed to utilise coal fines
in combination with syngas and/or natural gas as feedstock for the CFB boiler. The steam generation plant
will have a capacity of up to 240 tons of steam per hour which is an equivalent of up to 60 MWe.
The development of the thermal plant in the Clayville industrial area will provide the opportunity to utilise
an already available resource such as coal fines which are regarded as a waste by-product from coal
mining, as a fuel to produce steam for off-takers to utilise in various processes (i.e. direct heat, process
steam, power generation etc.). Potential steam off-takers include Aspen, Astral Foods, Clover SA, Sasko
Nestle R&R Ice cream, Norcros Johnson and Vesuvius.
Steam generated at the central plant will also be utilised to generate power via steam turbines. These
turbines will be owned by the various off-takers, and each turbine will be sized to each off-taker’s
requirements. Should the electricity output of an individual turbine exceed 10MW, an environmental
authorisation will be required to be obtained.
The conclusions and recommendations of this EIA are the result of the assessment of identified impacts by
a team of independent specialist consultants, and the parallel process of Public Participation. The Public
Participation process has been extensive and every effort has been made to include representatives of all
stakeholders in the broader study area. A summary of the recommendations and conclusions for the
Clayville Thermal Plant is provided in this Chapter.
8.1 Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact
Assessment Report, 2014 (as amended)
This chapter of the final EIA report includes the following information required in terms of Appendix 3:
Content of Environmental Impact Assessment reports:
Requirement Relevant Section
(k) where applicable, a summary of the findings and
recommendations of any specialist report complying
with Appendix 6 to these Regulations and an indication
as to how these findings and recommendations have
been included in the final assessment report.
A summary of the findings of the specialist reports are
included within section 8.4. The recommendations
made by the specialists are included in Chapter 6. A
summary of the recommendations for the Thermal Plant
is included in section 8.8.
(h)(x) a concluding statement indicating the location of
the preferred alternative development footprint within
No preferred alternative development locations within
the preferred project site have been identified for the
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Requirement Relevant Section
the approved site as contemplated in the accepted
Scoping Report.
Clayville Thermal Plant due to the lack of environmental
sensitivities within the site. The reasoning behind the
exclusion is included in section 8.4.
(l) an environmental impact statement which contains
(i) a summary of the key findings of the environmental
impact assessment, (ii) a map at an appropriate scale
which superimposes the proposed activity and its
associated structures and infrastructure on the
environmental sensitivities of the preferred site indicating
any areas that should be avoided, including buffers and
(iii) a summary of the positive and negative impacts and
risks of the proposed activity and identified alternatives.
An environmental impact statement (overall conclusion)
is included in section 8.7. A summary of the key findings
of the environmental impact assessment is included in
sections 8.4.1 – 8.4.4. A map superimposing the
proposed activities and its associated infrastructure on
the environmental sensitivities of the preferred
development area indicating sensitive receptors in close
proximity to the project site are included Figure 8.1. No
environmental sensitivities have been identified within
the project site. A summary of the costs (negative) and
benefits (positive) impacts and risks of the proposed
Clayville Thermal Plant is included in section 8.6.
(n) the final proposed alternatives which respond to the
impact management measures, avoidance and
mitigation measures identified through the assessment.
The final proposed alternatives for the Clayville Thermal
Plant which responds to the impact management
measures, avoidance and mitigation are included in
section 8.8.
(o) any aspects which were conditional to the findings
of the assessment either by the EAP or specialist which
are to be included as conditions of authorisation.
Conditions to be included in the authorisation of the
Clayville Thermal Plant are included in section 8.8.
(q) a reasoned opinion as to whether the proposed
activity should or should not be authorised, and if the
opinion is that it should be authorised, any conditions
that should be made in respect of that authorisation.
A reasoned opinion as to whether the Clayville Thermal
Plant should receive authorisation and the conditions
that should form part of the authorisation is included in
section 8.8.
8.2 Assessment Process
An Environmental Impact Assessment process, as defined in the NEMA EIA Regulations, is a systematic
process of identifying, assessing, and reporting environmental impacts associated with an activity. The EIA
process forms part of the planning of a project and informs the final design of a development. In terms of
the EIA Regulations published in terms of Section 24(5) of the National Environmental Management Act
(NEMA, Act No. 107 of 1998), Bellmall Energy Project 325 (Pty) Ltd requires authorisation from the Gauteng
Department of Agriculture and Rural Development (GDARD) for the installation of the Clayville Thermal
Plant.
