proposed development of a cellulose recovery plant and ... · reg. no. 2000/000392/07 po box 6002...

Zitholele Consulting Reg. No. 2000/000392/07

PO Box 6002 Halfway House 1685, South Africa Building 1, Maxwell Office Park, Magwa Crescent West c/o Allandale Road & Maxwell Drive, Waterfall City, Midrand T : 011 207 2060 F : 086 674 6121 E : [email protected]

FINAL BASIC ASSESSMENT REPORT:

Proposed development of a cellulose recovery plant and related infrastructure for the recovery of pre- and post-

consumer newsprint in Wadeville, Gauteng Province

GDARD Reference No.: 002/19-20/W0014

Report No : 18028-46-Rep-001-Fibre Plant FBAR-Rev1

Compiled on behalf of:

Nature Africa RF (Pty) Ltd

1 Wadestone Industrial Park Lamp Road (Cnr Chaperone Road)

Wadeville, Germiston Gauteng

1428

Submitted to:

Gauteng Department of Agriculture and Rural Development

P.O. Box 8769 Johannesburg

2000

15 November 20019 18028

Zitholele Consulting Reg. No. 2000/000392/07

PO Box 6002 Halfway House 1685, South Africa Building 1, Maxwell Office Park, Magwa Crescent West c/o Allandale Road & Maxwell Drive, Waterfall City, Midrand T : 011 207 2060 F : 086 674 6121 E : [email protected]

DOCUMENT CONTROL SHEET

Project Title: Proposed development of a cellulose recovery plant and related infrastructure for the recovery of pre- and post-consumer newsprint in Wadeville, Gauteng Province

Project No: 18028 Document Ref. No: 18028-46-Rep-001-Fibre Plant FBAR-Rev1

DOCUMENT APPROVAL

ACTION DESIGNATION NAME DATE SIGNATURE

Prepared Project Manager Mathys Vosloo 21/10/2019

Reviewed Project Associate Tebogo Mapinga 22/10/2019

Approved Divisional Manager Mathys Vosloo 23/10/2019

RECORD OF REVISIONS

Date Revision Author Comments

23/10/2019 0 Mathys Vosloo Draft BAR released for public review

14/11/2019 1 Mathys Vosloo Corrections and comments incorporated into Final BAR. Final BAR submission to GDARD

15 November 20019 iii 18028

The addition of information or changes to the text, sentences or paragraphs resulting from comments received during the Draft Basic Assessment Report review period has been indicated in underlined text.

15 November 20019 iv 18028

TABLE OF CONTENTS

SECTION PAGE

EXECUTIVE SUMMARY ............................................................................................ 1 1 Project and application details ................................................................................ 1

1.1 Introduction .......................................................................................................................... 1 1.2 Details of applicant .............................................................................................................. 1 1.3 Details of landowner ............................................................................................................ 2 1.4 Local Municipality ................................................................................................................ 2 1.5 Competent Authority ........................................................................................................... 2 1.6 Details of EAP ..................................................................................................................... 2 1.7 Property details ................................................................................................................... 3 1.8 Description of the Study Area ............................................................................................. 3 1.9 Development site................................................................................................................. 4 1.10 Existing authorisations ........................................................................................................ 5 1.11 Listed Activities triggered by the development .................................................................... 6 1.12 Need and desirability of the proposed development ........................................................... 7

2 Development proposal ............................................................................................. 8 2.1 Description of the proposed development .......................................................................... 8 2.2 Waste generation .............................................................................................................. 11 2.3 Potential emissions ........................................................................................................... 11 2.4 Potential noise generation ................................................................................................. 12 2.5 Bulk services ..................................................................................................................... 12 2.6 Consideration of Alternatives ............................................................................................ 12 2.7 Sustainable Development Considerations ........................................................................ 13

3 Description of study area ....................................................................................... 13 3.1 Site Screening Report (DEA Screening Tool) ................................................................... 13 3.2 Historical environmental sensitivity ................................................................................... 15 3.3 Existing environmental sensitivity ..................................................................................... 19 3.4 Gauteng Pollution Buffer Zone Guideline ......................................................................... 19 3.5 Site access and traffic ....................................................................................................... 19

4 Impact identification and assessment .................................................................. 20 4.1 Pre-construction Phase ..................................................................................................... 20 4.2 Construction Phase ........................................................................................................... 20 4.3 Operational Phase............................................................................................................. 22 4.4 Decommissioning Phase ................................................................................................... 23 4.5 No-Go Option .................................................................................................................... 23 4.6 Cumulative Impacts ........................................................................................................... 23

5 Conclusion and recommendations ....................................................................... 24 5.1 Environmental Impact Statement ...................................................................................... 24 5.2 Environmental Impact Summary ....................................................................................... 25 5.3 Recommendation of the EAP ............................................................................................ 25 5.4 Period for which the environmental authorisation is required ........................................... 25

BASIC ASSESSMENT REPORT IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT NO. 107 OF 1998), AS AMENDED, AND THE ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS, 2014 (VERSION 1) .............................................................. 26

SECTION A: ACTIVITY INFORMATION ........................................................................ 28 1. PROPOSAL OR DEVELOPMENT DESCRIPTION ................................................................. 28 2. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES .......................................... 28 3. ALTERNATIVES....................................................................................................................... 31 4. PHYSICAL SIZE OF THE ACTIVITY ....................................................................................... 37 5. SITE ACCESS .......................................................................................................................... 37 6. LAYOUT OR ROUTE PLAN ..................................................................................................... 39 7. SITE PHOTOGRAPHS ............................................................................................................ 40 8. FACILITY ILLUSTRATION ....................................................................................................... 40

SECTION B: DESCRIPTION OF RECEIVING ENVIRONMENT ..................................... 41

15 November 20019 v 18028

1. PROPERTY DESCRIPTION .................................................................................................... 41 2. ACTIVITY POSITION ............................................................................................................... 41 3. GRADIENT OF THE SITE ........................................................................................................ 42 4. LOCATION IN LANDSCAPE .................................................................................................... 42 5. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE .............................. 42 6. AGRICULTURE ........................................................................................................................ 43 7. GROUNDCOVER ..................................................................................................................... 43 8. LAND USE CHARACTER OF SURROUNDING AREA ........................................................... 45 9. SOCIO-ECONOMIC CONTEXT ............................................................................................... 46 10. CULTURAL/HISTORICAL FEATURES ................................................................................. 46

SECTION C: PUBLIC PARTICIPATION (SECTION 41) ................................................. 48 1. LOCAL AUTHORITY PARTICIPATION ................................................................................ 48 2. CONSULTATION WITH OTHER STAKEHOLDERS ............................................................ 49 3. GENERAL PUBLIC PARTICIPATION REQUIREMENTS .................................................... 50 4. APPENDICES FOR PUBLIC PARTICIPATION .................................................................... 50

SECTION D: RESOURCE USE AND PROCESS DETAILS ........................................... 51 1.WASTE, EFFLUENT, AND EMISSION MANAGEMENT .......................................................... 51 2.WATER USE ............................................................................................................................. 53 3.POWER SUPPLY ...................................................................................................................... 53 4.ENERGY EFFICIENCY ............................................................................................................. 54

SECTION E: IMPACT ASSESSMENT ............................................................................ 55 1.ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES ............................................ 55 2.IMPACTS THAT MAY RESULT FROM THE CONSTRUCTION AND OPERATIONAL PHASE ...................................................................................................................................................... 55 3.IMPACTS THAT MAY RESULT FROM THE DECOMMISSIONING AND CLOSURE PHASE 66 4.CUMULATIVE IMPACTS .......................................................................................................... 67 5.ENVIRONMENTAL IMPACT STATEMENT .............................................................................. 68 6.IMPACT SUMMARY OF THE PROPOSAL OR PREFERRED ALTERNATIVE ....................... 69 7.SPATIAL DEVELOPMENT TOOLS .......................................................................................... 69 8.RECOMMENDATION OF THE PRACTITIONER ..................................................................... 69 9.THE NEEDS AND DESIRABILITY OF THE PROPOSED DEVELOPMENT............................ 70 10. THE PERIOD FOR WHICH THE ENVIRONMENTAL AUTHORISATION IS REQUIRED .... 70 11. ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPr) ................................................ 70

SECTION F: APPENDIXES ............................................................................................ 71

15 November 20019 vi 18028

LIST OF FIGURES

Figure 1: Location of the proposed development site ......................................................................... 1

Figure 2: Aerial image of the development site as at 04/12/2018....................................................... 4

Figure 3: Manufacturing process flow diagram ................................................................................. 10

Figure 4: Historic environmental sensitivity of the development site ................................................ 16

Figure 5: Current environmental sensitivity of the development site ................................................ 17

Figure 6: Gauteng Pollution Buffer Zone for the proposed development site ................................... 18

Figure 7: Security controlled entrance to Wadestone Industrial Park ............................................... 19

Figure 8: Facility layout ..................................................................................................................... 33

Figure 9. Example of a Tautliner truck and trailer ............................................................................. 33

Figure 10: Fibre mat product ............................................................................................................. 34

Figure 11: Manufacturing Process Flow ........................................................................................... 35

LIST OF TABLES

Table 1: Details of applicant and designated contact person ............................................................. 1

Table 2: Details of the landowner ....................................................................................................... 2

Table 3: Details of local municipality ................................................................................................... 2

Table 4: Details of the Competent Authority ....................................................................................... 2

Table 5: Details of the independent EAP ............................................................................................ 3

Table 6: Details of the properties ........................................................................................................ 3

Table 7: Corner point coordinates of proposed development site ...................................................... 5

Table 8: Details of existing authorisations associated with development properties .......................... 5

Table 9: Listed activities triggered by the proposed development ...................................................... 6

Table 10: Waste type and quantities to be generated ...................................................................... 11

Table 11: Proposed development area environmental sensitivity .................................................... 14

Table 12: Proposed specialist assessments and needs motivation ................................................. 14

Table 13: Potential impacts, mitigation and impact significance for construction phase .................. 21

Table 14: Potential impacts, mitigation and impact significance for operational phase ................... 22

Table 15 :Extent of the Impacts ........................................................................................................ 55

Table 16 : Duration of the Impacts .................................................................................................... 55

Table 17 : Negative Potential Impacts .............................................................................................. 56

Table 18 : Positive Potential Impacts ................................................................................................ 56

Table 19 : Likelihood of Impacts ....................................................................................................... 56

Table 20 : Significance Assessment ................................................................................................. 57

15 November 20019 vii 18028

LIST OF APPENDICES Appendix A: Maps and Plans

Appendix A-1: Locality Map Appendix A-2: Site and Layout Plan Map Appendix A-3: Cadastral and Neighbouring Properties Map Appendix A-4: Ward delineation Map Appendix A-5: Infrastructure, Bulk Services and Servitudes Map Appendix A-6: Historic Site Sensitivity Map Appendix A-7: Current Site Sensitivity Map Appendix A-8: Gauteng Pollution Buffer Zone Map Appendix A-9: Geology Map Appendix A-10: Topographical Map

Appendix B: Photographs Appendix C: Facility illustration(s) Appendix C-1: Site Plan Drawing Appendix C-2: Fence Position Layout Appendix C-3: Plant Layout Drawing

Appendix C-4: Plant Air Ring Main Drawing Appendix C-5: Manufacturing process flow diagram

Appendix D: Route position information Appendix E: Public participation information

Appendix E-1: Proof of site notice Appendix E-2: Written notices issued as required in terms of the regulations Appendix E-3: Proof of newspaper advertisements Appendix E-4: Communications to and from interested and affected parties Appendix E-5: Minutes of any public and/or stakeholder meetings Appendix E-6: Comments and Responses Report Appendix E-7: Comments from I&APs on Basic Assessment (BA) Report Appendix E-8: Comments from I&APs on amendments to the BA Report Appendix E-9: Copy of the register of I&APs

Appendix F: Water use license(s) authorisation, SAHRA information, service letters from municipalities, water supply information

Appendix F-1: Enviroserve Quotation Appendix F-2: Bulk Services Letter Appendix F-3: Bulk Water and Sewer Report Appendix F-4: Roads and Stormwater information Appendix F-5: Bulk Water Supply Layout Drawing Appendix F-6: Bulk Stormwater Infrastructure Layout Drawing

Appendix G: Specialist reports Appendix G-1: Air Quality Assessment Opinion Letter Appendix G-2: Noise Assessment Opinion Letter Appendix G-3: Traffic Impact Assessment (part of GAUT: 002/17-18/E2053) Appendix G-4: Memo: Peak hour traffic calculations and assumptions Appendix G-5: Screening Report – Development footprint Appendix G-6: Screening Report – Development footprint 500m buffer

Appendix H: EMPr Appendix I: Other information

Appendix I-1: Wadeville Extension 50 Environmental Authorisation Appendix I-2: Wadeville Extension 51 Basic Assessment Report Appendix I-3: Wadeville Extension 51 Environmental Management Plan Appendix I-4: Wadeville Extension 51 GPEMF Letter (GPEMF19-20/0012) Appendix I-5: Detailed Impact Assessment Matrix Appendix I-6: Property information - affected properties Appendix I-7: Property information – Klippoortje 110 IR Ptn 215 Appendix I-8: CV of EAP

15 November 20019 viii 18028

LIST OF ACROYNYMS

Acronym Description

BA Basic Assessment

BAR Basic Assessment Report

CA Competent Authority

CAFT Carding Airlaid Fusion Technology

DWS Department of Water and Sanitation

EA Environmental Authorisation

EAP Environmental Assessment Practitioner

EIA Environmental Impact Assessment

EMPr Environmental Management Programme

GDACE Gauteng Department of Agriculture, Conservation and Environment

GDARD Gauteng Department of Agriculture and Rural Development

GHS Globally Harmonized System

GPEMF Gauteng Provincial Environmental Management Framework

HDA Housing Development Agency

HMI Human Machine Interface

NEMA National Environmental Management Act 107 of 1998 (as amended)

NEMWA National Environmental Management Waste Management Act 59 of 2008

HMI Human Machine Interface

NWA National Water Act 36 of 1998

OHS Occupational Health and Safety Act 85 of 1993

PAIA Promotion of Access to Information Act 2 of 2000

PPP Public Participation Process

TIA Traffic Impact Assessment

TPD Tons per day

TPM Tons per month

WML Waste Management Licence

WUL Water Use Licence

WULA Water Use Licence Application

15 November 20019 1 18028

Executive Summary

1 PROJECT AND APPLICATION DETAILS

1.1 Introduction

Naturecell Africa RF (Pty) Ltd is proposing to establish a cellulose recovery plant within an existing

industrial park known as Wadestone Industrial Park in Wadeville, Gauteng Province. The proposed

activity is located within an existing industrial area and falls within the jurisdiction of the Ekurhuleni

Metropolitan Municipality (Figure 1).

Figure 1: Location of the proposed development site

1.2 Details of applicant

The applicant for this Waste Management Licence (WML) Application is Mr Themba Mtombeni,

representing Naturecell Africa RF (Pty) Ltd (hereafter Naturecell). Details of the applicant and

designated contact person are provided in Table 1.

Table 1: Details of the applicant and designated contact person

Name of Applicant Mr Themba Mtombeni

Company Naturecell Africa RF (Pty) Ltd

Designated contact person Mr Andrew Scott

Trading name (if applicable) Naturecell

Company Registration 2012/047104/07

Physical address 1 Wadestone Industrial Park, Lamp Road (Cnr Chaperone Road), Wadeville, Germiston, Gauteng Province, 1428

Postal address PO Box 14903, Wadeville, 1422

Telephone 010 141 0246

Fax 086 476 6213

E-mail [email protected]

Wadestone Industrial Park

Image date: 05/05/2019

15 November 20019 2 18028

1.3 Details of landowner

The properties within which the proposed development is located are owned by Growthpoint Properties

Ltd, which is represented by Mr Errol Taylor. Details of the landowner are provided in Table 2.

Table 2: Details of the landowner

Name of Landowner Mr Errol Taylor

Company name Growthpoint Properties Ltd

Designated contact person Mr Errol Taylor


Physical address 1 Sandton Drive, Sandton

Postal address PO Box 78949, Sandton, 2146


Fax 011 944 6005

E-mail: [email protected]

1.4 Local Municipality

The proposed development falls within Ward 40 in the Ekurhuleni Metropolitan Municipality. Details of

the local municipality are provided in Table 3.

Table 3: Details of the local municipality

Province Gauteng Province

Municipality Ekurhuleni Metropolitan Municipality

Physical address Head Office, 15 Queen Street, Germiston

Postal address Private Bag X1069, Germiston, 1400

Telephone 011 999 5000 / 086 054 3000

Fax 011 999 1811

Ward 40

Ward Councillor Ms. Sibongile Martha Buthelezi


1.5 Competent Authority

The Competent Authority for this WML Application is the Gauteng Department of Agriculture and Rural

Development (GDARD). Details of the Competent Authority is provided in Table 4.

Table 4: Details of the Competent Authority

Competent Authority Gauteng Department of Agriculture and Rural Development (GDARD)

Contact person Mr Tendani Rambuda

Postal address PO Box 8769, Johannesburg, 2001


Fax 011 240 2619 / 086 420 2187


1.6 Details of EAP

Naturecell has appointed Zitholele Consulting (Pty) Ltd (hereafter Zitholele) as an independent

Environmental Assessment Practitioner (EAP) to compile and submit the WML Application on behalf of

Naturecell, the applicant. Details of the EAP is provided in Table 5.

15 November 20019 3 18028

Table 5: Details of the independent EAP

Name of EAP Dr Mathys Vosloo

Professional registration SACNASP (Pr.Sci.Nat – 400136/12)

Company name Zitholele Consulting (Pty) Ltd


Physical address Building 1, Maxwell Office Park, Magwa Crescent West, Waterfall City, Midrand

Postal address PO Box 6002, Halfway House,1685


Fax 086 674 6121

Email Address [email protected]

Dr Vosloo is a well-qualified and technically proficient environmental and natural scientist with 10 years’

scientific research experience and 14 years of environmental management and consulting experience.

Dr Vosloo holds a PhD in Zoology and is furthermore a registered Professional Natural Scientist

(Pr.Sci.Nat.) with the South African Council for Natural Scientific Professionals (SACNASP). His

experience ranges from Waste Management Services, Environmental Impact Assessments and

Environmental Control Officer (ECO) services to project management and State of the Environment

Reporting (SOER). Mathys recently played a pivotal role in developing and compiling a Regulation 9

exemption application in terms of the National Environmental Management: Waste Act (59 of 2008) to

exempt certain waste management activities associated with the re-use of ash from coal-fired power

stations. Dr Vosloo’s CV is attached in Appendix I-8.

1.7 Property details

The proposed site is located on Portion 273 of the Farm Kilppoortie 110 IR and Erf 876 Wadeville X 50.

The properties are located north of Moore street, east of Arnold Road, south of Lamp / Snapper street

and west of Osborn road. The site is very well suited to industrial uses due to its location within an

existing industrial node along the N17 Freeway. Details of the properties included in this WML

Application are included in Table 6. Title deed information relating to the properties in question is

provided in Appendix I-6.

Table 6: Details of the properties

Erf /Farm name Klippoortje 110 IR 876, Wadeville X50

Portion number(s) 273 0

SG 21-digit numbers T0IR00000000011000273 T0IR07090000087600000

Current Land Use Industrial 1 Industrial 1

Property Owner Growthpoint Prop Ltd Growthpoint Prop Ltd

Extent (ha) 1.1246 8.9298

Centre Coordinates 28°11'35.333" E, 26°16'26.627" S 28°11'41.789" E, 26°16'28.764" S

1.8 Description of the Study Area

The study area is located within the suburb of Wadeville, Germiston. The surrounding area is classified

as industrial/light industrial with several medium and large-scale industries located in the area.