The EIA process for the Clayville Thermal Plant has been undertaken in accordance with the EIA
Regulations of 2014 as amended, in terms of Section 24(5) of NEMA (Act No. 107 of 1998), and includes an
assessment of the activities associated with the construction and operation of the Thermal Plant. As part of
this EIA process comprehensive, independent environmental studies have been undertaken in
accordance with the EIA Regulations. The conclusions and recommendations of this EIA are the result of
the assessment of identified impacts by specialists and a parallel public participation process.
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The EIA Phase aimed to achieve the following:
» Provide an overall assessment of the social and biophysical environments affected by the proposed
project.
» Assess potentially significant impacts (direct, indirect and cumulative, where required) associated with
the proposed project.
» Identify and recommend appropriate mitigation measures for potentially significant environmental
impacts.
» Undertake a fully inclusive Public Participation process to ensure that Interested and Affected Parties
(I&APs) are afforded the opportunity to participate, and that their issues and concerns are recorded.
8.3 Overview of the Clayville Thermal Plant
The Clayville Thermal Plant utilising a Circulating Fluidised Bed (CFB) boiler will have the capacity to
generate up to 240 tons of steam per hour which is an equivalent of up to 60 MWe. The project site of
approximately 1.76ha in extent will comprise of the following infrastructure which has been included in the
scope of this EIA:
» CFB Boiler;
» Steam supply pipes from the central plant to various off-takers within the Clayville industrial area;
» Steam condensate return pipes to the central plant from various off-takers within the Clayville industrial
area;
» Exhaust stack located adjacent to the central plant;
» Condenser on site for the conversion of steam back to water;
» Wastewater treatment plant with a capacity of 6 000kl per day;
» Effluent pipes and clean water supply pipes connected from the central plant to 5 off-takers within the
Clayville industrial area;
» Holding tanks for the storage of water;
» Storage of diesel within permanent immobile liquid tanks;
» Silos for the storage of bottom ash, fly ash and limestone;
» Gas cylinders for the storage of syngas;
» Dome for the storage of coal fines;
» Feedstock holding and processing area;
» Ancillary infrastructure including access roads, maintenance building, access control facilities and
office.
The thermal plant will combine high-efficiency combustion of various solid fuels with low emissions, even
when burning fuels with completely different calorific values simultaneously. The feedstock is proposed to
include syngas/natural gas and coal fines. The coal fines will be sourced from mines within the Delmas
and Middelburg areas, and will be transported to the site via truck. Syngas will be sourced from the
Bellmall Energy Syngas Plant situated at remote locations, and will be transported to the site via truck.
Natural gas will be sourced from Sasol via an existing gas pipeline situated along Spanner Road (western
boundary of the project site) within the Clayville industrial area.
A central steam generation facility (or thermal plant) on the proposed site within the Clayville industrial
area is considered to be desirable as a result of the zoning of the site, the location of the site within Zone 5
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of the GPEMF, the opportunity to use a more efficient technology to raise steam compared to the
technologies currently used in the industrial area, the opportunity to reduce overall air emissions in the
industrial area, the opportunity to reduce reliance on heavy fuels and lower efficiency small boilers, the
availability of wastewater for treatment and use within the facility, and the opportunity to provide
employment.
8.4 Evaluation of the Proposed Project
The preceding chapters of this report, together with the independent specialist studies contained within
Appendices D to F, provide a detailed assessment of the environmental impacts on the social and
biophysical environment as a result of the proposed project, as identified through this EIA process. This
Chapter concludes the EIA process by providing a summary of the conclusions of the assessment of the
Clayville Thermal Plant and associated infrastructure. In doing so, it draws on information gathered as part
of the EIA process and the knowledge gained by the environmental consultants during the course of the
EIA, and presents an informed opinion of the environmental impacts associated with the proposed project,
as assessed by the team of independent specialist consultants.
From the conclusions of the detailed specialist studies undertaken, no fatal flaws, no-go areas or areas of
high sensitivity were identified within the project site (refer to Figure 8.1). Therefore, the entire project site
has been assessed as being suitable and appropriate from an environmental perspective for the
development and will not have a detrimental impact on any sensitive features present.
The potential environmental impacts associated with the proposed Thermal Plant include:
» Impacts on the air quality within the Clayville industrial area and associated impacts on human health;
» Impacts on traffic; and
» Impacts on archaeological resources.
8.4.1 Impacts on Air Quality and Human Health
Sensitive receptors (i.e. areas where the occupants are susceptible to the adverse effects of exposure to
air pollutants) have been identified within close proximity to the project site (refer to Figure 8.1 and
Appendix J):
» Clayville East (~1km east of the project site);
» Tswelapele (~1km west of the project site);
» Tembisa Provincial Hospital (~1.3km south of the project site);
» Clayville (~1.5 km north of the project site); and
» Olifantsfontein residential (~1.5 km south east of the project site).
The operation of the Clayville Thermal Plant will generate low emissions which will result in low ambient SO2,
NO2, CO and PM10 concentrations, and low ambient air quality impacts for the construction, operation
and decommissioning phase. The proposed development and associated infrastructure is therefore
unlikely to result in permanent damage to ambient air quality, and poses a low risk to human health.
Considering the results of the dispersion modelling and air quality impact assessment, the operation of the
Clayville Thermal Plant is expected to generate relatively low emissions from the CFB boiler for the coal
fines-only scenario, and significantly lower emissions for the Syngas and natural gas scenarios. These in
turn, result in ambient concentrations that are well below the NAAQS. Being a health-based standard,
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ambient concentrations below the standard imply that air quality poses an acceptable risk to human
health.
The installation of the Clayville Thermal Plant will eliminate the need for small boilers on the off-taker’s sites
and will therefore reduce different emission sources from the various boilers within the area. This is
considered to be a benefit in terms of air quality in the area.
The risk associated with the proposed development from an air quality and human health risk perspective
is therefore considered to be of low significance and acceptable. Recommended mitigation measures
must be implemented for the construction, operation and decommissioning phases in order to limit the risk
of any negative impacts.
8.4.2 Impacts on Heritage Resources
No significant archaeological, cultural landscape, built environment or battlefield sites were recorded on
the development site during the field surveys. No impacts on heritage resources are expected to occur
due to the development of the Clayville Thermal Plant. Based on the findings of the Heritage Assessment
the site is considered to be of low archaeological significance. The impact of the development of the
Clayville Thermal Plant on the archaeological nature of the site is considered to be of a low significance
with the implementation of the appropriate mitigation measures.
8.4.3 Impacts on Traffic
Impacts on traffic will be most significant during the construction phase due to an increase of heavy
vehicles on the existing road network. However, traffic volumes associated with the project are not
significant and can be accommodated on the existing road network with ease. However, the four-way
stop controlled intersection of Industry Road/ Nut Avenue is however already over capacity and it is
recommended that the intersection be signalised in consultation with the relevant roads authority. Overall
the impacts of the Thermal Plant on traffic will be of a medium to low significance with the implementation
of mitigation measures. It is concluded that the development of the Clayville Thermal Plant will not have a
detrimental impact on traffic or existing roads.
8.4.4 Cumulative impacts
Cumulative impacts and benefits on various environmental receptors will occur to varying degrees with
the development of the industrial sector and other developments within South Africa. The degree of
significance of these cumulative impacts is difficult to predict without detailed studies based on more
comprehensive data/information on each of the receptors and the site specific developments. The
current study assesses the cumulative impacts associated with the Clayville Thermal Plant together with
other industrial developments within the area on the basis of current and best available information, with
precautionary assumptions taken into account.
The potential for cumulative impacts are summarised in the sections which follow and have been
considered within the detailed specialist studies, where applicable (refer to Appendices D – F).
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The cumulative effects or impacts considered:
» Cumulative impacts associated with the location and nature of the project, i.e. a thermal plant
located within the Clayville industrial area on Erf 457, Erf 459 and Portion 12 of Erf 508;
» Cumulative impacts associated with other relevant approved or existing and proposed developments
within the surrounding area of the proposed Clayville Thermal Plant project site (refer to Figure 8.2).