Immediate neighbours to the proposed development site include Abeyla Trading (steel manufacturing

plant) and Brocsell Industries (heavy engineering and manufacturing) located to the south of the

development site. Bliss Brands and a pipe and iron storage yard are located to the west, while

engineering and manufacturing companies including Transital Engineering, Siyahamba Engineering,

15 November 20019 4 18028

Drava Engineering and I & J Aluminium are located north of the development site. The Wadeville Fire

Station and Wadeville Licencing Centre are located to the east of the development site.

Further afield, the closest suburbs to the development site are Klippoortjie Agricultural Holdings (~2km

southeast), Buhle Park (~1.6km to the south), Elspark (~2.2km to the east), Estera and Eslburg (~2.7km

north) and Dinwiddie (~3km northwest).

1.9 Development site

The development site is located within an existing and developing industrial park known as Wadestone

Industrial Park. Although tenants have already established in the industrial park, adjacent plots within

the park are being prepared for construction of warehousing facilities for future tenants. The applicant

has secured one of these plots under development for the development of the proposed fibre recovery

and manufacturing plant. An aerial image from Google Earth (Figure 2), dated 12 December 2018,

shows the proposed development site in the northwest corner of the industrial park. Foundation

preparation has already commenced. These clearing and preparation activities have been authorised

in terms of existing authorisations linked to the properties, i.e. GAUT: 002/06-07/N0126.

In Figure 2 Erf 876 of Wadeville Ext 50 is depicted by the white outline, while portion 273 of farm

Klippoortje 110 IR is depicted in purple outline. The proposed development site is 1.0564ha in size and

its boundary is depicted by the blue outline in Figure 2.

Figure 2: Aerial image of the development site as at 04/12/2018

The development site corner point coordinates are provided in Table 7.

Erf 876, Ptn 0

Klippoortje 110,

Ptn 273

Image date: 12/04/2018

15 November 20019 5 18028

Table 7: Corner point coordinates of proposed development site

Development site corner point Latitude (DMS) Longitude (DMS)

Corner Point A 26°16'25.599" S 28°11'32.818" E

Corner Point B 26°16'24.753" S 28°11'36.771" E

Corner Point C 26°16'25.259" S 28°11'36.923" E

Corner Point D 26°16'25.040" S 28°11'37.822" E

Corner Point E 26°16'27.421" S 28°11'38.551" E

Corner Point F 26°16'27.922" S 28°11'38.154" E

Corner Point G 26°16'26.980" S 28°11'37.866" E

Corner Point H 26°16'28.069" S 28°11'33.417" E

1.10 Existing authorisations

The proposed development falls within two properties, which have existing environmental

authorisations issued to the properties.

Table 8: Details of existing authorisations associated with development properties

Erf/farm portion tied to the current application

Klippoortje 110 IR, 273 Erf 876, 0, Wadeville X50

SG 21-digit numbers T0IR00000000011000273 T0IR07090000087600000

EA, Permit, Licence No authorisation required (Letter GMEMF19-20/0012, see Appendix I-4)

EA - GAUT: 002/06-07/N0126

Licencing Authority Gauteng Department of Agriculture and Rural Development

Gauteng Department of Agriculture, Conservation and Environment (GDACE, now GDARD)

Date issued Letter GMEMF19-20/0012 issued 25 June 2019

18 June 2007

Licence Holder Growthpoint Prop Ltd SRB Properties

Properties extent Portion 273 of the Farm Klippoortje 110 – I.R known as Wadeville Ext 51

Portions 131 and 133 of farm Klippoortjie 110 IR (subsequently consolidated into portion 2015 of farm Klippoortjie 110 IR, and thereafter re-surveyed to erf 876, ptn 0 Wadeville Ext 50)

Listed activities authorised

A basic Assessment process was initially undertaken to licence listed activity 27 of Listing Notice 1 (GN R.983 of 4 December 2014, as amended) and listed activities 4 and 12 of Listing Notice 3 (GN R.985 of 4 December 2014, as amended). The proposed development site fell within Zone 1 (northern portion of the site) and Zone 5 (southern portion of the site) of the GPEMF. GDARD subsequently confirmed that no authorisation is required as no listed activities were triggered, as per letter GMEMF19-20/0012 (Appendix I-4).

GN R.386 of 21 April 2006: Listed Activities 15 – Construction of a road wider than 4m; Listed Activity 16 – Transformation of undeveloped, vacant or derelict land to (a) establish infill development covering an area of 5ha ≤ 20ha

Construction status Clearing of vegetation and construction of internal roads has been completed.

Clearing of vegetation and construction of internal roads has been completed. Construction of warehouse infrastructure complete in SE portion of property.

EA included Appendix I-4 Appendix I-1

Activities associated with the clearing of vegetation, construction of roads, warehousing infrastructure

and associated infrastructure are thus already authorised in terms of EA - GAUT: 002/06-07/N0126.

15 November 20019 6 18028

1.11 Listed Activities triggered by the development

The proposed development triggers activities listed in terms of the National Environmental

Management: Waste Act, No 59 of 2008, as amended and Category A of GN 921 of 29 November 2013

(List of waste management activities that have, or are likely to have, a detrimental effect on the

environment). The proposed development trigger listed activities 3, 5, 6 and 12 of Category A as shown

in Table 9. A Waste Management Licence (WML) application only is required to authorise waste

activities triggered in terms of NEMWA.

The proposed development activities relating to the storage and recycling of waste are subject to the

provisions of Category C Storage of GN 921 of 29 November 2013. As such these activities will be

managed in terms of the of Norms and Standards for the Storage of Waste (GN 926 of 29 November

2013) and the National Norms and Standards for the Sorting, Shredding, Grinding, Crushing, Screening

or Baling of General Waste (GN 1093 of 11 October 2017). In terms of these norms and standards, the

activities will be registered with the relevant authority 90 days prior to construction taking place.

The listed activities applied for pertaining to Erf 876 of Wadeville Ext 50 and portion 273 of farm

Klippoortje 110 IR.

Table 9: Listed activities triggered by the proposed development

Act, Regulation, Notice Listed Activities Applicability to Listed Activity

NEM:WA 59 of 2008, GN 921 of November 2013

Category A, Activity 3: The recycling of general waste at a facility that has an operational area in excess of 500m2, excluding recycling that takes place as an integral part of an internal manufacturing process within the same premises.

The proposed cellulose recovery plant will undertake recycling activities which will involve the shredding of third party sourced pre- and post-consumer newsprint to recover cellulosic fibres. This recycling activity will be undertaken in a facility with an operational area of 4970m2. Activity 3 will, therefore, be applicable to this application.


Category A, Activity 5: The recovery of waste including the refining, utilisation, or co-processing of waste in excess of 10 tons but less than 100 tons of general waste per day or in excess of 500kg but less than 1 ton of hazardous waste per day, excluding recovery that takes place as an integral part of an internal manufacturing process within the same premises.

The proposed cellulose recovery plant will recover cellulosic fibres from approximately 38.3 tons of newsprint per day. Activity 5 will, therefore, be applicable to this application.


Category A, Activity 6: The treatment of general waste using any form of treatment at a facility that ha the capacity to process in excess of 10 tons but less than 100 tons.

In terms of the NEM:WA, the definition of “treatment” means any method, technique or process that is designed to-

(a) change the physical, biological or chemical character or composition of a waste; or

(b) remove, separate, concentrate or recover a hazardous or toxic component of a waste; or

(c) destroy or reduce the toxicity of a waste. in order to minimise the impact of the waste on the environment prior to further use or disposal. The proposed manufacturing process will change the physical character or composition of the waste by breaking the newsprint down to

15 November 20019 7 18028

fibres and blending the cellulose fibres with Ammonium Sulphate, Boric Acid bico fibres whereafter the mat product that is formed are subjected to a thermo-bonding process when the product is put through an oven. Although the purpose of this “treatment” process is not to minimise the impact of the waste on the environment, but rather to prepare the newsprint waste to be utilised in the process to produce insulation mats, this listed activity is accepted to apply to the activity 6(a), i.e.change the physical, biological or chemical character or composition of a waste.

NEM:WA 59 of 2008, GN 921 of 29 November 2013

Category A, Activity 12: The construction of a facility for a waste management activity listed in Category A of this Schedule (not in isolation to associated waste management activity).

The process of recovering cellulosic fibres from pre- and post-consumer newsprint will be undertaken in a facility that has an operational footprint of 4970m2. Activity 12 will, therefore, be applicable to this application.

No listed activities in terms of the National Environmental Management Act, No 108 of 1998 (NEMA),

as amended, and EIA Regulations, 2014 (GN R.982) and listing notices (GN R.983, GN R.984 and GN

R.985), as amended, are triggered by the proposed development.

A Water Use Licence Application (WULA) has been compiled and submitted on behalf of the developer

and operator of the greater industrial park complex, Growthpoint Prop Ltd, to the Department of Water

and Sanitation (DWS). This application applied for the licencing of Section 21 (c) and (i) water uses in

terms of the National Water Act, No 36 of 1998. A Water Use Licence (WUL) has not been issued to

Growthpoint Prop Ltd to date. The proposed activities of the applicant for this Waste Management

Licence Application, Naturecell Africa RF (Pty) Ltd, does not trigger any water uses as stipulated in

terms of section 21 of the National Water Act, 36 of 1998 and therefore does not need to apply for a

Water Use Licence.

1.12 Need and desirability of the proposed development

The rate of urbanization in metropolitan areas has created major pressures to provide job opportunities

for new arrivals, especially in the lower-income employment group. In order to achieve this economic

growth is paramount. One of the avenues to contribute to economic growth and job creation is the

establishment of industrial areas, parks or zones. This is especially evident in the South African

government’s efforts to establish Special Economic Zones (SEZs), which are large scale Industrial

Development Zones (IDZs) geared up to stimulate economic growth and job opportunities in South

Africa, underpinned by the Special Economic Zones Act, No 16 of 2014. The Wadestone Industrial Park

development contributes, albeit at a smaller scale, to this overall economic development objective by

providing the space and amenities for the commercial and industrial business to establish itself within

the complex.

The proposed cellulose recovery plant is one of the developments that will establish within the

Wadestone Industrial Park. The plant’s objective is to recover cellulosic fibres, which are blended and

treated to ultimately form a bonded mat product, which is then cut into batts and packaged as a final

product for use in thermal and acoustical insulation applications.

15 November 20019 8 18028

Furthermore, In November 2011 the National Building Regulations were amended whereby it is now a

legislative requirement that all new buildings meet minimum energy efficiency standards. Part of these

requirements, as expounded by South African National Standards SANS 10400 – XA: The Application

of the National Building Regulations – Part XA – Energy Usage; requires that all new buildings be

thermally insulated.

The development is, therefore, responding to an increased demand for these end products through the

supply of a competitive and affordable quality product, made possible through the recycling of pre-and

post-consumer newsprint. Furthermore, this recycled cellulosic product has a very low embodied energy

compared to competitive insulation products on the market and thus is a preferred solution from a cradle

to grave energy perspective.

2 DEVELOPMENT PROPOSAL

2.1 Description of the proposed development

The applicant, Naturecell, required warehousing space of approximately 70m x 70m to install and

operate the machinery required for the production of the cellulosic fibre mats. The proposed

manufacturing plant will recover cellulosic fibres from pre- and post-consumer newsprint through a

process that will utilise Carding Airlaid Fusion Technology (CAFT) to produce fibre mats that are used

as an insulating material. The value chain is described in section 3 of this Basic Assessment Report,

and is summarised below in relation to the fibre recovery and manufacturing process flow diagram

included in Figure 3 below.

1. Delivery of material

Pre- and post-consumer newsprint will be delivered in bales to the recovery/manufacturing plant by a

3rd party services provider, Wykco Recycling. 32 bales of double sorted newsprint of approx. 1000kg’s

each will be delivered on a tautliner (curtainsider) truck daily.

2. Offloading and storage

The pre- and post-consumer newsprint bales will be offloaded by forklift and stored in the northeastern

corner of the warehouse. This designated area will store a maximum of 128 bales of pre-and post-

consumer newsprint, which will be arranged in 8 rows with 8 bales per row and can be double stacked

with a second layer of bales on top of the 64 placed bales.

3. Unbaling and In-feed

From the storage area bales are brought to the load table area by forklift where the bales area untied

manually and taken apart. The sorted paper is loaded onto the load table by an operator with a mini

loader machine. The loaded paper moves with the conveyer passing a metal detector unit which scans

for any metal that may have been missed in the suppliers sorting process.

4. Shredding and fiberizing line

From the paper loading conveyer, the paper drops into the shredder and is shredded down to hand size

pieces. The paper is vacuumed from the shredder to a trap unit, where unwanted objects and other

impurities are removed. Passing the trap unit, the fan feeds the paper into a whirlwind hammer mill

where the paper is reduced to postage stamp size. The fire-retardant chemicals are introduced at this

15 November 20019 9 18028

point and impregnated into the fibres. From here the paper pieces are vacuumed from the hammermill

into the fiberizer where the paper pieces are ground down to fibres of varying lengths.

5. Dry Chemical blending line

A ribbon blender is used to blend Ammonium sulphate ((NH4)2SO4, CAS No: 7783-20-2) and Boric

acid (BH3O3, CAS No: 10043-35-3) in a fixed ratio. These chemicals are used as fire retardants in the

manufacturing process and are stored near the blending line (5). Ammonium sulphate and Boric acid

are not listed as hazardous substances in SANS 10234 supplement: SANS 10234A:2008 List of

classification and labelling of chemicals in accordance with the Globally Harmonized System (GHS).

Approximately 2.8 tons per day (TPD) of Ammonium sulphate and 0.9 TPD of Boric acid will be

consumed by the process.

6. Fibre Storage and blend line

Cellulose fibres extracted from the fiberizer are vacuumed into a storage bin prior to entering the

blending line. Bicomponent PP/PET (bico) fibres are discharged from bulk bags into a hopper from

which they are loaded onto a conveyer and added in a fixed ratio to the cellulose fibre drawn from the

storage bin in a controlled process. The blend line mixes the cellulose and bico fibres to form a

homogenous mix which is then delivered to the CAFT system via a fan where the mat-forming process

starts.

7. CAFT process

The CAFT forms the web of product that the mat (product) consists of. The Human Machine Interface

(HMI) is the central control unit for the process. This controls all settings and motor speeds on the CAFT

system, and feed control from the blend line. From the CAFT a continuous mat product exits onto the

oven conveyor.

8. Oven line

The mat product enters the oven, via the oven conveyor, where the thermo-bonding process takes

place. When the mat product exits the oven it passes directly to the cooling section, which dissipates

the residual thermal energy left in the mat product with fans pulling ambient air through the product.

This process stabilises the formed mat product.

9. Cutting

The mat passes on to the cutting section where it is cut by longitudinal and transversal slitters into batts

at the specified length and width. The height of the mat is determined by the forming setup and height

set for the oven.

10. Packaging

From the cutter, the batts pass on the roller table into the stacker where they a stacked for wrapping.

The formed stack passes on the rolling table into the wrapping machine, which wraps the stack in

polyethylene foil and welds the foil together around the stack. The package then exits the wrapper and

is passed to a holding table, where an operator manually loads the package onto a mobile stillage.

When the stillage is filled, the stillage is removed by a forklift and stacked in the designated product

storage area.

15 November 20019 10 18028

Figure 3: Manufacturing process flow diagram

15 November 20019 11 18028

2.2 Waste generation

Waste type and quantities to be generated by the proposed development is summarised in Table 10.

No floor drains exist within the warehouse area as all cleaning will be done by vacuum and/or sweeping.

As a rule, the applicant will not use water for process cleaning as it will cause damage to both raw

materials and finished goods, thus the manufacturing process will not produce waste (“dirty”) water.

The only process waste generated will be the packaging materials used in the supply of the raw

materials, specifically bulk bags used in the supply of Ammonium sulphate and bico fibre. Boric acid

will be supplied in 25kg paper bags, which is intended to be included in the raw materials feedstock and

therefore consumed in the manufacturing process. A small amount of galvanised wire that is used to

bind the paper bales will be collected and stored temporarily prior to recycling.

Table 10: Waste type and quantities to be generated

Types of waste

Main source

Quantities On-site recovery reuse recycling treatment or

disposal

Offsite recovery reuse recycling

treatment or disposal

Offsite disposal

TPD TPM Method & location Method, location, contractor details

Pre- and Post-consumer newsprint

Wykco Recycling

38.3 1149

Recovery of cellulosic fibres through CAFT technology. Recovery process within warehouse at identified site.

No off-site recovery will take place

No offsite disposal will take place

General waste from recovery process

Naturecell 0.3 10.1

No on-site recovery, reuse, recycling, treatment or disposal. Temporary on-site storage of waste.

No off-site recovery, reuse, recycling or treatment of waste.

Waste collected by 3rd party service provider for off-site disposal at licenced landfill site.

Hazardous waste

No hazardous waste will be produced

0 0 No hazardous waste will be produced

All disposable waste will be collected in skips, which will be located within a designated refuse yard

located next to the access road leading to the facility within the development footprint. The refuse yard

is enclosed with access control. The skips will be collected by a third-party service provider for disposal

to an appropriately licenced landfill. All out of specification product will be recovered and recycled within

the process thus no direct process waste will be generated.

2.3 Potential emissions

The manufacturing process described above includes the operation of an oven, which will be operated

through the combustion of natural gas. An air quality specialist was appointed to assess whether

significant emissions would be generated in terms of the National Environmental Management: Air

Quality Act, No. 39 of 2004, as amended, and the “List of Activities which result in atmospheric

emissions” (GN 893). Based on the manufacturing process details and plant specifications provided,

the specialist concluded that the heat input per unit is significantly below (<0.25 MW) the threshold

trigger of 50 MW (GN 893, Category 1, Sub-category 1.4). Furthermore, the processing of the recycled

fibre is limited to a maximum of 130°C and no thermal decomposition/reaction of the cellulose fibre

occurs. Thus, this description does not meet the definition of “thermal treatment” (GN 893, Category 8,

Sub-category 8.1). Lastly, no chlorine dioxide is used or produced in the process (GN 893, Category 9,

15 November 20019 12 18028

Sub-category 9.4), therefore no significant emissions will be generated by the fibre recovery and

manufacturing process.

2.4 Potential noise generation

The manufacturing process described above includes the operation of a shredder, hammermill,

fiberizer, conveyor, and fans during the manufacturing process. A noise specialist was appointed to

assess whether significant noise would be generated in terms of the Gauteng Noise Control Regulations

(The Gauteng Provincial Government, 1999) and SANS 10103:2008 ‘The measurement and rating of

environmental noise with respect to annoyance and to speech communication’ (SABS, 2008). Based

on the provided information relating to the manufacturing process, site location and conservative high-

level screening calculation, the noise specialist concluded that the potential noise levels at both the

potential sensitive receptors and nearby industrial receptors are anticipated to be below the relevant

noise limits in terms of the NCRs and SANS limits. Furthermore, in the context of the existing industrial

area, the baseline noise levels are anticipated to be relatively high from the existing industry and are

likely to mask the contribution of the proposed facility.

2.5 Bulk services

Bulk water supply will be obtained from the Ekurhuleni Metropolitan Municipality (EMM) via existing bulk

water supply infrastructure.

It is anticipated that 1.2 MVA power will be required and has already been catered for in the greater

Wadestone Industrial Park Development.

Bulk stormwater infrastructure has furthermore been constructed as part of the greater Wadestone

Industrial Park Development, therefore stormwater originating within the fibre recovery plant footprint

will be channelled to existing stormwater drains to the bulk stormwater infrastructure installed.

Ablution facilities within the plant will tie into existing sewerage infrastructure servicing the greater

Wadestone Industrial Park Development.

2.6 Consideration of Alternatives

1. Alternative sites within properties not considered

No alternative sites within the Wadestone Industrial Park development were considered as the

proposed site (Site 6) was the only suitable site available to the applicant to lease within the

development. Tenants for the other sites have already either been secured or are under negotiation.

2. Alternative properties not considered

During the project development phase the applicant identified the need for a site or property that could

provide sufficient space to accommodate the development infrastructure and activities, were located

close to existing industrial nodes and aligned with the available operational capital within which the plant

was expected to operate. Of the sites considered, the Wadestone Industrial Park development on

Portion 273 of the farm Kilppoortie 110 IR and Erf 876 Wadeville X 50 was identified at the only suitable

site that could meet the development requirements.

3. Alternative technologies not considered:

15 November 20019 13 18028

Assessment of available technologies to produce nonwoven fibre mats identified Carding Airlaid Fusion

Technology (CAFT) as the most suitable technology based on several advantages and benefit when

compared to alternative manufacturing processes. No alternative technologies were therefore

considered.

4. Alternative energy sources not considered

Alternative energy sources, apart from electricity and natural gas, have not been considered as the

CAFT infrastructure has been designed specifically for use of electricity and natural gas (oven).

5. Alternative designs not considered

No design alternatives were considered as the design and construction of the warehousing

infrastructure is not within the control of the applicant. The Wadestone Industrial Park has been

designed and developed by Growthpoint Properties.

2.7 Sustainable Development Considerations

The original process design required the fire-retardant chemicals to be dissolved in water and spray

applied to the fibre which would then be subject to a drying process. In reviewing the design it was

decided to remove this dissolution process and apply the chemicals on a dry basis using what is known

as a whirlwind mill to directly impregnate the fibres. Thus, the manufacturing process does not consume

any water. Elimination of this additional step of drying the fibres which would be necessary if the wet

process was used effectively reduces gas consumption in the process by half. High-efficiency motors

are being used throughout the plant to reduce the energy requirements of the plant.

The applicant’s waste minimisation and recycling policy include recycling of all possible recyclable

waste generated in the manufacturing process. For example, the applicant has requested raw materials

to be supplied in paper bags which can then be consumed within the process as part of the raw material

feedstock. Furthermore, waste polypropylene packaging materials will be stored in waste bins in a

designated area for removal by 3rd party who will reroute for recycling where possible. Furthermore,

the design of the building has been tailored to accommodate the manufacturing line to optimise the use

of space. The building is oriented approximately N-S with translucent roof panels along the length of

the eastern roof hinge to take advantage of natural light in the building.

3 DESCRIPTION OF STUDY AREA

3.1 Site Screening Report (DEA Screening Tool)

In terms of Government Notice No. 960, promulgated in terms of the National Environmental

Management Act, 1998, the submission of a report generated by the National web-based environmental

screening tool (https://screening.environment.gov.za) with an application for environmental

authorisation will become compulsory from 4 October 2019.

A screening report based on the development footprint of the proposed development within the

Wadestone Industrial park has been generated to screen the site environmental sensitivities associated

with the development site. This screening report is attached in Appendix G-5. The site screening

highlighted the following:

https://screening.environment.gov.za/

15 November 20019 14 18028

The proposed development site falls within the Gauteng Provincial Environmental Management

Framework (GPEMF). In terms of the GPEMF the proposed development footprint falls within:

• Central Power Corridor

• Zone 1 of the GPEMF standard (GN. 164 of 2 March 2018)

• Zone 5 of the GPEMF standard (GN. 164 of 2 March 2018)

• Highveld Priority Area (Air Quality)

The proposed development does not trigger any listed activities in terms of the NEMA EIA Regulations

and listing notices, hence the listed activities identified for the exclusion of obtaining an EA does not

apply. Compliance with the NEMWA is however still applicable and a WML Application and Basic

Assessment process must be undertaken.

In terms of the listed sensitivity themes, the screening report allocated the sensitivities shown in Table

11

Table 11: Proposed development area environmental sensitivity

Theme Sensitivity

Agricultural Theme Medium

Aquatic Biodiversity Theme Low

Civil Aviation Theme High

Defence Theme Low

Terrestrial Biodiversity Theme Very High

Based on the sensitivities identified the screening report recommended the specialist assessments

listed in Table 12. Motivation for the need or exclusion of the identified specialist assessments is

included in Table 12.

Table 12: Proposed specialist assessments and needs motivation

Specialist Assessment Assessment motivation

Agricultural Impact Assessment

The development site, encompassing the properties Erf 876 Portion 0, Wadeville Ext 50 and Portion 273 of farm Klippoortje 110 IR, have been authorised for the development of an industrial park. The assessment process considered aspects relating to potential agricultural impact, heritage, archaeology and palaeontology, terrestrial and aquatic biodiversity, hydrology and the socio-economic environment. The development site has subsequently been cleared of vegetation and construction of infrastructure has commenced in terms of the existing authorisations. Assessments relating to the above-mentioned environmental aspects are therefore not necessary as impacts relating to these aspects during the construction phase have been considered. The proposed fibre recovery and manufacturing plant will furthermore be installed and operated within an enclosed warehouse structure, while waste management will be constructed and operated to effectively manage the handling and storage of waste to avoid any impact on the landscaped terrestrial and aquatic environment within the industrial park

Archaeological and Cultural Heritage Impact Assessment

Palaeontology Impact Assessment

Terrestrial Biodiversity Impact Assessment

Aquatic Biodiversity Impact Assessment

Hydrology Assessment

Socio-Economic Assessment

Noise Impact Assessment Noise impacts during the construction phase were considered and the proposed development subsequently authorised. Potential noise impacts during the operational phase of the fibre recovery and manufacturing plant will be assessed by a noise specialist.

Traffic Impact Assessment Traffic impacts during the construction phase were considered and the proposed development subsequently authorised. The anticipated traffic volumes expected to service the fibre recovery and manufacturing plant have been calculated to fall within the traffic volumes considered as part of the existing authorisations of the industrial park.

15 November 20019 15 18028

Ambient Air Quality Impact Assessment

The potential impact of the proposed fibre recovery and manufacturing plant on ambient air quality will be considered by an appropriately qualified and experienced air quality specialist.

Health Impact Assessment The specifications provided for the proposed fibre recovery and manufacturing plant technology does not trigger a listed activity in terms of the National Environmental Management: Air Quality Act, No. 39 of 2004. It is therefore anticipated that the potential impact on human health will be negligible if any. It is therefore concluded that undertaking a Health Impact Assessment is not necessary for the proposed development.

A screening assessment of site including a 500m buffer area, included in Appendix G-6, was also

conducted to assess the potential impact on wetlands or watercourses within 500m of the proposed

development. The screening analysis concluded that no watercourses are located within 500m of the

proposed development.

3.2 Historical environmental sensitivity

Prior to the development of the Wadestone industrial park, the Basic Assessment process that was

undertaken to authorise the listed activities associated with the Wadeville Ext 50 development included

an ecological assessment of the surrounding environment. The ecological assessment was conducted

by Eco Assessments cc in 2017 and found the following:

• The site was located on Carltonville Dolomite Grassland vegetation type according to Mucina and

Rutherford (2006);

• Vegetation units identified within the study area included natural grassland (Eragrostis racemose),

disturbed grassland (Cynodon dactylon) and altered grassland (Tagetes minuta);

• A large portion of the site vegetation has been altered, allowing for the invasion of several and a

variety of exotic species;

• Altered grassland made up approximately 60% of the site;

• No other obvious natural features such as streams, hills or rocky outcrops occur on the site;

• No recorded Red Data flora species records for the site or in the vicinity of the site;

• Pentad information (SABAP2) indicates a high bird species count of 196 species of which a large

part is grassland birds;

• A range of smaller mammal species such as mongoose, rats, and mice could have been present

on-site due to site consisting of open, rural land and being connected to undeveloped land

southwards;

• Twelve amphibian species are listed for the area including common species such as Red toad,

Bubbling Kassina and Guttural Toad; and

• No species are listed for the area with a Near Threatened or higher conservation status.

The Extension 50 development site was classified as having a southern aspect with grassland sloping

gently down towards the Elsburgspruit, a large wetland system running through the area and located

300 meters south of the site. A historical sensitivity map is provided in Figure 4 and Appendix A-6.

15 November 20019 16 18028

Figure 4: Historic environmental sensitivity of the development site

15 November 20019 17 18028

Figure 5: Current environmental sensitivity of the development site

15 November 20019 18 18028

Figure 6: Gauteng Pollution Buffer Zone for the proposed development site

15 November 20019 19 18028

3.3 Existing environmental sensitivity

The current environmental sensitivity within the proposed development site is presented in Figure 5 and

Appendix A-7. The proposed development site has been cleared of all vegetation, hence no

environmental sensitivities remain within the development site boundaries.

3.4 Gauteng Pollution Buffer Zone Guideline

The proposed development site falls within the Category 3 Industries, therefore, requiring a worst-case

buffer of 50m and best case buffer of 100m. Industries that fall within the pollution buffer zone are

located north of the development site and include Ambro Steel, Probraze Metals (Pty) Ltd, Active

Industrial Engineering and Supplies, and P and T Technology (Pty) Ltd. The development site, including

the mentioned industries, is located within an existing industrial area. A map depicting the pollution

buffer zone is included in Figure 6 and Appendix A-8.

3.5 Site access and traffic

Site access to the greater industrial park is gained from the north via Chaperone Road through an

access-controlled entrance with security checkpoint (Figure 7). This entrance and security checkpoint

are already fully functional and were developed as part of the Wadeville Ext 50 development authorised

in terms of an existing Environmental Authorisation (GAUT 002/06-07/N0126).

A Traffic Impact (TIA) Study was undertaken by Aurecon (Pty) Ltd, as part of the Wadeville Ext 51

development, to assess anticipated traffic flows and impacts to and from the entire industrial park

development. This TIA is included in Appendix G-3.

Figure 7: Security controlled entrance to Wadestone Industrial Park

The TIA found that Wadeville Ext. 51 did not have access from the surrounding public roads. Since Ext

51 forms part of the greater industrial park with the development on Ext 50, the two sites will share

existing access currently serving Ext. 50. The site is currently served by three vehicle accesses which

will be retained to serve the proposed development. The existing access is off Chaperone Road and

15 November 20019 20 18028

has one lane in each direction which extend to two lanes to service the two inbound and two outbound

lanes at the access gate. The TIA further calculated that the greater industrial development would

generate 108 trips during both the AM and PM peak hour.

Potential traffic to and from the proposed fibre recovery and manufacturing plant was further considered

in this application. Considering that the TIA undertook by Aurecon in 2017 estimated that approximately

108 trips would be generated by the greater industrial park during both the AM and PM peak hours, the

applicant conducted a study on the number of trips that would be required from an operations and

staffing perspective. Based on the proportionate land area, the Naturecell premises were allocated 40

of the 108 peak hour trips. Based on a calculation made by the applicant it was estimated that the

anticipated number of peak hourly trips would fall within the levels stipulated in the TIA. A memo

showing the assumptions and calculations made by the applicant is included in Appendix G-4.

4 IMPACT IDENTIFICATION AND ASSESSMENT

4.1 Pre-construction Phase

The applicant, Naturecell, proposes to operate a fibre recovery and manufacturing plant within the

Wadeville Industrial Park development which is owned, managed and operated by Growthpoint

Properties. Growthpoint Properties undertook an application for Environmental Authorisation (EA)

(Application reference: GAUT: 002/06-07/N0126) for the entire Wadestone Industrial Park

Development, which are located on Wadeville Extension 50 and 51. EA was obtained for the

development of Wadeville Extension 50 on 18 June 2007, and have been included as Appendix I-1.

Construction activities authorized by this EA has commenced and is nearing completion.

An application for EA (GAUT: 002/17-18/E2053) was undertaken in 2017 for the development of

Wadeville Extension 51. The application included activities associated with the proposed establishment

of an industry township and associated infrastructure on the Remaining extent of Portion 267 and

Portion 273 of the Farm Klippoortje 110 – I.R. Subsequent to the submission of the application and BAR

to the competent authority, GDARD confirmed that due to fact that the development site falls within the

Gauteng Provincial Environmental Management Framework’s Zone 1 and Zone 5 and due to the fact

that all vegetation has been cleared no further authorisation is required. A letter from GDARD to this

effect is included in Appendix I-4.

The applicant, Naturecell, is a tenant of the industrial park and is not responsible for the construction of

the infrastructure associated with the industrial park. No pre-application impacts were identified.

4.2 Construction Phase

The construction activities that will be relevant to this application will be limited to the installation of the

manufacturing plant and equipment within the already constructed warehouse structure ONLY.

Potential impacts identified during the construction phase, including proposed mitigation measures and

impact significance after mitigation are provided in Table 13.

15 November 20019 21 18028

Table 13: Potential impacts, mitigation and impact significance for the construction phase

Potential Impact Mitigation measures proposed Residual Impact

significance after mitigation

Packaging material waste handling and storage result in contamination of surrounding aquatic or terrestrial environment.

• Unboxing and unwrapping may only take place within a designated area within the warehouse structure.

• No material, substances or liquids may be placed or disposed into any stormwater infrastructure or areas not designated for storage of waste at any time.

1 – Low (-)

Spillage of hydrocarbons or oils within the warehouse footprint result in the indirect contamination of surrounding terrestrial and/or aquatic environment.

• Drip trays or appropriate spillage containers must be used when components that require petrochemicals or lubricating oils are installed and filled.

• The applicant must identify and capacitate a designated staff member/s to execute the containment and clean-up of any spillages that may occur during installation of infrastructure.

• The applicant must facilitate environmental awareness, emergency preparedness and emergency response procedures training to staff/contractors involved in the installation of the plant.

• Any spillages that do occur must be contained and cleaned up immediately by the designated trained staff.


1 – Low (-)

Littering and poor housekeeping during the construction phase results in contamination of surrounding terrestrial and/or aquatic environments.


• Littering and housekeeping within the warehouse structure must be actively managed by the applicant.

• Littering and poor housekeeping on areas not directly managed by the applicant must be reported immediately to the developer, Growthpoint Properties to action and remedy.


1 – Low (-)

Impact on landscaped areas, fauna, and flora within the industrial park footprint.


• No-go areas, which will include areas in the process of being landscaped, must be communicated to the applicant's staff/contractor prior to commencement of the plant installation activities.

1 – Low (-)

Protest or community action, and other social impact arising from disputes between employer and employees/community.

• The applicant must develop/implement a procurement process/policy in terms of the relevant and applicable legislation governing the procurement of labour.

• The applicant should take cognisance of the surrounding community needs and requests, especially during procurement of unskilled labour, as long as it is in line with the relevant and applicable legislation.

• The applicant must provide a complaint register at the entrance of the industrial park where community comments, complaints or grievances can be recorded.

• Complaints and grievances registered in the complaints register must be investigated and actioned by the applicant on an ongoing basis.

1 - Low

Provision of employment opportunities (Positive impact)



11 – High (+)

15 November 20019 22 18028

4.3 Operational Phase

Operational activities will include the day-to-day operations and maintenance of the fibre recovery and

manufacturing plant ONLY. Potential impacts identified during the operational phase, including

proposed mitigation measures and impact significance after mitigation are provided in Table 14.

Table 14: Potential impacts, mitigation and impact significance for operational phase

Potential Impact Mitigation measures proposed Impact


Generation of waste from the manufacturing process result in contamination of surrounding aquatic or terrestrial environment.

• The applicant must develop/implement a waste management plan/policy that will guide all waste management activities at the plant in terms of the National Waste Management Strategy, 2011 (GN 344 of 4 May 2012), or must comply with the requirements of the developer’s SHEQ policy or documents where waste management has already been incorporated.

• The applicant will endeavour to recycle the recyclable portion of waste as far as possible.

• Unrecyclable waste must be collected on an ongoing basis and temporarily stored in the designated and fenced waste storage area.

• Unrecyclable waste stored in the designated waste storage area must be removed by a suitable licensed service provider from the site at a frequency of not more than 60 days.


1 – Low (-)

Operational activities contribute to noise impact to sensitive local receptors during daytime hours

• All operational activities will occur within an enclosed warehouse structure within an established industrial zone.

• Based on specifications provided for plant and equipment, noise levels are not expected to exceed legislated industrial noise levels at the closest sensitive noise receptors.

2 – Low (-)

Operational activities contribute to air quality emissions in the region

• Anticipated atmospheric emission levels generated at the plant will not exceed legislated Minimum Emission Standards (MES). Therefore, an application for an Atmospheric Emission License (AEL) is not required. This confirms that the contribution of anticipated emission levels to the existing emissions will be neglectable.

• The applicant must provide a complaint register at the entrance of the industrial park where community complaints relating to emissions can be recorded.

• Complaints relating to operational emissions that are registered in the complaints register must be investigated and actioned by the applicant on an ongoing basis.

6 – Moderate (-)

Protest or community action, and other social impact arising from disputes between employer and employees/community.


• Leverage this through recruitment policies that favour local labour.

• The applicant should continuously take cognisance of the surrounding community needs and requests, especially during procurement of unskilled labour, as long as it is in line with the relevant and applicable legislation.



2 – Low (-)

Provision of employment

• The applicant must continue to implement a procurement process/policy in terms of the relevant and applicable legislation governing the procurement of labour.

11 – High (+)

15 November 20019 23 18028

Potential Impact Mitigation measures proposed Impact


opportunities (Positive impact)


4.4 Decommissioning Phase

Due to the nature of the proposed development, decommissioning of the facility is not envisioned at this

stage. However, should the facility be decommissioned in future the decommissioning activities will

need to comply with the relevant legislation at the time. Mitigation measures proposed for the

construction phase will apply.

4.5 No-Go Option

The No-Go Option, which is reflective of the scenario where the proposed fibre recovery and

manufacturing plant development does not go ahead is considered in the application. Potential impacts

as a result of the proposed development not going ahead, including proposed mitigation measures and

impact significance after mitigation, are provided in Table 15. The impacts complete table, including the

risk of the impact and mitigation not being implemented, are shown on page 66 of the Final BAR.

Table 15: Potential impacts, mitigation and impact significance for No-Go Option

Potential Impact Mitigation measures proposed

Impact significance

after mitigation

No contamination and spillage of hydrocarbons on the environment.

• Any proposed development must go through an Environmental Impact Assessment Process to ensure that potential impacts on the environment are mitigated or avoided.

0 – Low (+)

Pre- and post-consumer newsprints disposed of in landfills.

• Recommend Environmental Authorisation for the proposed fibre recovery and manufacturing plant development.

• Encourage the reduction of waste at source, reuse and recycling of waste.

• Encourage separation of waste into recyclable and non-recyclable waste materials.

• Encourage waste minimisation industries to ensure that waste materials such as the pre- and post-consumer newsprints are recycled.

• Encourage communities to be involved in the collection of recyclable materials to such industries.

8 – Moderate (-)

The identified business opportunity can not be realised by the developer thereby contributing to the local and regional economy.

• Recommend Environmental Authorisation for the proposed fibre recovery and manufacturing plant development

8 – Moderate (-)

Potential employment opportunities on a local scale will not be realised.

• Recommend Environmental Authorisation for the proposed fibre recovery and manufacturing plant development

5 – Moderate (-)

4.6 Cumulative Impacts

Cumulative impacts are assessed as the combination of impacts from the proposed development with

current and future development impacts in the immediate area of the Project site. The cumulative

15 November 20019 24 18028

impacts assessed depend on the status of other projects and the level of data available to characterise

the magnitude of the impacts. Cumulative impacts there were considered are discussed in brief in the

following sections.

4.6.1 Litter and Waste

Activities associated with the use of the site may result in littering. Similarly, the building process

generates wastes that could pollute the site and its surrounds. For this reason, it is important that a

waste management plan must be developed by the operator of the industrial park, if not already

implemented. Each tenant must align and comply with such waste management plan. The litter will

reduce as the construction phase comes to an end.

4.6.2 Stormwater Runoff

The development of hard surfaces will give rise to greater volumes and velocity of runoff waters during

high peak flows. This water will drain into the roads and stormwater management system. Localised

flooding may result in negative impacts on the bed and banks of the stream course due to the cumulative

effects.