Considering the cumulative assessments undertaken for air quality, archaeology and traffic, it can be
concluded that the development of the Clayville Thermal Plant and other proposed developments in the
region are acceptable and will not result in an unacceptable loss or risk or an increase of the impacts. The
following can be concluded considering the Thermal Plant:
» The construction and operation of the proposed project will not result in an unacceptable risk to
human health through impacts on air quality, as is evidenced by the absence of exceedances of the
NAAQS for the various pollutants under consideration. The anticipated cumulative impacts of the
proposed project are therefore considered to be within acceptable limits from an air quality
perspective.
» The construction and operation of the proposed project will not result in an unacceptable loss of
archaeological or heritage resources, largely due to the absence of such sites within the development
area. The anticipated cumulative impacts of the proposed project are therefore considered to be
within acceptable limits from an archaeological and heritage perspective.
» The construction and operation of the proposed project will not result in an unacceptable impact on
the traffic of the local area, largely as a result of the location of the development site within an
industrial area. The Clayville Thermal Plant is considered acceptable when considering the potential
for impacts to traffic, and will not significantly impact on the national and regional road network of
South Africa and the areas surrounding the project site.
As the project site is located within an industrial area and within Zone 5 (Industrial and Commercial
Development Focus Area) as described by the Gauteng Provincial Environmental Management
Framework 2014, it can be expected that various developments within this area will be taking place in
future as the area was identified as being suitable for these types of developments. The installation of the
Clayville Thermal Plant will eliminate the need for small boilers on the off-taker’s sites and will result in a
reduction of different emission sources from the various boilers within the area. This is considered to be a
benefit in terms of air quality in the area.
The low potential for cumulative impacts and risks makes the location of this project site a desirable
location for further consideration provided that environmental impacts are mitigated to suitable standards
by strict control and implementation of the EMPr, as recommended within this EIA Report.
Considering the findings of the specialist assessments undertaken for the project, cumulative impacts
range from a low to moderate significance and can be considered as both positive and negative. Based
on a detailed evaluation, the cumulative impacts associated with the construction and operation of the
Clayville Thermal Plant and other developments in the region are considered to be acceptable. The
implementation of the EMPr and recommended mitigation measures would assist in mitigating these
negative impacts to an acceptable level as well as enhancing the positive impacts to a beneficial level.
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Figure 8.1: Zoomed-out map of the sensitive receptors identified within close proximity to the project site (refer to Appendix J for A3 map).
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Figure 8.2: Other relevant existing developments within the surrounding area of the Clayville Thermal Plant project site (refer to Appendix J for
A3 Map).
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8.5 Environmental Costs of the Project versus Benefits of the Project
Environmental (natural environment, economic and social) costs can be expected at a local and site level
and are considered acceptable provided that the mitigation measures as outlined in the EMPr are
adhered to. These could include:
» The construction and operation of the Clayville Thermal Plant will initially have a marginal additive
effect on existing air emission concentrations during the use of coal fines as a feedstock and will
become negligible as clean fuels are introduced (i.e. Syngas and natural gas). The impacts
associated with the proposed development from an air quality and human health risk perspective is
therefore considered to be low.
» Traffic impacts associated with the development of the Clayville Thermal Plant which relate mainly to
an increase in traffic. The construction and future operations traffic volumes are moderate to low and
can be accommodated on the affected road network with ease.
These costs are expected to occur at a regional, local and site level and are considered acceptable
provided the mitigation measures as outlined in the EMPr are adhered to.
Benefits of the project include the following:
» The proposed project will utilise an existing waste by-product (i.e. coal fines) as a fuel source to
generate steam while reducing emissions within the Clayville industrial area which present a major
disposal challenge to the mining industry and are currently being stored as coal dumps and slurry
dams, which emit CO2. By utilising this waste by-product as a feedstock for a CFB boiler to produce
steam, provide an opportunity to convert a mining liability into a revenue stream. This is considered to
be a benefit from an environmental perspective as this would result in a reduction of the amount of
coal fines stored, and a subsequent reduction in CO2 emissions associated with this storage.
» The operation of the Clayville Thermal Plant will eliminate the need for small boilers on the off-taker’s
sites and will therefore reduce different emission sources from the various boilers within the area. This is
considered to be a benefit in terms of air quality in the area.
» The project will result in socio-economic benefits at the local and regional scale through job creation,
procurement of materials and provision of services and other associated downstream economic
development. These will transpire during the lifecycle of the development.
» The recycling of wastewater will result in a reduction of wastewater being disposed of to the municipal
system, thereby reducing the pressure on these systems and impacts on the environment.