4.6.3 Social benefits

In an area that has high unemployment and low-level job opportunities, the cumulative benefits of this

industrial area being developed are high.

4.6.4 Cumulative impacts not considered

It must be noted that due to the fact that potential air quality and noise impacts are expected to be

negligible as confirmed by respective air quality and noise specialists (see Appendix G-1 and G-2),

potential cumulative impacts associated with air quality and noise were not assessed.

5 CONCLUSION AND RECOMMENDATIONS

5.1 Environmental Impact Statement

The site is located within an industrial area and has already been cleared for construction of the relevant

structures and infrastructure. The applicant, Naturecell, is a tenant within this establishing industrial

park. Construction of the applicant’s warehouse structure is furthermore being undertaken by the

industrial park developer and operator, Growthpoint Properties, and as such construction impacts

resulting from the activities of the applicant is limited to the installation of the fibre recovery and

manufacturing plant and technology within the warehouse structure allocated to Naturecell as the

tenant.

Impact on the surrounding natural environment will be negligible, with the main concern being the

handling and management of waste within the applicant’s site. With the implementation of the proposed

mitigation, any potential impacts relating to the management of waste within Naturecell’s site will be

Low as a designated waste management area has been included in the design of the plant. It is

15 November 20019 25 18028

therefore concluded that impacts resulting from the management and storage of waste will be unlikely

during the construction and operational phases of the development, and in the event that such impacts

may occur the impact significance will be Low as a result of mitigating procedures and policies in place.

Other potential impacts resulting from the construction and operational phases of the proposed fibre

recovery and manufacturing plant are associated with the employment of labour. A significant positive

impact that will result is definite employment opportunities for local skilled and unskilled labour.

Potential negative impacts associated with the employment of labour include protest action or

community action where disputes between employer and employees cannot be resolved. Unfortunately,

the management of such incidents is difficult to predict and control. As such the likelihood of this impact

occurring will remain probable. However, proposed mitigation measures will reduce the impact

significance to Low and the likelihood of such impact occurring unlikely.

5.2 Environmental Impact Summary

Based on the potential impact identified and assessment, impacts will predominantly be limited to the

site and study area. The impacts will mostly occur during the construction phase of the fibre recovery

and manufacturing plant, which will be approximately 2 months. All of the impacts identified during the

construction phase can be mitigated to acceptable limits and the majority of the impacts showed a

MODERATE significance before and a LOW significance after mitigation measures are implemented.

Establishment of the proposed plant within the existing industrial park is therefore not likely to

significantly impact on the remaining surrounding environment.

It is, therefore, the EAP’s recommendation that GDARD grants Environmental Authorisation for the

proposed development.

5.3 Recommendation of the EAP

The EAP recommends that the proposed development of a cellulose recovery plant be authorised at

the proposed location. The EAP recommends the following conditions to be included in the

Environmental Authorisation:

• All mitigation proposed in the Environmental Management Programme (EMPr) (refer to

Appendix H) must be implemented and adhered to by the applicant/developer.

• The applicant must adhere and implement any strategy, policy or plan developed by the

operator of the industrial park, Growthpoint Properties (Pty) Ltd, and applicable to all tenants

within the park, relating to the prevention of pollution and protection of the environment.

5.4 Period for which the environmental authorisation is required

The proposed construction phase, i.e. installation of the processing plant within the warehouse

structure, is expected to be completed within a period of 2 months, while the operation of the fibre

recovery and manufacturing plant is expected to continue indefinitely.

15 November 20019 26 18028

Basic Assessment Report in terms of the National Environmental Management

Act, 1998 (Act No. 107 of 1998), as amended, and the Environmental Impact

Assessment Regulations, 2014 (Version 1)

Kindly note that: 1. This Basic Assessment Report is the standard report required by GDARD in terms of the EIA Regulations, 2014.

2. This application form is current as of 8 December 2014. It is the responsibility of the EAP to ascertain whether subsequent

versions of the form have been published or produced by the competent authority.

3. A draft Basic Assessment Report must be submitted, for purposes of comments within a period of thirty (30) days, to all State Departments administering a law relating to a matter likely to be affected by the activity to be undertaken.

4. A draft Basic Assessment Report (1 hard copy and two CD’s) must be submitted, for purposes of comments within a period of thirty (30) days, to a Competent Authority empowered in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended to consider and decide on the application.

5. Five (5) copies (3 hard copies and 2 CDs-PDF) of the final report and attachments must be handed in at offices of the relevant competent authority, as detailed below.

6. The report must be typed within the spaces provided in the form. The size of the spaces provided is not necessarily indicative of the amount of information to be provided. The report is in the form of a table that can extend itself as each space is filled with typing.

7. Selected boxes must be indicated by a cross and, when the form is completed electronically, must also be highlighted.

8. An incomplete report may lead to an application for environmental authorisation being refused.

9. Any report that does not contain a titled and dated full colour large scale layout plan of the proposed activities including a coherent legend, overlain with the sensitivities found on site may lead to an application for environmental authorisation being refused.

10. The use of “not applicable” in the report must be done with circumspection because if it is used in respect of material information that is required by the competent authority for assessing the application, it may result in the application for environmental authorisation being refused.

11. No faxed or e-mailed reports will be accepted. Only hand delivered or posted applications will be accepted.

12. Unless protected by law, and clearly indicated as such, all information filled in on this application will become public information on receipt by the competent authority. The applicant/EAP must provide any interested and affected party with the information contained in this application on request, during any stage of the application process.

13. Although pre-application meeting with the Competent Authority is optional, applicants are advised to have these meetings

prior to submission of application to seek guidance from the Competent Authority.

DEPARTMENTAL DETAILS Gauteng Department of Agriculture and Rural Development Attention: Administrative Unit of the of the Environmental Affairs Branch P.O. Box 8769 Johannesburg 2000 Administrative Unit of the of the Environmental Affairs Branch Ground floor Diamond Building 11 Diagonal Street, Johannesburg Administrative Unit telephone number: (011) 240 3377 Department central telephone number: (011) 240 2500

15 November 20019 27 18028

If this BAR has not been submitted within 90 days of receipt of the application by the competent authority and permission was not requested to submit within 140 days, please indicate the reasons for not submitting within time frame.

N/A

Is a closure plan applicable for this application and has it been included in this report?

if not, state reasons for not including the closure plan.

The proposed project is for the construction and operation of a cellulose recovery plant within an existing industrial park in Wadeville, Germiston. No closure activities are therefore associated with the type of development.

Has a draft report for this application been submitted to a competent authority and all State Departments administering a law relating to a matter likely to be affected as a result of this activity? Is a list of the State Departments referred to above attached to this report including their full contact details and contact person?

If no, state reasons for not attaching the list.

N/A

Have State Departments including the competent authority commented?

If no, why? N/A

(For official use only) NEAS Reference Number:

File Reference Number:

Application Number:

Date Received:

No

Yes

Yes, available in the Appendix E-9

Yes

15 November 20019 28 18028

SECTION A: ACTIVITY INFORMATION

1. PROPOSAL OR DEVELOPMENT DESCRIPTION

Project title (must be the same name as per application form):

Proposed development of a cellulose recovery plant and related infrastructure for the recovery of pre- and post-consumer newsprint in Wadeville, Gauteng Province

Select the appropriate box

The application is for an upgrade of an existing development

The application is for a new development

X Other, specify

Does the activity also require any authorisation other than NEMA EIA authorisation?

YES

If yes, describe the legislation and the Competent Authority administering such legislation

A Waste Management License (WML), to be issued by GDARD, is required in terms of the National Environmental Management: Waste Act, 59 of 2008, as amended.

If yes, have you applied for the authorisation(s)? YES

If yes, have you received approval(s)? (attach in appropriate appendix)

NO

2. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES

List all legislation, policies and/or guidelines of any sphere of government that are applicable to the application as contemplated in the EIA regulations:

Title of legislation, policy or guideline: Administering authority: Promulgation Date:

The Constitution of the Republic of South Africa, Act 106 of 1998

The Judiciary 18 December 1996

National Environmental Management Act, No. 107 of 1998, as amended (NEMA)

National & Provincial (GDARD)

27 November 1998

NEMA Environmental Impact Assessment (EIA) Regulations 2014 (GN R.982), as amended on 7 April 2017 (published in Government Notice No. R.326)

Gauteng Department of Agriculture and Rural Development (GDARD)

4 December 2014, amended on 7 April 2018

National Environmental Management: Waste Act, No 59 of 2008, as amended (NEMWA)


10 March 2009

National Environmental Management Air Quality Act, No. 39 of 2004, as amended (NEMAQA)


11 September 2005

National Heritage Resources Act, No 25 of 1999 The South African Heritage Resource Agency (SAHRA)

28 April 1999

National Water Act, No 36 of 1998, as amended (NWA) Department of Water and Sanitation (DWS)

20 August 1998

Promotion of Access to Information Act, No. 2 of 2000 (PAIA)

Department of Justice and Constitutional Development

7 July 2000

Occupational Health and Safety Act, No 85 of 1993 (OHSA)

Department of Labour 23 June 1993

National Waste Management Strategy (NWMS) National & Provincial (GDARD)

4 May 2012

Gauteng Provincial Environmental Management Framework


2 March 2018

National Norms and standards for the storage of waste, published i.t.o. NEMWA


23 November 2013

National Norms and standards for the sorting, shredding, grinding, crushing, screening or baling of general waste, published i.t.o. NEMWA


11 October 2017

15 November 20019 29 18028

Gauteng Pollution Buffer Zones Guideline Gauteng Department of

Agriculture and Rural Development (GDARD)

24 March 2017

Gauteng Sustainability Development Guideline Gauteng Department of Agriculture and Rural Development (GDARD)

April 2017

Gauteng Provincial Integrated Waste Management Policy


September 2006

Ekurhuleni Metropolitan Municipality Bioregional Plan Ekurhuleni Metropolitan Municipality

March 2014

Applicable by-laws of the Ekurhuleni Metropolitan Municipality.

Ekurhuleni Metropolitan Municipality

Description of compliance with the relevant legislation, policy or guideline:

Legislation, policy of guideline Description of compliance

The Constitution of the Republic of South Africa (Act 106 of 1998)

Section 24 of the Constitution of the Republic of South Africa provides for a comprehensive environmental right. Therefore, stakeholders and Interested and Affected Parties may exercise their rights by providing comments during the PP process and raising issues of concern that are likely to infringe upon their environmental rights. The Basic Assessment process recognises this right and the EAP has recorded, considered and responded to any and all issues of concern raised by the I&APs.

National Environmental Management Act 107 of 1998 (NEMA) and subsequent amendments to the Act.

The NEMA (as amended) is regarded as South Africa’s environmental framework legislation which provides for environmental management and gives effect to section 24 of the Constitution. The Basic Assessment and Public Participation processes were undertaken in strict compliance with the NEMA, as amended.

NEMA Environmental Impact Assessment (EIA) Regulations 2014 (GN R.982), as amended on 7 April 2017 (published in Government Notice No. R.326)

The Basic Assessment Process for the proposed project has been carried out in accordance with Regulations 19 and 20 of the NEMA EIA Regulations, 2014.

National Environmental Management: Waste Act, No 59 of 2008, as amended (NEMWA)

All requirements/provisions concerning waste-producing activities and the handling of waste, as provided in the NEMWA and the regulations thereunder must be conformed to.

National Environmental Management Air Quality Act, No. 39 of 2004, as amended (NEMAQA)

Confirmation of the proposed process and thresholds indicate that no listed activities in terms of GN 893 will be triggered. Therefore, Air Emissions Licence (AEL) will not be required.

National Water Act of 1998 A WULA is currently being undertaken in terms of section 21 (c) and (i) by LEAP Environmental Consultants for the entire development. It is therefore expected that no additional applications for water uses are required for this development.

National Heritage Resources Act 25 of 1999

Provisions in the NHRA relating to the protection and management of heritage resources apply to the proposed project. A Heritage Screening Assessment undertaken for the site revealed that there are no significant heritage resources that would be impacted.

Promotion of Access to Information Act, No. 2 of 2000 (PAIA)

As per the NEMA EIA Regulations, 2014, as well as the principles/objectives of the PAIA, the Basic Assessment Report as well as all supporting documentation (e.g. specialist studies) will be made available to the public for review and comment.

Occupational Health and Safety Act, No 85 of 1993 (OHSA)

This is primarily intended to provide for the health and safety of persons at work and for the health and safety of persons in connection with the activities of persons at work. All work that is carried out for the implementation of the project activities as well as during each phase of the project lifecycle should be carried out in accordance with the provisions of the OHS Act.

National Waste Management Strategy (NWMS)

The NWMS imposes an obligation on the private sector, amongst others, to take responsibility for their products throughout the products' life cycles and institute cleaner technology practices and minimise waste generation through the implementation of the waste management hierarchy. The applicant is committed to reduce, re-use or recycle any waste originating from its premises.

15 November 20019 30 18028

Gauteng Provincial Environmental Management Framework (GPEMP)

The objective of the GPEMF is to guide sustainable land use management within the Gauteng Province through the establishment of geographical areas where certain activities can be excluded from an EIA process. Although the development falls within Zone 1 and 5 of the GPEMF, None of the listed activities in the EIA Regulations 2014 is applicable to the development. The Basic Assessment process required is triggered in terms of NEMWA.

National Norms and standards for the storage of waste, published i.t.o. NEMWA

The purpose of the Norms and Standards for the storage of waste includes providing minimum standards for the design and operation of new and existing waste storage facilities. The proposed development will require a waste storage area, prior to removal by a 3rd party service provider

National Norms and standards for the sorting, shredding, grinding, crushing, screening or baling of general waste, published i.t.o. NEMWA

The purpose of these norms and standards is to provide a uniform national approach relating to the management of a waste facility that sort, shred, grind, crush, screen or bale general waste. The proposed facility will shred, crush and grind pre-and post-consumer waste in its manufacturing process.

Gauteng Pollution Buffer Zones Guideline

This guideline was developed to ensure that pollution buffers are created between the potential pollution sources and the nearest human settlements. This buffer zone guideline has been applied to the proposed development footprint.

Gauteng Sustainability Development Guideline (GPIWMP)

This guideline promotes the inclusion of sustainable development principles in the design and operation of new buildings and infrastructure, such as the collection of greywater and rainwater harvesting for flushing toilets, irrigation, etc. The GPIWMP is strongly focussed on the environmental management principles and waste management hierarchy.

Gauteng Provincial Integrated Waste Management Policy

Sets out the vision, principles and strategic goals and objectives that the Gauteng Provincial Government will apply to achieve integrated and environmentally sustainable waste management in the Province. The applicant has taken these principles into account in the development of the fibre recovery plant.

Ekurhuleni Metropolitan Municipality Bioregional Plan

The purpose of a bioregional plan is to inform land-use planning, environmental assessment and authorisations, and natural resource management, by a range of sectors whose policies and decisions impact on biodiversity. This is done by providing a map of biodiversity priority areas, including Critical Biodiversity Areas and Ecological Support Areas, with accompanying land-use planning and decision-making guidelines.

Integrated Environmental Management Guideline Series (Guideline 5) Companion to the EIA Regulations 2010 published in Government Notice 805 (10 October 2012)

The aim of the guideline is to provide a detailed consideration of the practical implementation of the NEMA EIA Regulations. The guideline also provides guidance and clarity on the EA Process to be followed and the interpretation of the listed activities. The guideline was used as a reference document to the applicability of the NEMA EIA Regulations, 2014 on the proposed project.

Integrated Environmental Management Guideline Series (Guideline 7) Public Participation in the EIA Process published in Government Notice 805 (10 October 2012)

The guideline is intended to provide information on the benefits of public participation, the minimum legal requirements for the Public Participation Process (PPP), the steps of the PPP, guidelines for planning a PPP and a description of the roles and responsibilities of the various role-players. The guideline was referred to, to facilitate an adequate understanding of the execution of the PPP.

Applicable by-laws of the Ekurhuleni Metropolitan Municipality.

A by-law is considered a piece of legislation that is specific to the municipal area of jurisdiction. By-laws are intended to regulate the affairs and the services it provides within the municipal boundaries. A by-law is passed by the Council of a municipality

15 November 20019 31 18028

3. ALTERNATIVES

Describe the proposal and alternatives that are considered in this application. Alternatives should include a consideration of all possible means by which the purpose and need of the proposed activity could be accomplished. The determination of whether the site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances of the activity and its environment. The no-go option must in all cases be included in the assessment phase as the baseline against which the impacts of the other alternatives are assessed. Do not include the no go option into the alternative table below. Note: After receipt of this report the competent authority may also request the applicant to assess additional alternatives that could possibly accomplish the purpose and need of the proposed activity if it is clear that realistic alternatives have not been considered to a reasonable extent. Please describe the process followed to reach (decide on) the list of alternatives below

The applicant, Naturecell, required warehousing space of approximately 70m x 70m to install and operate the machinery required for the production of the cellulosic fibre mats. The new industrial park development, referred to as the Wadestone Industrial Park being developed by Growthpoint Properties, was identified as a suitable site and could provide all the necessary services and warehousing needs to operate the fibre recovery plant proposed by Naturecell. Growthpoint Properties had already undertaken an environmental impact assessment process for the greater industrial park development, after which an Environmental Authorisation (EA) was granted by GDARD. The applicant will, therefore, lease warehousing space within an authorized existing industrial park development. Therefore, no other site alternatives to lease were considered. In terms of technology alternatives, the applicant identified the Carding Airlaid Fusion Technology (CAFT) system developed and patented by Advance Nonwoven (https://advancenonwoven.dk) provided a significant advantage over traditional airlaid nonwovens systems thus giving the applicant a competitive advantage in entering the airlaid nonwovens industry. The traditional paper-based nonwoven technologies include mainly wetlaid (modified paper) systems designed to accommodate short synthetic fibers, as well as wood pulp fibers. Traditional paper-based nonwoven fabrics are manufactured with machinery designed to manipulate short fibers suspended in fluid. The advantages and benefits of the CAFT system compared to traditional paper-based wetlaid nonwoven technologies are provided in the table below.

Advance Nonwoven’s CAFT system Traditional nonwoven technologies

Avantages:

• Patented technology

• Produce fiber Length between 1 and 100 mm while maintaining capacity through whole range

• High capacity in kg/hour

• Process and technology can be optimised to operate without the need to use water

• Low amount of bonding fiber necessary

• Can process homogeneous and non-homogeneous materials

• Can produce low or high density products

• Allows processing of traditional fibres and new natural fibres or waste material at a high capacity of up to 2 tonnes per hour

• Several adjustment options for optimizing the output

Disadvantages:

• Traditional airlaid nonwovens industry operates with fibres in the 1-12 mm range

• Traditional carding industry with fibres in the range of 5-100mm

• In both cases, capacity is reduced as the fibre length increases

• Technologies mainly require a wetlaid process, i.e. require utilitsation of water in the process

• Due to wetlaid based technology, the manufacturing process require additional step to dry fibre product, resulting in additional energy consumption

Considering the clear competitive advantage the CAFT system offered, the applicant moved forward with considering the CAFT system only, as none of the traditional nonwoven technologies could provide a sufficient competitive advantage to ensure success to a new entrant in the airlaid nonwoven industry. Traditional nonwoven technologies were therefore not considered feasible to reach the developer’s objectives and was not considered further as a reasonable and feasible alternative. During further consideration of the CAFT system and in consultation with the developing company, Advance onwoven, two variations of the CAFT system were considered, i.e.

1. CAFT with Direct Applied Liquid Technology (DALT), and 2. CAFT without Direct Applied Liquid Technology (DALT).

The Direct Applied Liquid Technology system sprays the fibre product with a fire retardant liquid at a controlled flow as it passes in the pipe, and it automatically halts when no products is present. This step in the process

https://advancenonwoven.dk/

15 November 20019 32 18028

thus require water in the process to impregnate the fibres with the fire retardant compound. Water for the spray system is stored in two tanks, which are temperature controlled up to a temperature of 40°C. The disadvantage of the CAFT system with the DALT system is not only require the utilisation in water, but also require the water system to be maintained at 40°C. This process thus require large volumes of water and an energy consumption need that could be double that of the CAFT system without the DALT. Considering the clear competitive advantage the CAFT system without DALT offered, the applicant moved forward with considering the CAFT without DALT technology only. The CAFT with DALT system cannot provide a sufficient competitive advantage to ensure success to a new entrant in the airlaid nonwoven industry and was therefore not considered further as a reasonable and feasible alternative. In conclusion the proposed CAFT (without DALT) system is internationally recognized as the most efficient process to recover cellulosic fibres from newsprint. No other technologies were therefore considered.

Provide a description of the alternatives considered

No.

Alternative type, either alternative: site on property, properties, activity, design, technology, energy, operational or other (provide details of “other”)

Description

1 Proposal (Site on property)

The proposed manufacturing plant will be located on site 6 within the Wadestone Industrial Park. Site 6 is located in the northwestern portion of the industrial park and fulfills all the proposed manufacturing plant’s needs and requirements. The site is already serviced with sufficient electrical capacity and has access to the Sasol Gas pipeline.

2 Alternative 1

3 Alternative 2

1 Proposal (Properties)

The proposed activity is located on Portion 273 of the farm Kilppoortie 110 IR and Erf 876 Wadeville X 50 which falls within the jurisdiction of the Ekurhuleni Metropolitan Municipality. The site is located north of Moore street, east of Arnold Road, south of Lamp / Snapper street and west of Osborn road. The site is within an existing industrial park and is very well suited to industrial uses due to its location in an existing industrial node along the N17 Freeway.

2 Alternative 1

3 Alternative 2

1 Proposal (Technology)

The proposed technology to be used is the Carding Airlaid Fusion Technology (CAFT). The traditional airlaid nonwovens industry operates with fibres in the 1-12 mm range, and the traditional carding industry with fibres in the range of 5-100mm. In both cases, capacity is reduced as the fibre length increases. With CAFT, fibres from 1-100 mm can be accommodated while capacity is maintained regardless of the fibre length. In addition, CAFT can process both homogeneous and non-homogeneous materials. This allows the processing of both traditional fibres and new natural fibres or waste material at a high capacity of up to 2 tonnes per hour.

2 Alternative 1

3 Alternative 2

1 Proposal (Energy)

The proposed CAFT and manufacturing process will be operated using an electricity supply of 1.2 MVA power, which has already been catered for in the greater Wadestone Industrial Park development, while the oven will be fuelled with natural gas obtained from a 3rd party service provider.

2 Alternative 1

3 Alternative 2

1 Proposed Activity

The proposed manufacturing plant will recover cellulosic fibres from pre- and post-consumer newsprint through a process that will utilise Carding Airlaid Fusion Technology (CAFT) to produce fibre mats that are used as an insulating material. The value chain is described hereunder in relation to the numbered diagram below. A manufacturing process flow diagram is provided in Figure 11, while an A3 version for the process flow diagram is included in Appendix C-5.

15 November 20019 33 18028

Figure 8: Facility layout

1. Delivery of input material

Pre- and post-consumer newsprint will be delivered in bales to the recovery/manufacturing plant by a 3rd party services provider, Wykco Recycling. 32 bales of double sorted newsprint of approx. 1000kg’s each will be delivered on a tautliner (curtainsider) truck (Figure 9) daily.

Figure 9. Example of a Tautliner truck and trailer

2. Offloading and storage The pre- and post-consumer newsprint bales will be offloaded by forklift and stored in the northeastern corner of the warehouse, identified by numeral 2. This designated area will store a maximum of 128 bales of pre-and post-consumer newsprint, which will be arranged in 8 rows with 8 bales per row and can be double stacked with a second layer of bales on top of the 64 placed bales.

3. Unbaling and In-feed From the storage area (2) bales are brought to the load table area by forklift where the bales area untied manually and taken apart. The sorted paper is loaded onto the load table by an operator with a mini loader machine. The loaded paper moves with the conveyer passing a

1

2 3 4

5 Paper bale storage

Chemical storage

Final product storage

6

7

8

9

10

Shredder

Trap unit

Hammer mill

Fiberizer

15 November 20019 34 18028

metal detector unit which scans for any metal that may have been missed in the supplier's sorting process.

4. Shredding and fiberizing line From the paper loading conveyer (3) the paper drops into the shredder and is shredded down to hand size pieces. The paper is vacuumed from the shredder to a trap unit, where unwanted objects and other impurities are removed. Passing the trap unit, the fan feeds the paper into a whirlwind hammer mill where the paper is reduced to postage stamp size. The fire-retardant chemicals are introduced at this point and impregnated into the fibres. From here the paper pieces are vacuumed from the hammermill into the fiberizer where the paper pieces are ground down to fibres of varying lengths.

5. Dry Chemical blending line A ribbon blender is used to blend Ammonium sulphate ((NH4)2SO4, CAS No: 7783-20-2) and Boric acid (BH3O3, CAS No: 10043-35-3) in a fixed ratio. These chemicals are used as fire retardants in the manufacturing process and are stored near the blending line (5). Ammonium sulphate and Boric acid are not listed as hazardous substances in SANS 10234 supplement: SANS 10234A:2008 List of classification and labelling of chemicals in accordance with the Globally Harmonized System (GHS). Approximately 2.8 tons per day (TPD) of Ammonium sulphate and 0.9 TPD of Boric acid will be consumed by the process.

6. Fibre storage and Blend line Cellulose fibres extracted from the fiberizer are vacuumed into a storage bin prior to entering the blending line. Bicomponent PP/PET (bico) fibres are discharged from bulk bags into a hopper from which they are loaded onto a conveyer and added in a fixed ratio to the cellulose fibre drawn from the storage bin in a controlled process. The blend line mixes the cellulose and bico fibres to form a homogenous mix which is then delivered to the CAFT system via a fan where the mat-forming process starts.

7. CAFT process The CAFT forms the web of product that the mat (product) consists of (Figure 10). The Human Machine Interface (HMI) is the central control unit for the process. This controls all settings and motor speeds on the CAFT system, and feed control from the blend line. From the CAFT a continuous mat product exits onto the oven conveyer.

Figure 10: Fibre mat product

8. Oven line The mat product enters the oven, via the oven conveyer, where the thermo-bonding process takes place. The oven is equipped with temperature and airflow control for each section of the oven. When the mat product exits the oven it passes directly to the cooling section, which dissipates the residual thermal energy left in the mat product with fans pulling ambient air through the product. This process stabilises the formed mat product.

15 November 20019 35 18028

9. Cutting

The mat passes on to the cutting section where it is cut by longitudinal and transversal slitters into batts at the specified length and width. The height of the mat is determined by the forming setup and height set for the oven.

10. Packaging From the cutter, the batts pass on the roller table into the stacker where they a stacked for wrapping. The formed stack passes on the rolling table into the wrapping machine, which wraps the stack in polyethylene foil and welds the foil together around the stack. The package then exits the wrapper and is passed to a holding table, where an operator manually loads the package onto a mobile stillage. When the stillage is filled, the stillage is removed by a forklift and stacked in the designated product storage area (10).

Figure 11: Manufacturing Process Flow

Waste generation No floor drains exist within the warehouse area as all cleaning will be done by vacuum and/or sweeping. As a rule, the applicant will not use water for process cleaning as it will cause damage to both raw materials and finished goods, thus the manufacturing process will not produce waste (“dirty”) water. The only process waste generated will be the packaging materials used in the supply of the raw materials, specifically bulk bags used in the supply of Ammonium sulphate and bico fibre. Boric acid will be supplied in 25kg paper bags, which is intended to be included in the raw materials feedstock and therefore consumed in the manufacturing process. A small amount of galvanised wire that is used to bind the paper bales will be collected and stored temporarily prior to recycling. All disposable waste will be collected in skips, which will be located within a designated refuse yard located next to the access road leading to the facility within the development footprint. The refuse yard is enclosed with access control. The skips will be collected by a third-party service provider for disposal to an appropriately licenced landfill. The applicant has attempted to find a local recycling operation to recycle polyprop bulk bags but have been unable to locate such an operation raising doubt whether such an operation exists in SA currently. The applicant’s operation is therefore aligned with the waste management hierarchy. The manufacturing process is already optimised to reduce the generation of waste during the process, especially with the optimisation of the process to negate the use of water in the process (avoidance of wastewater generation). Other waste such as paper bags are re-used and recycled, with the remainder of non-reusable and non-recyclable waste being disposed. All out of specification product will be recovered and recycled within the process thus no direct process waste will be generated.

15 November 20019 36 18028

Potential emissions The manufacturing process described above includes operation of an oven, which will be operated through combustion of natural gas. An air quality specialist was appointed to assess whether significant emissions would be generated in terms of the National Environmental Management: Air Quality Act, No. 39 of 2004, as amended, and the “List of Activities which result in atmospheric emissions” (GN 893). Based on the manufacturing process details and plant specifications provided, the specialist concluded that the heat input per unit is significantly below (<0.25 MW) the threshold trigger of 50 MW (GN 893, Category 1, Sub-category 1.4). Furthermore, the processing of the recycled fibre is limited to a maximum of 130°C and no thermal decomposition/reaction of the cellulose fibre occurs. Thus, this description does not meet the definition of “thermal treatment” (GN 893, Category 8, Sub-category 8.1). Lastly, no chlorine dioxide is used or produced in the process (GN 893, Category 9, Sub-category 9.4), therefore no significant emissions will be generated by the fibre recovery and manufacturing process. The air quality specialist memorandum is included as Appendix G-1 to this application form. Potential noise generation The manufacturing process described above include operation of a shredder, hammermill, conveyor and fans during the manufacturing process. An noise specialist was appointed to assess whether significant noise would be generated in terms of the Gauteng Noise Control Regulations (The Gauteng Provincial Government, 1999) and SANS 10103:2008 ‘The measurement and rating of environmental noise with respect to annoyance and to speech communication’ (SABS, 2008). Based on the provided information relating to the manufacturing process, site location and conservative high-level screening calculation, the noise specialist concluded that the potential noise levels at both the potential sensitive receptors and nearby industrial receptors are anticipated to be below the relevant noise limits in terms of the NCRs and SANS limits. Furthermore, in the context of the existing industrial area, the baseline noise levels are anticipated to be relatively high from the existing industry and is likely to mask the contribution of the proposed facility. The specialist concluded that the facility may not require a detailed noise modelling study. The noise specialist memorandum is included as Appendix G-2 to this application form. Bulk services Bulk water supply will be obtained from the Ekurhuleni Metropolitan Municipality (EMM) via existing bulk water supply infrastructure. A layout drawing showing bulk water supply is included in Appendix F-3 to this application. It is anticipated that 1.2 MVA power will be required, and has already been catered for in the greater Wadestone Industrial Park Development. Bulk stormwater infrastructure has furthermore been constructed as part of the greater Wadestone Industrial Park Development, therefore stormwater originating within the fibre recovery plant footprint will be channelled to existing stormwater drains to the bulk stormwater infrastructure installed. Layout drawings showing bulk stormwater infrastructure servicing the greater Wadestone Industrial Park Development are included in Appendix F-4 to this application form. Ablution facilities within the plant will tie into existing sewerage infrastructure servicing the greater Wadestone Industrial Park Development.

2 Alternative 1

3 Alternative 2

In the event that no alternative(s) has/have been provided, a motivation must be included in the table below.

Alternative sites within properties not considered: No alternative sites within the Wadestone Industrial Park development were considered as the proposed site (Site 6) was the only suitable site available to the applicant to lease within the development. Tenants for the other sites have already either been secured or are under negotiation. Alternative properties not considered: During the project development phase, the applicant identified the need for a site or property that could provide sufficient space to accommodate the development infrastructure and activities, were located close to existing industrial nodes and aligned with the available operational capital within which the plant was expected to operate. During the screening process for suitable industrial properties, the Wadestone Industrial Park development on Portion 273 of the farm Kilppoortie 110 IR and Erf 876 Wadeville X 50 was identified at the only suitable site that could meet the

15 November 20019 37 18028

development requirements. The site is within an existing industrial park and is very well suited to industrial uses due to its location to an existing industrial node along the N17 Freeway. No other properties were subsequently considered. Furthermore the site needed to have sufficient electrical capacity readily available with access to the Sasol Gas pipeline. Alternative technologies not considered: Assessment of available technologies to produce nonwoven fibre mats identified Carding Airlaid Fusion Technology (CAFT) as the most suitable technology based on several advantages and benefit when compared to alternative manufacturing processes. That fact that CAFT could process fibres from both homogeneous and non-homogeneous materials within the range of 1-100 mm, while maintaining a high capacity regardless of the fibre length contributed to selecting this technology as the preferred alternative. Furthermore, the fact that this technology could be optimized to negate the use of water in the process and cutting energy consumption by half convinced the applicant not to consider alternative manufacturing processes that could not match the obvious benefits or were less sustainable than the CAFT. No alternative technologies were therefore considered. Alternative energy sources not considered: Alternative energy sources, apart from the electricity and natural gas, have not been considered as the CAFT infrastructure has been design specifically for use of electricity and natural gas (oven). No design alternatives were considered as the design and construction of the warehousing infrastructure is not within the control of the applicant. The Wadestone Industrial Park has been designed and developed by Growthpoint Properties.

4. PHYSICAL SIZE OF THE ACTIVITY

Indicate the total physical size (footprint) of the proposal as well as alternatives. Footprints are to include all new infrastructure (roads, services etc), impermeable surfaces and landscaped areas:

Size of the activity:

Proposed activity (Total environmental (landscaping, parking, etc.) and the building footprint)

1.08 ha

Alternatives:

Alternative 1 (if any)


Ha/ m2 or, for linear activities:

Length of the activity:

Proposed activity

Alternatives:



m/km Indicate the size of the site(s) or servitudes (within which the above footprints will occur):

Size of the site/servitude:

Proposed activity (Wadestone Industrial Park footprint)

11.46 ha

Alternatives:



Ha/m2

5. SITE ACCESS Proposal

Does ready access to the site exist, or is access directly from an existing road? YES

If NO, what is the distance over which a new access road will be built

Describe the type of access road planned:

15 November 20019 38 18028

Site access to the greater industrial park is gained from the north via Chaperone Road through an access-controlled entrance with security checkpoint. This entrance and security checkpoint is already fully functional and were developed as part of the Wadeville Ext 51 development authorised in terms of an existing Environmental Authorisation (GAUT 002/17-18/E2053). Traffic associated with greater industrial park A Traffic Impact (TIA) Study was undertaken by Aurecon (Pty) Ltd, as part of the abovementioned Wadeville Ext 51 development, to assess anticipated traffic flows and impacts to and from the entire industrial park development. This TIA is included in Appendix G-7. The TIA found that Wadeville Ext. 51 did not have access from the surrounding public roads. Since Ext 51 forms part of the greater industrial park with the development on Ext 50, the two sites are planned to share an existing access currently serving Ext. 50. The site is currently served by three vehicle accesses which will be retained to serve the proposed development. The existing access is off Chaperone Road and has one lane in each direction which extend to two lanes to service the two inbound and two outbound lanes at the access gate. The TIA further calculated that the greater industrial development would generate 108 trips during both the AM and PM peak hour. In terms of Public and Non-motorised Transport (NMT), it is expected that the greater industrial park will generate public transport trips. There are currently no bus stops or minibus taxi lay-bys in the vicinity of the site however public transport can be accessed along Osborn Road which is about 450m from the site. It is anticipated that the development will generate NMT trips which also include public transport users who need to walk to and from public transport facilities. In order to promote a safe environment for NMT users the Ext. 50 TIA recommended 2m wide sidewalks along the southern boundary of Lamp Road from Osborn Road to Snapper Road as well as along the southern boundary of Chaperone Road from Lamp Road to the site access. This would also be sufficient for the proposed Ext. 51 development as well. It should be noted that much of the southern boundary of Lamp Road is already paved. The TIA concluded that in order to mitigate the impact of development traffic at the Lamp Road / Osborn Road intersection, it recommended the following optimisations and improvements:

• Signal optimisation

• 60m slip lane in the westbound direction on Osborn Road

• extension of existing right-turning lane, from 60m to 90m in the southbound direction of Osborn Road Traffic associated with the operation of the proposed fibre recovery and manufacturing plant Potential traffic to and from the proposed fibre recovery and manufacturing plant was further considered in this application. Considering that the TIA undertaken by Aurecon in 2017 estimated that approximately 108 trips would be generated by the greater industrial park during both the AM and PM peak hour, the applicant conducted a study on the number of trips that would be required from an operations and staffing perspective. Based on the proportionate land area, the Naturecell premises were allocated 40 of the 108 peak hour trips. Based on calculation made by the applicant it was estimated that the anticipated number of peak hourly trips would fall within the levels stipulated in the TIA. A memo showing the assumptions and calculations made by the applicant is included in Appendix G-8.

Include the position of the access road on the site plan (if the access road is to traverse a sensitive feature the impact thereof must be included in the assessment). Alternative 1

Does ready access to the site exist, or is access directly from an existing road? YES NO

If NO, what is the distance over which a new access road will be built m


Include the position of the access road on the site plan. (if the access road is to traverse a sensitive feature the impact thereof must be included in the assessment). Alternative 2

Does ready access to the site exist, or is access directly from an existing road? YES NO

If NO, what is the distance over which a new access road will be built m


Include the position of the access road on the site plan. (if the access road is to traverse a sensitive feature the impact thereof must be included in the assessment).

15 November 20019 39 18028

PLEASE NOTE: Points 6 to 8 of Section A must be duplicated where relevant for alternatives

(only complete when

applicable)

6. LAYOUT OR ROUTE PLAN

A detailed site or route (for linear activities) plan(s) must be prepared for each alternative site or alternative activity. It must be attached to this document. The site or route plans must indicate the following: ➢ the layout plan is printed in colour and is overlaid with a sensitivity map (if applicable); ➢ layout plan is of acceptable paper size and scale, e.g.

o A4 size for activities with development footprint of 10sqm to 5 hectares; o A3 size for activities with development footprint of ˃ 5 hectares to 20 hectares; o A2 size for activities with development footprint of ˃20 hectares to 50 hectares); o A1 size for activities with development footprint of ˃50 hectares);

➢ The following should serve as a guide for scale issues on the layout plan:

o A0 = 1: 500 o A1 = 1: 1000 o A2 = 1: 2000 o A3 = 1: 4000 o A4 = 1: 8000 (±10 000)

A Layout Plan Map of the proposed development is included in Appendix A-2. ➢ shapefiles of the activity must be included in the electronic submission on the CD’s; Shapefiles of the proposed development are included on a Memory Stick included with the hardcopy. ➢ the property boundaries and Surveyor General numbers of all the properties within 50m of the site; Property boundaries and SG numbers of all properties within 50m of the development site is included as a Neighbouring Properties Map in Appendix A-3. ➢ the exact position of each element of the activity as well as any other structures on the site; A Layout Plan Map of the proposed development, including all elements and structures within the site is included as Appendix A-2. ➢ the position of services, including electricity supply cables (indicate above or underground), water supply

pipelines, boreholes, sewage pipelines, septic tanks, stormwater infrastructure; ➢ servitudes indicating the purpose of the servitude; An Infrastructure, Bulk Services and Servitudes Map for the proposed site is included in Appendix A-5. ➢ sensitive environmental elements on and within 100m of the site or sites (including the relevant buffers as

prescribed by the competent authority) including (but not limited thereto): o Rivers and wetlands; o the 1:100 and 1:50 year flood line; o ridges; o cultural and historical features; o areas with indigenous vegetation (even if it is degraded or infested with alien species);

➢ Where a watercourse is located on the site at least one cross section of the water course must be included (to allow the position of the relevant buffer from the bank to be clearly indicated)

A Historic and Current Site Sensitivity Map for the proposed site is included in Appendix A-6 and Appendix A-7, respectively. FOR LOCALITY MAP (NOTE THIS IS ALSO INCLUDED IN THE APPLICATION FORM REQUIREMENTS)

➢ the scale of locality map must be at least 1:50 000. For linear activities of more than 25 kilometres, a smaller

scale e.g. 1:250 000 can be used. The scale must be indicated on the map; ➢ the locality map and all other maps must be in colour; ➢ locality map must show property boundaries and numbers within 100m of the site, and for poultry and/or

piggery, locality map must show properties within 500m and prevailing or predominant wind direction;

Section A 6-8 has been duplicated 0 Number of times

15 November 20019 40 18028

➢ for gentle slopes the 1m contour intervals must be indicated on the map and whenever the slope of the site

exceeds 1:10, the 500mm contours must be indicated on the map; ➢ areas with indigenous vegetation (even if it is degraded or infested with alien species); ➢ locality map must show exact position of development site or sites; ➢ locality map showing and identifying (if possible) public and access roads; and ➢ the current land use as well as the land use zoning of each of the properties adjoining the site or sites.