» Development of the site provides an opportunity to manage and control the alien plant species
currently present within the site. This would reduce the risk of such species spreading in the surrounding
areas.
The benefits of the project are expected to occur at a national, regional and local level. These benefits
offset the localised environmental costs of the project, which are considered to be of moderate to low
significance.
8.6 Overall Conclusion (Impact Statement)
The findings of the independent specialist studies undertaken within this EIA to assess both the benefits and
potential negative impacts anticipated as a result of the proposed project conclude that:
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» Impacts associated with the construction and operation of Clayville Thermal Plant and associated
infrastructure are expected to be of medium to low significance with the implementation of
appropriate mitigation measures.
» The operation of the project will reduce emissions from the various small boilers within the area.
» The project will reduce the pressure on municipal systems and impacts on the environment by
recycling wastewater currently being disposed of into the municipal system.
» The Thermal Plant will assist the municipality in reducing the level of unemployment through the
creation of jobs and supporting local business in a Municipality with a 28.8% unemployment rate.
» The project supports the creation of local employment, business opportunities and skills development
for the surrounding area.
» No environmental fatal flaws were identified to be associated with the proposed project provided that
the recommended mitigation measures are implemented.
The findings of the specialist studies undertaken within this EIA to assess both the benefits and potential
negative impacts anticipated as a result of the proposed project conclude that there are no
environmental fatal flaws that should prevent the Clayville Thermal Plant from proceeding, provided that
the recommended mitigation and management measures are implemented. The significance levels of
the majority of identified negative impacts have been reduced by implementing the mitigation measures
recommended by the specialist team during the EIA process. Environmental specifications for the
management of potential impacts are detailed within the draft Environmental Management Programme
(EMPr) for the Thermal Plant which is included within Appendix H.
With reference to the information available at this planning approval stage in the project cycle, the
confidence in the environmental assessment is regarded as acceptable, provided all measures are taken
to protect and preserve the surrounding environment.
8.7 Overall Recommendation
Based on the nature and extent of the proposed project, the local level of disturbance, the benefits
expected, the findings of the EIA, and the understanding of the significance level of potential
environmental impacts, it is the opinion of the EIA project team that the project can proceed on condition
that the mitigation measures specified in Chapters 6 of the EIA Report, the independent specialist Impact
Assessments contained within Appendices D to F, and those provided within the EMPr contained within
Appendix H of this EIA report are observed and implemented.
The following key conditions would be required to be included within an authorisation issued for the
project:
» All mitigation measures detailed within this report, as well as the specialist reports contained within
Appendices D to F, must be implemented.
» The Environmental Management Programme (EMPr) as contained within Appendix H of this report
must form part of the contract with the Contractors appointed to construct, operate and maintain the
Clayville Thermal Plant, and must be used to ensure compliance with environmental specifications and
management measures. The implementation of this EMPr for all life cycle phases of the project is
considered key in achieving the appropriate environmental management standards as detailed for
this project.
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» The applicant should include the installation and operation of an Electrostatic Precipitator (ESP) for the
reduction of particulates and utilise sorbent for the reduction of SO2 emissions for the Thermal Plant.
» There should be a progressive move from initially using coal fines to using clean fuels such as Syngas
and natural gas during the operation phase of the project.
» The developer should engage with the relevant authority regarding the installation of traffic signals at
the Industry Road/Nut Avenue intersection to improve the intersection performance.
» A left-turn deceleration lane on Industry Road for vehicles entering the development or a second entry
lane should be introduced. Additional access to the site via Spanner Road can be created, to
improve on-site manoeuvrability, to reduce right-turn exit movements at the development access and
to reduce traffic impact on Industry Road.
» A letter confirming the availability of water and sanitation services must be obtained from the City of
Ekurhuleni prior to construction.
» A grievance mechanism procedure should be implemented through which I&APs can communicate
with the developer to ensure the protection of the constitutional rights of communities in the area
including the rights of neighbouring industries and businesses.
» Following the final design of the facility, a revised layout must be submitted to the GDARD for review
and approval prior to commencing with construction.
» A Chance Find Procedure should be implemented for the project site should any sites be identified
during the construction phase of the project. Should unmarked graves, buried archaeological or
palaeontological heritage resources be found during construction they should be reported to SAHRA
immediately.
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References Page 119
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