A Locality Map for the proposed site is included in Appendix A-1.

7. SITE PHOTOGRAPHS

Colour photographs from the center of the site must be taken in at least the eight major compass directions with a description of each photograph. Photographs must be attached under the appropriate Appendix. It should be supplemented with additional photographs of relevant features on the site, where applicable. Site photographs in each of the eight cardinal directions are included in Appendix B.

8. FACILITY ILLUSTRATION

A detailed illustration of the activity must be provided at a scale of 1:200 for activities that include structures. The illustrations must be to scale and must represent a realistic image of the planned activity. The illustration must give a representative view of the activity to be attached in the appropriate Appendix. Facility Illustrations for the proposed development are provided in Appendix C.

15 November 20019 41 18028

SECTION B: DESCRIPTION OF RECEIVING ENVIRONMENT

Note: Complete Section B for the proposal and alternative(s) (if necessary) Instructions for completion of Section B for linear activities

1) For linear activities (pipelines etc) it may be necessary to complete Section B for each section of the site that has a significantly different environment.

2) Indicate on a plan(s) the different environments identified 3) Complete Section B for each of the above areas identified 4) Attach to this form in a chronological order 5) Each copy of Section B must clearly indicate the corresponding sections of the route at the top of the

next page.

Instructions for completion of Section B for location/route alternatives

1) For each location/route alternative identified the entire Section B needs to be completed 2) Each alterative location/route needs to be clearly indicated at the top of the next page 3) Attach the above documents in a chronological order

(complete only when appropriate)

Instructions for completion of Section B when both location/route alternatives and linear activities are applicable for the application Section B is to be completed and attachments order in the following way

• All significantly different environments identified for Alternative 1 is to be completed and attached in a chronological order; then

• All significantly different environments identified for Alternative 2 is to be completed and attached chronological order, etc.

Section B - Section of Route N/A (complete only when appropriate for above)

Section B – Location/route Alternative No. N/A (complete only when appropriate for above)

1. PROPERTY DESCRIPTION

Property description: (Including Physical Address and Farm name, portion etc.)

The proposed site is located on Portion 273 of the Farm Kilppoortie 110 IR and Erf 876 Wadeville X 50 which falls within the jurisdiction of the Ekurhuleni Metropolitan Municipality. The site is located north of Moore street, east of Arnold Road, south of Lamp / Snapper street and west of Osborn road.

2. ACTIVITY POSITION

Indicate the position of the activity using the latitude and longitude of the centre point of the site for each alternative site. The co-ordinates should be in decimal degrees. The degrees should have at least six decimals to ensure adequate accuracy. The projection that must be used in all cases is the WGS84 spheroid in a national or local projection.

Alternative: Latitude (S): Longitude (E):

1. Project Proposal 26.273970° 28.193213°

In the case of linear activities: Alternative: Latitude (S): Longitude (E):

• Starting point of the activity o o

Section B has been duplicated for sections of the route 0 times

Section B has been duplicated for location/route alternatives

0 times

15 November 20019 42 18028

• Middle point of the activity o o

• End point of the activity o o

For route alternatives that are longer than 500m, please provide co-ordinates taken every 250 meters along the route and attached in the appropriate Appendix

Addendum of route alternatives attached N/A

The 21 digit Surveyor General code of each cadastral land parcel

PROPOSAL T 0 I R 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 2 7 3

PROPOSAL T 0 I R 0 7 0 9 0 0 0 0 0 0 8 6 3 0 0 0 0 0

ALT. 1

ALT. 2

etc.

3. GRADIENT OF THE SITE

Indicate the general gradient of the site.

Flat 1:50 – 1:20 1:20 – 1:15 1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5 Steeper than 1:5

4. LOCATION IN LANDSCAPE Indicate the landform(s) that best describes the site.

Ridgeline Plateau Side slope of hill/ridge

Valley Plain Undulating

plain/low hills River front

5. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE

a) Is the site located on any of the following?

Shallow water table (less than 1.5m deep) NO

Dolomite, sinkhole or doline areas NO

Seasonally wet soils (often close to water bodies) NO

Unstable rocky slopes or steep slopes with loose soil NO

Dispersive soils (soils that dissolve in water) NO

Soils with high clay content (clay fraction more than 40%) NO

Any other unstable soil or geological feature NO

An area sensitive to erosion NO

(Information in respect of the above will often be available at the planning sections of local authorities. Where it exists, the 1:50 000 scale Regional Geotechnical Maps prepared by Geological Survey may also be used).

b) are any caves located on the site(s)

NO

If yes to above provide location details in terms of latitude and longitude and indicate location on site or route map(s) Latitude (S): Longitude (E):

o o

c) are any caves located within a 300m radius of the site(s)

NO


o o

d) are any sinkholes located within a 300m radius of the site(s)

NO

15 November 20019 43 18028


o o

If any of the answers to the above are “YES” or “unsure”, specialist input may be requested by the Department

6. AGRICULTURE

Does the site have high potential agriculture as contemplated in the Gauteng Agricultural Potential Atlas (GAPA 4)?

NO

Please note: The Department may request specialist input/studies in respect of the above.

7. GROUNDCOVER To be noted that the location of all identified rare or endangered species or other elements should be accurately indicated on the site plan(s). Indicate the types of groundcover present on the site and include the estimated percentage found on site

Natural veld - good condition

% =

Natural veld with scattered aliens

=60%

Natural veld with heavy alien infestation

% =

Veld dominated by alien species

% =

Landscaped (vegetation)

% =

Sport field % =

Cultivated land % =

Paved surface (hard landscaping)

=10%

Building or other structure

% =

Bare soil =100%

Please note: The Department may request specialist input/studies depending on the nature of the groundcover and potential impact(s) of the proposed activity/ies.

An ecological assessment conducted by Eco Assessments cc in 2017 indicated that the following was found on site: Floral Assessment The site was located on Carltonville Dolomite Grassland vegetation type according to Mucina and Rutherford (2006). This vegetation type makes two intrusions into the landscape in this region, one north and one south of Johannesburg. The conservation status of this vegetation type is Vulnerable due to urbanization as well as the lack of this vegetation type statutorily conserved. Vegetation units identified within the study area included natural grassland (Eragrostis racemose), disturbed grassland (Cynodon dactylon) and altered grassland (Tagetes minuta). The natural grassland patches most resembled the original vegetation and consisted of a mix of grasses and forbs with some tree species present. Some areas were dominated by Eragostis chloromelas, while other areas were dominated by Themeda triandra. A large portion of the site vegetation has been altered, allowing for the invasion of several and a variety of exotic species. Some disturbance is historic such as dumped rock heaps in the southwestern corner and central portion of the site. Altered grassland made up approximately 60% of the site. The ecological study further concluded that, according to GDARD, there are no recorded Red Data flora species records for the site or in the vicinity of the site. One Fabaceae species has previously been recorded within 5 km of the site. The habitat of this species is described as Highveld Grassland which is what was present on site. It was concluded that there is a low chance that this species would occur on-site, due to limited undisturbed habitat available as well as due to historic disturbances on surrounding land. Fauna Assessment The habitat presented on the site for birds includes mostly grassland, with some tree habitat in the form of indigenous and exotic trees. Grassland is known to support a wide variety of species including larks, pipits, Korhaans, lapwings and the like. Subsequently the pentad information provided by the South African Bird Atlas Program 2 (SABAP2) indicates a high species count of 196 species of which a large part is grassland birds.

15 November 20019 44 18028

The ecological specialist also concluded that a range of smaller mammal species such as mongoose, rats and mice could have been be present on site due to site consisting of open, rural land and being connected to undeveloped land southwards. Habitats on site where reptiles could potentially be found included dumped rock heaps, holes made by other species and dense grassy areas. Common species such as snakes and lizards are likely to occur abundantly on the site. Twelve amphibian species are listed for the area including common species such as Red toad, Bubbling Kassina and Guttural Toad. No species are listed for the area with a Near Threatened or higher conservation status. Current ground cover on site It must be noted that the assessment undertaken by Eco Assessment cc in 2017 was conducted before Growthpoint Development was granted authorisation to undertake the Wadeville Extension 51 development. The development site has subsequently been cleared with the site now consisting of landscaped bare soil.

Are there any rare or endangered flora or fauna species (including red list species) present on the site

NO

If YES, specify and explain:

Not Applicable

Are there any rare or endangered flora or fauna species (including red list species) present within a 200m (if within urban area as defined in the Regulations) or within 600m (if outside the urban area as defined in the Regulations) radius of the site.

NO


Not Applicable

Are there any special or sensitive habitats or other natural features present on the site?

NO


Not applicable

Was a specialist consulted to assist with completing this section

NO

If yes complete specialist details

Name of the specialist:

Qualification(s) of the specialist:

Postal address:

Postal code:

Telephone: Cell:

E-mail: Fax:

Are any further specialist studies recommended by the specialist?

NO

If YES, specify:

If YES, is such a report(s) attached? YES NO

If YES list the specialist reports attached below

Signature of specialist: Date:

Please note; If more than one specialist was consulted to assist with the filling in of this section then this table must be appropriately duplicated

15 November 20019 45 18028

8. LAND USE CHARACTER OF SURROUNDING AREA

Using the associated number of the relevant current land use or prominent feature from the table below, fill in the position of these land-uses in the vacant blocks below which represent a 500m radius around the site

1. Vacant land 2. River, stream,

wetland 3. Nature

conservation area 4. Public open

space 5. Koppie or

ridge

6. Dam or reservoir 7. Agriculture 8. Low density

residential 9. Medium to high density residential

10. Informal residential

11. Old age home 12. Retail 13. Offices 14. Commercial &

warehousing 15. Light industrial

16. Heavy industrialAN

17. Hospitality facility

18. Church 19. Education

facilities 20. Sport facilities

21. Golf course/polo fields

22. AirportN 23. Train station or

shunting yardN 24. Railway lineN

25. Major road (4 lanes or

more)N

26. Sewage treatment plantA

27. Landfill or waste treatment

siteA

28. Historical building

29. Graveyard 30.

Archeological site

31. Open cast mine 32. Underground

mine 33.Spoil heap or

slimes damA 34. Small Holdings

Other land uses (describe):

Note: More than one (1) Land-use may be indicated in a block Please note: The Department may request specialist input/studies

depending on the nature of the land use character of the area and potential impact(s) of the proposed activity/ies. Specialist reports that look at health & air quality and noise impacts may be required for any feature above and in particular those features marked with an “A “and with an “N” respectively.

Have specialist reports been attached YES

If yes indicate the type of reports below

Appendix G-1: Air Quality Assessment Opinion Letter Appendix G-2: Noise Assessment Opinion Letter

NORTH

WEST

9 9 9 9 31

EAST

14 14 14 14 2

14 14 14 9

14 2 2 2 9

14 9 9 34 8

SOUTH

NOTE: Each block represents an area of 250m X 250m, if your proposed development is larger than this please use the appropriate number and orientation of hashed blocks

= Site

15 November 20019 46 18028

9. SOCIO-ECONOMIC CONTEXT Describe the existing social and economic characteristics of the area and the community condition as baseline information to assess the potential social, economic and community impacts.

The site is located in Wadeville, which falls within the jurisdiction of the City of Ekurhuleni Metropolitan Municipality and located in Ward 39. Ekurhuleni houses 6% of the country’s population and 26% of Gauteng’s population. It has a resident population of approximately 3 178 470 million people and 1 015 645 million households. The municipality has an average annual population growth rate of 2.47%. Between 2001 and 2011, the number of households in Ekurhuleni increased by 36.1%, a figure which was above the average national growth of 35.7%. This growth in population holds serious service delivery implications since it translates into increased demand for municipal services. The municipality is home to 78.7% Africans, 15.8% Whites, 2.7% Colored, 2.1% Indians and 0.6% Other. The City of Ekurhuleni has persons aged 20+ with higher education at 14.6%, which ranks it the fourth South African Municipality with this Percentage. It also has persons aged 20+ with matric at 35.4%. The percentage of no schooling people at the age of 20+ is at 3.6% and it is the fourth municipality in the country (Stats SA). The unemployment rate in the City of Ekurhuleni is at 28.8% with the youth unemployment rate at 36.9%. Ekurhuleni has the highest rate of unemployed youth in Gauteng, City of Tshwane being in second place and City of Johannesburg being the third. According to Stats Sa, there are about 1, 6 million economically active individuals (i.e. those who are employed or unemployed but looking for work) residing within the municipality.

10. CULTURAL/HISTORICAL FEATURES Please be advised that if section 38 of the National Heritage Resources Act 25 of 1999 is applicable to your proposal or alternatives, then you are requested to furnish this Department with written comment from the South African Heritage Resource Agency (SAHRA) – Attach comment in appropriate annexure 38. (1) Subject to the provisions of subsections (7), (8) and (9), any person who intends to undertake a development categorized as- (a) the construction of a road, wall, powerline, pipeline, canal or other similar form of linear development or

barrier exceeding 300m in length; (b) the construction of a bridge or similar structure exceeding 50m in length; (c) any development or other activity which will change the character of a site- (i) exceeding 5 000 m2 in extent; or (ii) involving three or more existing erven or subdivisions thereof; or (iii) involving three or more erven or divisions thereof which have been consolidated within the past five years; or (iv) the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resource

authority; (d) the re-zoning of a site exceeding 10 000 m2 in extent; or (e) any other category of development provided for in regulations by SAHRA or a provincial heritage resources

authority, must at the very earliest stages of initiating such a development, notify the responsible heritage resources authority and furnish it with details regarding the location, nature and extent of the proposed development.

Are there any signs of culturally (aesthetic, social, spiritual, environmental) or historically significant elements, as defined in section 2 of the National Heritage Resources Act, 1999, (Act No. 25 of 1999), including archaeological or palaeontological sites, on or close (within 20m) to the site?

NO

If YES, explain: N/A

If uncertain, the Department may request that specialist input be provided to establish whether there is such a feature(s) present on or close to the site. Briefly explain the findings of the specialist if one was already appointed:

15 November 20019 47 18028

Heritage Site Assessment and Screening

A Site Assessment and Heritage Screening Report was undertaken by PGS Heritage (Pty) Ltd in July

2017 for the Wadeville Extension 51 development that encompass the western section of the Wadestone

Industrial Park development. PGS Heritage found that no significant heritage features were located

within the study area. Therefore, the heritage sensitivity of the study area is LOW. The Site Assessment

and Heritage Screening Report is attached as Appendix G-4.

Palaeontological Impact Assessment: Desktop Study

A desktop assessment was conducted by Dr. Heidi Fourie in August 2017. The assessment indicated

that the proposed development is taking place on the Black Reef Formation, Transvaal Supergroup,

Nixon et al. (1988) described the black shales south-west of Potchefstroom as consisting of overlapping

laminated basal mounds which are stromatolitic as well as spheroidal possible planktonic fossil algae.

These can range in size from 3.5 - 17 mm in height and up to 10 mm in diameter and can be present in

the development area. The construction of the industrial units will not intrude into the overlying recent

sandy and clayey deposits along the watercourse.

The Transvaal Supergroup fills an east-west elongated basin in the south-central part of the old

Transvaal (now North –West, Gauteng and Mpumalanga) as far south as Potchefstroom. It is Vaalian

in age, approximately 2600 Ma to 2100 Ma. A maximum thickness of the Transvaal Supergroup reaches

2000 m in the north-eastern section. The east-west elongated basin is filled with clastic, volcanic and

chemical sedimentary rocks. Three groups based on lithological differences have been established: they

are the Rooiberg, Pretoria and Chuniespoort Groups as well as other smaller groups (Kent 1980,

Snyman 1996). It is the Bushveld Complex that is responsible for the tilting of the Transvaal sediments

and the heat of its intrusion having created andalusite crystals (Norman and Whitfield 2006). This

Supergroup is underlain by the Ventersdorp, Witwatersrand and Pongola Supergroups, and the

Dominion Group. Three prominent ridges are present from the oldest to the youngest, the Time Ball Hill,

Daspoort and Magaliesberg Formations (Norman and Whitfield 2006). Fossils in South Africa mainly

occur in rocks of sedimentary nature and not in rocks from igneous or metamorphic nature.

The palaeontological specialist concluded that it is not necessary to undertake a Phase 1

Palaeontological Impact Assessment: Filed Study to determine whether the development will affect

fossiliferous outcrops. The palaeontological sensitivity is Moderate, so caution is recommended.

However, a Phase 1 Palaeontological Assessment or mitigation measures will be required if a fossil is

found during construction. The palaeontological specialist further recommended that if any

palaeontological material is uncovered or exposed during construction, excavation or blasting SAHRA

must be notified immediately. All construction activities must be stopped, and a palaeontologist should

be called in to determine proper mitigation measures. The Palaeontological Impact Assessment:

Desktop Study Report is attached as Appendix G-5.

Will any building or structure older than 60 years be affected in any way?

NO

Is it necessary to apply for a permit in terms of the National Heritage Resources Act, 1999 (Act 25 of 1999)?

NO

If yes, please attached the comments from SAHRA in the appropriate Appendix

15 November 20019 48 18028

SECTION C: PUBLIC PARTICIPATION (SECTION 41)

The Environmental Assessment Practitioner must conduct public participation process in accordance with

the requirement of the EIA Regulations, 2014.

1. LOCAL AUTHORITY PARTICIPATION

Local authorities are key interested and affected parties in each application and no decision on any application will be made before the relevant local authority is provided with the opportunity to give input. The planning and the environmental sections of the local authority must be informed of the application at least thirty (30) calendar days before the submission of the application to the competent authority.

Was the draft report submitted to the local authority for comment? YES

If yes, has any comments been received from the local authority? YES

If “YES”, briefly describe the comment below (also attach any correspondence to and from the local authority to this application):

During the public review period provided from 18 September to 21 October 2019 for review and comment on the Draft BAR, follow up correspondence with the City of Ekurhuleni (CoE) was undertaken. During this period the CoE requested an extension to the public review period, which was subsequently granted for the CoE and the comment period was extended for a further 3 weeks up to 8 November 2019. Comment from the CoE was received from Ms F Mabindisa from the CoE on 12 November 2019 in a letter dated 8 November 2019. Comments raised in the letter were considered and responses to the comments were provided in the Comments and Responses Report (CRR) included in Appendix E-6. Proof of correspondence with the CoE is provided in Appendix E-7. Comments raised by the CoE and responses provided in the CRR is included below for easy reference.

15 November 20019 49 18028

Comment from CoE Responses provided by EAP

1. The Department has assessed the environmental

parameters/constraints of property in question against the

following environmental management tools:

The Ekurhuleni Bioregional Plan, 2012. Gauteng Provincial

Environmental Management Framework (GPEMF), 2015

1.1 In terms of the Ekurhuleni Bioregional Plan, 2012, prior to

the current development, the property was falling within the

"Critical Biodiversity Area 1" category, which are areas

required to meet biodiversity pattern or threshold.

This statement is acknowledged. The original footprint of the

greater Wadestone Industrial Park does fall within a CBA. The

same footprint however, fall within Zone 1 and Zone 5 of the

Gauteng Provincial Environmental Management Framework

(GPEMF), 2015. The operator of the greater industrial park

applied for Environmental Authorisation for the entire footprint,

which was subsequently authorised by GDARD.

This application does not impact or destroy on any CBA footprint

or sensitive and endangered ecosystems.

Mathys Vosloo, EAP, Zitholele Consulting

1.2 In terms of Gauteng Provincial Environmental

Management Framework (GPEMF), 2015, the proposed

development site falls within two different zones:

Zone 1: (Urban Development Zone). The intention within this

zone is to streamline urban development activities in it and to

promote development infill, densification and concentration of

urban development in order to establish more effective and

efficient city region that will minimize urban sprawl into rural

areas.

The greater industrial park footprint fall within Zone 1 and Zone 5

of the Gauteng Provincial Environmental Management

Framework (GPEMF), 2015. The operator of the greater industrial

park applied for Environmental Authorisation for the entire

footprint, which was subsequently authorised by GDARD.


It should be noted that, the Minister of Environmental Affairs

published amendments to the NEMA: EIA Regulation and

listing notices on the 7 April 2017, it is therefore recommended

that, the content of the report should refer to the current

amendments,

Reference to the amendment of the EIA regulations is made in

section 2 (page 28 and 29) of the FBAR.


3, It has been stated on page 6 of the report that, the Water

Use License Application has been applied for this proposed

development and the applicant has applied for the licensing

of Section 21 (c) and (i), the statement is misleading

This paragraph have been amended to clarify who have

submitted the Water Use Licence Application.


4, The name of the newspaper were the advert was published

and the date as well is not appearing in the attached proof of

newspaper advertisement

The newspaper advertisement referred to which was included in

the Draft BAR is only the proof of advertisement which was

submitted prior to placement of the advertisement. The actual

advertisement was not included as the tearsheet was not

available yet at the time the DBAR was released to the public.

The actual newspaper teasheet which was placed in The Star on

Wednesday, September 18, 2019 has been included in the FBAR

as appendix E-3. This tearsheet clearly indicates the newspaper

and placement date at the top right corner of the newspaper

teasheet.


5, It is recommended that, the content in the attached draft

EMPr be adhered to

A recommendation of the FBAR is that the conditions of the EMPr

be adhered to during construction and operation of the facility.


If “NO” briefly explain why no comments have been received or why the report was not submitted if that is the case.

N/A

2. CONSULTATION WITH OTHER STAKEHOLDERS

Any stakeholder that has a direct interest in the activity, site or property, such as servitude holders and service providers, should be informed of the application at least thirty (30) calendar days before the submission of the application and be provided with the opportunity to comment.

15 November 20019 50 18028

Has any comment been received from stakeholders? YES

If “YES”, briefly describe the feedback below (also attach copies of any correspondence to and from the stakeholders to this application):

The only comment received from stakeholders was from Mr. Kade Guerreiro, which is acting as the shadow DA assigned councilor for ward 40 where the proposed development will be taking place. Mr. Guerreiro thanked the PP office for the email notification as well as follow up call to him and stated that he will go over all the details and respond accordingly, Mr. Guerreiro’s comment is captured in the CRR included in Appendix E-6. Proof of correspondence with the CoE is provided in Appendix E-7. No further correspondence were received from Mr. Guerreiro or any other stakeholder during the process.

If “NO” briefly explain why no comments have been received

N/A

3. GENERAL PUBLIC PARTICIPATION REQUIREMENTS

The Environmental Assessment Practitioner must ensure that the public participation process is adequate and must determine whether a public meeting or any other additional measure is appropriate or not based on the particular nature of each case. Special attention should be given to the involvement of local community structures such as Ward Committees and ratepayers associations. Please note that public concerns that emerge at a later stage that should have been addressed may cause the competent authority to withdraw any authorisation it may have issued if it becomes apparent that the public participation process was flawed. The EAP must record all comments and respond to each comment of the public / interested and affected party before the application report is submitted. The comments and responses must be captured in a Comments and Responses Report as prescribed in the regulations and be attached to this application.

4. APPENDICES FOR PUBLIC PARTICIPATION All public participation information is to be attached in the appropriate Appendix. The information in this

Appendix is to be ordered as detailed below

Appendix 1 – Proof of site notice

Appendix 2 – Written notices issued as required in terms of the regulations

Appendix 3 – Proof of newspaper advertisements

Appendix 4 –Communications to and from interested and affected parties

Appendix 5 – Minutes of any public and/or stakeholder meetings

Appendix 6 - Comments and Responses Report

Appendix 7 –Comments from I&APs on Basic Assessment (BA) Report

Appendix 8 –Comments from I&APs on amendments to the BA Report

Appendix 9 – Copy of the register of I&APs

15 November 20019 51 18028

SECTION D: RESOURCE USE AND PROCESS DETAILS

Note: Section D is to be completed for the proposal and alternative(s) (if necessary)

Instructions for completion of Section D for alternatives

1) For each alternative under investigation, where such alternatives will have different resource and process details (e.g. technology alternative), the entire Section D needs to be completed

4) Each alterative needs to be clearly indicated in the box below 5) Attach the above documents in a chronological order

(complete only when appropriate)

Section D Alternative No. 0 (complete only when appropriate for above)

1.WASTE, EFFLUENT, AND EMISSION MANAGEMENT Solid waste management

Will the activity produce solid construction waste during the construction/initiation phase?

YES

If yes, what estimated quantity will be produced per month? Growthpoint Properties are undertaking the construction of the warehousing/top structure in terms of the Environmental Authorisation issued by GDARD for the Wadeville Extension 51 development. This proposed development falls within the Wadeville Extension 51 development therefore solid waste management will be undertaken by Growthpoint Properties. The applicant will only take control of the leased property and infrastructure once the construction of the top structure has been completed. The applicant is therefore only responsible for operational activities associated with the development site.

How will the construction solid waste be disposed of (describe)?

In terms of the original Basic Assessment application undertaken on behalf of Growthpoint Properties, it was stated that building rubble and solid construction waste (such as sand gravel, concrete, and waste material) that cannot be used for filling and rehabilitation and other general waste generated during the construction phase will be removed from site and be disposed of at a licensed landfill site.

Where will the construction solid waste be disposed of (describe)?

All non-recyclable general waste will be removed by a registered waste management service provider from the site and be disposed of safely and responsibly at a licensed landfill site.

Will the activity produce solid waste during its operational phase? YES

If yes, what estimated quantity will be produced per month? 6 m3

How will the solid waste be disposed of (describe)?

Minimal waste will be generated during the operational phase. Packaging waste generated during the operational phase will be recycled back into the cellulose recovery system and waste that cannot be recycled will be removed via a 3rd party service provider and disposed of at a licensed landfill.

Has the municipality or relevant service provider confirmed that sufficient air space exists for treating/disposing of the solid waste to be generated by this activity?

YES

Where will the solid waste be disposed if it does not feed into a municipal waste stream (describe)?

The applicant has requested confirmation from EnviroServe Waste Management, who has provided the applicant with a quotation to remove waste to a registered landfill site managed by EnviroServe. The EnviroServe quotation is included in Appendix F-2.

Section D has been duplicated for alternatives 0 times

15 November 20019 52 18028

Note: If the solid waste (construction or operational phases) will not be disposed of in a registered landfill site or be taken up in a municipal waste stream, the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

Can any part of the solid waste be classified as hazardous in terms of the relevant legislation?

NO

If yes, inform the competent authority and request a change to an application for scoping and EIA.

Is the activity that is being applied for a solid waste handling or treatment facility? NO

If yes, the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

Describe the measures, if any, that will be taken to ensure the optimal reuse or recycling of materials:

Construction Phase Construction activities associated with the development of the Wadestone Industrial Park infrastructure were assessed in the original application (GAUT: 002/17-18/E2053) submitted on behalf of Growthpoint Properties and authorized by GDARD. Measures reported in the Basic Assessment Report is therefore repeated here for completeness. Recycling facilities for paper and glass will be available within the small waste transfer station on the property. General Waste Management

• Litter and rubble on the construction site and in the construction camp will be monitored strictly by a dedicated housekeeping team.

• All waste generated on-site will be separated into metal, paper, plastic, glass & contaminated paper, glass, plastic, and polystyrene and will be recycled.

Construction rubble

• All rubble from demolition activities will be used on-site as part of the existing development or will be taken off the construction site and disposed of at an appropriate landfill.

• No material shall be left on site that may harm man or animals. Broken, damaged and unused nuts, bolts and washers shall be picked up and removed from the site.

• Surplus concrete will not be dumped indiscriminately.

• Concrete water will be re-used in the batching process Operational Phase Minimal waste will be generated during the operational phase. Packaging and other waste generated during the operational phase will firstly be recycled back into the cellulose recovery system and waste that cannot be recycled will be removed via a 3rd party service provider and disposed of at a licensed landfill.

Liquid effluent (other than domestic sewage)

Will the activity produce effluent, other than normal sewage, that will be disposed of in a municipal sewage system?

NO

If yes, what estimated quantity will be produced per month? N/A

If yes, has the municipality confirmed that sufficient capacity exist for treating / disposing of the liquid effluent to be generated by this activity(ies)?

NO

Will the activity produce any effluent that will be treated and/or disposed of on site?

NO

If yes, what estimated quantity will be produced per month? N/A

If yes describe the nature of the effluent and how it will be disposed.

N/A

Note that if effluent is to be treated or disposed on site the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA

Will the activity produce effluent that will be treated and/or disposed of at another facility?

NO

If yes, provide the particulars of the facility:

Facility name:

Contact person:

Postal address:

Postal code:

Telephone: Cell:

E-mail: Fax:

Describe the measures that will be taken to ensure the optimal reuse or recycling of waste water, if any:

15 November 20019 53 18028

N/A

Liquid effluent (domestic sewage)

Will the activity produce domestic effluent that will be disposed of in a municipal sewage system?

YES

If yes, what estimated quantity will be produced per month? Unknown at this stage.

If yes, has the municipality confirmed that sufficient capacity exist for treating / disposing of the domestic effluent to be generated by this activity(ies)?

YES

Will the activity produce any effluent that will be treated and/or disposed of on site?

NO

If yes describe how it will be treated and disposed off.

N/A

Emissions into the atmosphere

Will the activity release emissions into the atmosphere? YES

If yes, is it controlled by any legislation of any sphere of government? YES

If yes, the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

If no, describe the emissions in terms of type and concentration:

Emissions will be released from the process oven during the manufacturing process. This potential release of emissions was discussed with the GDARD during the pre-application consultation meeting. The minutes of this meeting is attached in Appendix E-5. An air quality specialist was furthermore consulted to undertake a screening assessment on whether the potential emissions will trigger the need to undertake an Atmospheric Emission License (AEL) Application. The specialist, however, concluded based on the proposed manufacturing process and specifications of the plant that no listed activities in terms of the National Environmental Management: Air Quality Act, No. 39 of 2004, and associated List of activities (GN 893 of 22 November 2013, as amended) will be triggered by the proposed development. No AEL application is therefore required. The Air Quality Assessment Opinion Letter is attached in Appendix G-1.

2.WATER USE

Indicate the source(s) of water that will be used for the activity

municipal Directly from water board

groundwater river, stream, dam or lake

other the activity will not use water

If water is to be extracted from groundwater, river, stream, dam, lake or any other natural feature, please indicate

the volume that will be extracted per month: N/A

If Yes, please attach proof of assurance of water supply, e.g. yield of borehole, in the appropriate Appendix

Does the activity require a water use permit from the Department of Water Affairs? YES

If yes, list the permits required

The development site is located within 500m of a wetland, hence the owner of the industrial park development, Growthpoint Properties, must undertake a Section 21 (c) and (i) Water Use License Application (WULA). Growthpoint Properties appointed LEAP Landscape Architects and Environmental Planners to undertake the WULA. LEAP has confirmed that the WULA for Wadeville Extension 51 had been completed and already submitted to the Department of Water and Sanitation via the e-WULAAS portal. The Department of Water and Sanitation is currently reviewing the WULA submission.

If yes, have you applied for the water use permit(s)? YES, WULA compiled and submitted by LEAP Environmental on behalf of Growthpoint Properties, see above

If yes, have you received approval(s)? (attached in appropriate appendix)

NO

3.POWER SUPPLY

Please indicate the source of power supply e.g. Municipality / Eskom / Renewable energy source

Municipality – electricity is also available to service the new industrial stands

If power supply is not available, where will power be sourced from?

Renewable energy sources can be used for lighting .

15 November 20019 54 18028

4.ENERGY EFFICIENCY

Describe the design measures, if any, that have been taken to ensure that the activity is energy efficient:

The following energy savings methods shall be investigated for possible implementation for the proposed development:

• Use of energy-efficient lighting;

• Use of daylight wherever possible in lieu of artificial lighting;

• Use of renewable solar-powered lighting for external lighting;

• Switching off of all electrical appliances at night and times not in use;

• Use of high-efficient HVAC systems;

• Use of solar water heating;

• Setting thermostats of water heaters at the most efficient level;

• Insulation of hot water pipes and hot water storage tanks;

• Use of low-flow showerheads;

• Use of high-efficient electric motors;

• Use of control methods to reduce maximum demand and exploit off-peak electricity tariffs; and

• Insulation of windows, walls, ceilings, and roofs.

Describe how alternative energy sources have been taken into account or been built into the design of the activity, if any:

The original process design required the fire-retardant chemicals to be dissolved in water and spray applied to the fibre which would then be subject to a drying process. In reviewing the design it was decided to remove this dissolution process and apply the chemicals on a dry basis using what is known as a whirlwind mill to directly impregnate the fibres. Thus, the manufacturing process does not consume any water. As per the above change in technology for eliminating water consumption, the use of dry chemical processing eliminated the need for the additional step of drying the fibres which would be necessary if the wet process was used. This effectively reduces gas consumption in the process by half. Furthermore, high-efficiency motors will be used throughout the plant. The applicant’s waste minimisation and recycling policy include the recycling of all possible recyclable waste generated in the manufacturing process. For example, the applicant has requested raw materials to be supplied in paper bags which can then be consumed within the process as part of the raw material feedstock. Furthermore, waste polypropylene packaging materials will be stored in waste bins in a designated area for removal by a 3rd party who will reroute for recycling where possible. The design of the building has been tailored to accommodate the manufacturing line to optimise the use of space. The building is oriented approximately N-S with translucent roof panels along the length of the eastern roof hinge to take advantage of natural light in the building.

15 November 20019 55 18028

SECTION E: IMPACT ASSESSMENT

The assessment of impacts must adhere to the minimum requirements in the EIA Regulations, 2014, and should take applicable official guidelines into account. The issues raised by interested and affected parties should also be addressed in the assessment of impacts as well as the impacts of not implementing the activity (Section 24(4)(b)(i).

1.ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES

Summarise the issues raised by interested and affected parties.

Comments received during the review period will be incorporated into this section of the report and also included in the Comment and Responses Report (CRR) in Appendix E-6.

Summary of response from the practitioner to the issues raised by the interested and affected parties (including the manner in which the public comments are incorporated or why they were not included) (A full response must be provided in the Comments and Response Report that must be attached to this report):

Comments received during the review period will be addressed in this section of the report and also included in the Comment and Responses Report (CRR) in Appendix E-6.

2.IMPACTS THAT MAY RESULT FROM THE CONSTRUCTION AND OPERATIONAL PHASE

Briefly describe the methodology utilized in the rating of significance of impacts

Impact Assessment Methodology The impacts will be ranked according to the methodology described below. Where possible, mitigation measures will be provided to manage impacts. In order to ensure uniformity, a standard impact assessment methodology will be utilised so that a wide range of impacts can be compared with each other. The impact assessment methodology makes provision for the assessment of impacts against the following criteria, as discussed below. Nature of the impact Each impact should be described in terms of the features and qualities of the impact. A detailed description of the impact will allow for the contextualisation of the assessment. Extent of the impact Extent intends to assess the footprint of the impact. The larger the footprint, the higher the impact rating will be. The table below provides the descriptors and criteria for assessment.

Table 16: Extent of the Impacts

Extent Descriptor Definition Rating

Site Impact footprint remains within the boundary of the site. 1

Local Impact footprint extends beyond the boundary of the site to the adjacent surrounding areas.

2

Regional Impact footprint includes the greater surrounds and may include an entire municipal or provincial jurisdiction.

3

National The scale of the impact is applicable to the Republic of South Africa. 4

Global The impact has global implications. 5

Duration of the impact The duration of the impact is the period of time that the impact will manifest on the receiving environment. Importantly, the concept of reversibility is reflected in the duration rating. The longer the impact endures, the less likely it is to be reversible. See Table 17 for the criteria for rating duration of impacts.

Table 17: Duration of the Impacts

Duration Descriptor

Definition Rating

Construction/ Decommissioning phase only

The impact endures for only as long as the construction or the decommissioning period of the project activity. This implies that the impact is fully reversible.

1

Short term The impact continues to manifest for a period of between 3 and 5 years beyond construction or decommissioning. The impact is still reversible.

2

15 November 20019 56 18028

Medium term The impact continues between 6 and 15 years beyond the construction

or decommissioning phase. The impact is still reversible with relevant and applicable mitigation and management actions.

3

Long term The impact continues for a period in excess of 15 years beyond construction or decommissioning. The impact is only reversible with considerable effort in implementation of rigorous mitigation actions.

4

Permanent The impact will continue indefinitely and is not reversible. 5

Potential intensity of the impact The concept of the potential intensity of an impact is the acknowledgement at the outset of the project of the potential significance of the impact on the receiving environment. Potential intensity provides a measure for comparing significance across different specialist assessments. This is possible by aligning specialist ratings with the potential intensity rating provided here. This allows for better integration of specialist studies into the environmental impact assessment. See Table 18 and Table 19 below.

Table 18: Negative Potential Impacts

Potential intensity descriptor

Definition of negative impact Rating

High Significant impact to human health linked to mortality / loss of a species/endemic habitat.

16

Moderate-High Significant impact to faunal or floral populations / loss of livelihoods/individual economic loss.

8

Moderate Reduction in environmental quality / loss of habitat / loss of heritage / loss of welfare amenity

4

Moderate-Low Nuisance impact 2

Low Negative change with no associated consequences. 1

Table 19: Positive Potential Impacts

Potential intensity descriptor

Definition of positive impact Rating

Moderate-High Net improvement in human welfare 8

Moderate Improved environmental quality/improved individual livelihoods 4

Moderate-Low Economic development 2

Low Positive change with no other consequences. 1

It must be noted that there is no HIGH rating for positive impacts under potential intensity, as it must be understood that no positive spinoff of an activity can possibly raises a similar significance rating to a negative impact that affects human health or causes the irreplaceable loss of a species. Likelihood of the impact This is the likelihood of the impact potential intensity manifesting. This is not the likelihood of the activity occurring. If an impact is unlikely to manifest, then the likelihood rating will reduce the overall significance. Table 20 provides the rating methodology for likelihood. The rating for likelihood is provided in fractions in order to provide an indication of percentage probability, although it is noted that mathematical connotation cannot be implied to numbers utilised for ratings.

Table 20: Likelihood of Impacts

Likelihood descriptor

Definition Rating

Improbable The possibility of the impact occurring is negligible and only under exceptional circumstances.

0.1

Unlikely The possibility of the impact occurring is low with a less than 10% chance of occurring. The impact has not occurred before.

0.2

Probable The impact has a 10% to 40% chance of occurring. Only likely to happen once in every 3 years or more.

0.5

Highly probable It is most likely that the impact will occur and there is a 41% to 75% chance of occurrence.

0.75

Definite More than a 75% chance of occurrence. The impact will occur regularly.

1

Cumulative Impacts

15 November 20019 57 18028

Cumulative impacts are reflected in the in the potential intensity of the rating system. In order to assess any impact on the environment, cumulative impacts must be considered in order to determine an accurate significance. Impacts cannot be assessed in isolation. An integrated approach requires that cumulative impacts be included in the assessment of individual impacts. The nature of the impact should be described in such a way as to detail the potential cumulative impact of the activity. Significance Assessment The significance assessment assigns numbers to rate impacts in order to provide a more quantitative description of impacts for purposes of decision making. Significance is an expression of the risk of damage to the environment, should the proposed activity be authorised. To allow for impacts to be described in a quantitative manner in addition to the qualitative description given above, a rating scale of between 1 and 5 was used for each of the assessment criteria. Thus, the total value of the impact is described as the function of significance, which takes cognisance of extent, duration, potential intensity and likelihood. Impact Significance = (extent + duration + potential intensity) x likelihood

Table 21: Significance Assessment

Score Rating Implications for Decision-making

<3 Low Project can be authorised with low risk of environmental degradation

3-9 Moderate Project can be authorised but with conditions and routine inspections. Mitigation measures must be implemented.

10-20 High Project can be authorised but with strict conditions and high levels of compliance and enforcement. Monitoring and mitigation are essential.

21-26 Fatally flawed Project cannot be authorised

Notation of Impacts In order to make the report easier to read the following notation format is used to highlight the various components of the assessment:

• Extent- in italics

• Duration – in underline

• Potential intensity – IN CAPITALS

• Likelihood - in bold Please note that the impact rating system may change slightly to accommodate ease of use. However, the basic principle of the rating system will remain the same.

Briefly describe and compare the potential impacts (as appropriate), significance rating of impacts, proposed mitigation and significance rating of impacts after mitigation that are likely to occur as a result of the construction phase for the various alternatives of the proposed development. This must include an assessment of the significance of all impacts. Proposal

Potential impacts:

Significance rating of impacts (positive or negative):

Proposed mitigation:

Significance rating of impacts after mitigation:

Risk of the impact and mitigation not being implemented

PRE-CONSTRUCTION AND CONSTRUCTION PHASE

The applicant, Naturecell, propose to operate a fibre recovery and manufacturing plant within the Wadeville Industrial Park development which is owned, managed and operated by Growthpoint Properties. Growthpoint Properties undertook an application for Environmental Authorisation (EA) (Application reference: GAUT: 002/06-07/N0126) for the entire Wadestone Industrial Park Development, which are located on Wadeville Extension 50 and 51. EA was obtained for the development of Wadeville Extension 50 on 18 June 2007, and have been included as Appendix I-1. Construction activities authorized by this EA has commenced and is nearing completion. An application for EA (GAUT: 002/17-18/E2053) was undertaken by LEAP Landscape Architects and Environmental Planners in 2017 on behalf of the applicant, Growthpoint Properties, for the development of Wadeville Extension 51. The application included activities associated with the proposed establishment of an industry township and associated infrastructure on the Remaining extent of Portion 267 and Portion 273 of the Farm Klippoortje 110 – I.R within the Ekurhuleni Metropolitan Municipality. The Basic Assessment Report (BAR) submitted in terms of this

15 November 20019 58 18028

Potential impacts:





application is included in Appendix I-2. The Environmental Management Programme (EMPr) compiled for the proposed development for this application is included in Appendix I-3. Subsequent to the submission of the application and BAR to the competent authority, GDARD confirmed that due to fact that the development site fall within the Gauteng Provincial Environmental Management Framework’s Zone 1 and Zone 5 and due to the fact that all vegetation has been cleared no further authorisation is required. A letter from GDARD to this effect is included in Appendix I-4. The greater Wadestone Industrial Park require complete clearance of the land portions, installation of bulk services, construction of access and internal roads, construction of parking lot areas, construction of buildings and infrastructure and the construction of large warehousing structures, which will be leased to tenants to undertake their respective commercial or industrial activities. All activities associated with the pre-construction activities, clearance of land and construction activities have therefore been authorized for the greater Wadestone Industrial Park development. Since the applicant, Naturecell, is a tenant of the industrial park and is not responsible for the construction of the infrastructure associated with the industrial park, the construction activities that will be relevant to this application will be limited to the installation of the manufacturing plant and equipment within the already constructed warehouse structure ONLY, while operational activities will include the day-to-day operations and maintenance of the fibre recovery and manufacturing plant ONLY.

CONSTRUCTION PHASE

Packaging material waste handling and storage result in contamination of surrounding aquatic or terrestrial environments.

1 - Low (-) • Unboxing and unwrapping may only take place within a designated area within the warehouse structure.


1 – Low (-) • The receiving environment where plant and equipment will be unboxed and unwrapped is represented by the constructed warehouse structure with an impermeable concrete floor.

• The development within which the proposed manufacturing plant will be located is within an existing industrial park. Therefore, some degree of littering may be expected, however not within the control of the applicant.

• Proposed mitigation measures are aimed at avoiding contamination and limiting the potential contamination footprint to within the impermeable surfaces of the plant footprint

The risk of the impact occurring is therefore unlikely if proposed mitigation is implemented, while the risk of mitigation not being implemented is unlikely as mitigation conditions will be legally binding on the holder of the authorisation.

Spillage of hydrocarbons or oils within the warehouse footprint result in the indirect contamination of surrounding terrestrial and/or

1 – Low (-) • Drip trays or appropriate spillage containers must be used when components that require petrochemicals or lubricating oils are installed and filled.

• The applicant must identify and capacitate a

1 – Low (-) • The industrial development is currently still in a developmental phase with construction activities still expected to take place in the short term.

• The development within which the proposed

15 November 20019 59 18028

Potential impacts:





aquatic environments.

designated staff member/s to execute the containment and clean-up of any spillages that may occur during the installation of infrastructure.


• Any spillages that do occur must be contained and cleaned up immediately by the designated trained staff.


manufacturing plant will be located is within an existing industrial park where construction activities will still be taking place. Therefore, some degree of littering and poor housekeeping could be expected, however management of this is not within the control of the applicant.


Littering and poor housekeeping during the construction phase results in contamination of surrounding terrestrial and/or aquatic environments.

1 – Low (-) • The applicant must facilitate environmental awareness, emergency preparedness and emergency response procedures training to staff/contractors involved in the installation of the plant.

• Littering and housekeeping within the warehouse structure must be actively managed by the applicant.

• Littering and poor housekeeping on areas not directly managed by the applicant must be reported immediately to the developer, Growthpoint Properties to action and remedy.


1 – Low (-) • The plant and equipment will be installed within the constructed warehouse structure with an impermeable concrete floor. No prior littering is anticipated.

• The development within which the proposed manufacturing plant will be located is within an existing industrial park where construction activities will still be taking place. Therefore, some degree of littering and poor housekeeping could be expected, however management of this is not within the control of the applicant.

• Residual impact consideration is limited to the applicant's site, although the applicant does not exercise the management of grounds around the warehouse structure.

The risk of the impact occurring is therefore unlikely if proposed mitigation is implemented, while the risk of mitigation not being implemented is unlikely as mitigation conditions will be

15 November 20019 60 18028

Potential impacts:





legally binding on the holder of the authorisation.

Impact on landscaped areas, fauna and flora within the industrial park footprint


• No-go areas, which will include areas in the process of being landscaped, must be communicated to the applicant's staff/contractor prior to commencement of the plant installation activities.

• It is anticipated that some areas within the industrial park footprint will have undergone landscaping within vegetation establishment in the process.

• The applicant is not responsible for landscaping, however, contractors/staff undertaking installation of plant and equipment, as well as contractors that may be undertaking activities not associated with this development, may interact with landscaping areas.

• Proposed mitigation measures are aimed at avoiding impacts and incidents arising from staff or contractors employed by the applicant.


Protest or community action, and other social impacts arising from disputes between employer and employees/community.

1 - Low • The applicant must develop/implement a procurement process/policy in terms of the relevant and applicable legislation governing procurement of labour.


• The applicant must provide a complaints register at the entrance of the industrial park where community comments, complaints or grievances can be recorded.

• Complaints and grievances registered in the complaints register must be investigated and actioned

1 - Low • The industrial development is currently still in developmental phase with construction activities still expected to take place in the short term.

• The applicant may need to employ contractors or labour during installation of equipment and establishment of the plant.

• Residual impacts include the potential for labour employed by the developer or other tenants to instigate/influence labour employed by the applicant.


15 November 20019 61 18028

Potential impacts:





by the applicant on an ongoing basis.


8 – Moderate (+)


• The applicant should take cognisance of the surrounding community needs and requests, especially during the procurement of unskilled labour, as long as it is in line with the relevant and applicable legislation.

11 – High (+)

• The greater industrial park development is still in a developmental phase, therefore some employment opportunities does currently exist at the site.

• Additional employment opportunities will be created through establishment of the fibre recovery and manufacturing plant.

• Employment opportunities will furthermore also be available within the greater industrial park development, which will include those provided by this development.

The risk of the impact occurring is therefore highly probable if proposed mitigation is implemented, while the risk of mitigation not being implemented is unlikely as mitigation conditions will be legally binding on the holder of the authorisation.

OPERATIONAL PHASE

The generation of waste from the manufacturing process result in contamination of surrounding aquatic or terrestrial environment.

1 – Low (-) • The applicant must develop/implement a waste management plan/policy that will guide all waste management activities at the plant in terms of the National Waste Management Strategy, 2011 (GN 344 of 4 May 2012) , or must comply with the requirements of the applicant’s own SHEQ policy or documents where waste management has already been incorporated.

• The applicant will endeavour to recycle the recyclable portion of waste as far as possible.

• Unrecyclable waste must be collected on an ongoing basis and temporarily stored in the designated and fenced waste storage area.

• Unrecyclable waste stored in the designated waste storage area must be removed by a suitable licensed service provider

1 – Low (-) • No waste generation is anticipated to occur prior to the commencement of the operation of the fibre manufacturing plant. However, general waste is being generated by tenants already established in the industrial park.

• The proposed fibre recovery and manufacturing plant are expected to generate small volumes of general waste after recycling of recyclable waste. Unrecyclable waste will be removed from the site by a service provider independent of waste generated by the rest of the industrial park.

• Residual impact considers the portion of waste that will be recycled and an additional contribution of general waste to landfill airspace.

The risk of the impact occurring is therefore unlikely if

15 November 20019 62 18028

Potential impacts:





from the site at a frequency of not more than 60 days.


proposed mitigation is implemented, while the risk of mitigation not being implemented is unlikely as mitigation conditions will be legally binding on the holder of the authorisation.

Operational activities contribute to noise impact to sensitive local receptors during daytime hours

2 – Low (-) • All operational activities will occur within an enclosed warehouse structure within an established industrial zone.

• Based on specifications provided for plant and equipment, noise levels are not expected to exceed legislated industrial noise levels at the closest sensitive noise receptors.

2 – Low (-) • The greater industrial park is currently operating within an established industrial area, with surrounding industries contributing to industrial noise generation.

• Assessment of the anticipated noise levels during daytime hours by a recognised noise specialist indicate that noise levels generated at the plant will not exceed legislated industrial noise levels.

• Residual night-time noise levels are not expected to exceed legislated industrial noise levels.


Operational activities contribute to air quality emissions in the region

6 – Moderate (-)

• Anticipated atmospheric emission levels generated at the plant will not exceed legislated Minimum Emission Standards (MES). Therefore, an application for an Atmospheric Emission License (AEL) is not required. This confirms that the contribution of anticipated emission levels to the existing emissions will be neglectable.

• The applicant must install appropriate emission reduction technologies to reduce emission concentrations resulting from the operation of the plant.

• The applicant must provide a complaint register at the entrance of the industrial park where community complaints relating to emissions can be recorded.

6 – Moderate (-)

• The greater industrial park is currently operating within an established industrial area, with surrounding industries contributing to atmospheric emissions.

• Assessment of the anticipated atmospheric emissions from the plant (oven) by a recognised air quality specialist indicate that emission levels generated at the plant will not exceed legislated Minimum Emission Standards (MES).

The risk of the impact occurring is probable if proposed mitigation is implemented. The significance rating and risk are however associated with the existing air quality conditions in the priority area and it is anticipated that the operation of the plant will not contribute to a

15 November 20019 63 18028

Potential impacts:





• Complaints relating to operational emissions that is registered in the complaints register must be investigated and actioned by the applicant on an ongoing basis.

deterioration of the air quality locally or in the region. See detailed impact assessment matrix in Appendix I-5. The risk of mitigation not being implemented is unlikely as mitigation conditions will be legally binding on the holder of the authorisation.

Protest or community action, and other social impacts arising from disputes between employer and employees/community.

5 – Moderate (-)


• The applicant should continuously take cognisance of the surrounding community needs, especially during the procurement of unskilled labour, as long as it is in line with the relevant and applicable legislation.



2 – Low (-) • The industrial development is currently still in a developmental phase with construction activities still expected to take place in the short term.

• The applicant may need to employ contractors or labour during the installation of equipment and the establishment of the plant.

• Residual impacts include the potential for labour employed by the developer or other tenants to instigate/influence labour employed by the applicant.

The risk of the impact occurring is unlikely if proposed mitigation is implemented, while the risk of mitigation not being implemented is unlikely as mitigation conditions will be legally binding on the holder of the authorisation.


11 – High (+)

• The applicant must continue to implement a procurement process/policy in terms of the relevant and applicable legislation governing the procurement of labour.

• The applicant should take cognisance of the surrounding community needs and requests, especially during the procurement of unskilled labour, as long as it is in line with the relevant and applicable legislation.

11 – High (+)

• Additional employment opportunities will be created through the establishment of the fibre recovery and manufacturing plant, as well as the establishment of other tenants in the industrial park.

• Employment opportunities will be available within the greater industrial park development, which will include those provided by this development.

The risk of the impact occurring is unlikely if proposed mitigation is implemented, while the risk of mitigation not being implemented is unlikely as mitigation conditions will be legally binding on the holder of the authorisation.

15 November 20019 64 18028

Potential impacts:





Alternative 1 (REPEAT THIS TABLE FOR EACH ALTERNATIVE)

Potential impacts:





No Go

Potential impacts:





No contamination and spillage of hydrocarbons on the environment.

0 – Low (+) • Any proposed development must go through an Environmental Impact Assessment Process to ensure that potential impacts on the environment are mitigated or avoided.

0 – Low (+) • The greater Wadestone Industrial Park is already operational, however, hydrocarbon contamination and spillages are unlikely considering the industrial park layout and required adherence to an existing EA and EMPr.

• The proposed fibre recovery and manufacturing plant are not anticipated to contribute significant impacts in terms of spillages and contamination as the plant will be established within an existing warehouse structure developed as part of the greater industrial park development.

• The residual impact of the development of the fibre recovery and manufacturing plant is therefore not expected to be greater than the existing and cumulative impact.

Pre- and post-consumer newsprints disposed of in landfills.

11 – High (-) • Recommend Environmental Authorisatoin for the proposed fibre recovery and

8 – Moderate (-)

• Large volumes of newsprint are generated on a monthly basis as a result of unsold newspapers.

15 November 20019 65 18028

manufacturing plant development.

• Encourage the reduction of waste at source, reuse, and recycling of waste.

• Encourage separation of waste into recyclable and non-recyclable waste materials.

• Encourage waste minimisation industries to ensure that waste materials such as the pre- and post-consumer newsprints are recycled.

• Encourage communities to be involved in the collection of recyclable materials to such industries.

Considering the existing pressure on current landfills in Gauteng, the existing impact significance is considered High.

• The cumulative impact relates to the volume of more than 1000 tons per month that will be added to the newsprint sent to landfill that could have been recycled via the proposed development. Them impact significance is therefore still regarded as High.

• After proposed mitigation has been implemented and the proposed development is granted authorisation, the residual impact of a reduction in waste to landfill will at least be felt very probably on a local scale. The impact significance of the residual impact on a local scale is therefore expected to be reduced to Moderate.

The identified business opportunity can not be realised by the developer thereby contributing to the local and regional economy.

14 – High (-) • Recommend Environmental Authorisation for the proposed fibre recovery and manufacturing plant development

8 – Moderate (-) • Currently, the South Africa economy is struggling severely with economic growth expected to be below 1%. As a result, the local and regional economy is significantly affected. Impact significance is calculated to be High.

• If the development does not go ahead, the cumulative impact is expected to remain high, if not deteriorating over the medium term.

• After proposed mitigation has been implemented and the proposed development is granted authorisation, the residual impact is expected to at least contribute to the local and regional economy. The impact significance of the residual impact on a regional scale is therefore expected to reduce through the contribution to the regional economy. The impact significance is calculated to be reduced to Moderate.

15 November 20019 66 18028

Potential employment opportunities on a local scale will not be realised.

13 – High (-) • Recommend Environmental Authorisatin for the proposed fibre recovery and manufacturing plant development

5 – Moderate (-) • Currently, the South Africa economy is struggling severely with the local and regional economy significantly affected. As a result employment opportunities are not being realised with the unemployment rate increasing nationally. This impact is reflected in the local economy. The impact of significance on a local scale is calculated to be High.

• If the development does not go ahead, the cumulative impact is expected to remain high, if not deteriorating over the medium term.

• After proposed mitigation has been implemented and the proposed development is granted authorisation, the residual impact is expected to at least contribute to realising local employment opportunities. The impact significance is calculated to be reduced to Moderate.

List any specialist reports that were used to fill in the above tables. Such reports are to be attached in the appropriate Appendix.

Appendix G-1: Air Quality Specialist Opinion Letter Appendix G-2: Noise Specialist Opinion Letter

Describe any gaps in knowledge or assumptions made in the assessment of the environment and the impacts associated with the proposed development.

Assumptions In undertaking this BAR, it has been assumed that all information from the previously undertaken specialist assessments during a BAR conducted by LEAP is accurate.

3.IMPACTS THAT MAY RESULT FROM THE DECOMMISSIONING AND CLOSURE PHASE Briefly describe and compare the potential impacts (as appropriate), significance rating of impacts, proposed mitigation and significance rating of impacts after mitigation that are likely to occur as a result of the decommissioning and closure phase for the various alternatives of the proposed development. This must include an assessment of the significance of all impacts.

Proposal

Potential impacts:





15 November 20019 67 18028

Due to the nature of the proposed development, the decommissioning phase is not envisioned at this stage. However, should the facility be decommissioned in future the decommissioning activities will need to comply with the relevant legislation at the time. Mitigation measures proposed for the construction phase will apply.

Alternative 1

Potential impacts:





Alternative 2

Potential impacts:





List any specialist reports that were used to fill in the above tables. Such reports are to be attached in the appropriate Appendix.

Where applicable indicate the detailed financial provisions for rehabilitation, closure and ongoing post decommissioning management for the negative environmental impacts.

4.CUMULATIVE IMPACTS Describe potential impacts that, on their own may not be significant, but is significant when added to the impact of other activities or existing impacts in the environment. Substantiate response:

Cumulative impacts are assessed as the combination of impacts from the proposed development with current and future development impacts in the immediate area of the Project site. The cumulative impacts assessed depend on the status of other projects and the level of data available to characterise the magnitude of the impacts. Cumulative impacts there were considered include:

• Litter and Waste Activities associated with the use of the site may result in littering. Similarly, the building process generates wastes that could pollute the site and its surrounds. For this reason, it is important that a waste management plan must be developed by the operator of the industrial park, if not already implemented. Each tenant must

15 November 20019 68 18028

align and comply with such a waste management plan. The litter will reduce as the construction phase comes to an end.

• Stormwater Runoff The development of hard surfaces will give rise to greater volumes and velocity of runoff waters during high peak flows. This water will drain into the roads and stormwater management system. Localised flooding may result in negative impacts on the bed and banks of the stream course due to the cumulative effects.

• Social benefits In an area that has high unemployment and low-level job opportunities, the cumulative benefits of this industrial area being developed are high.

5.ENVIRONMENTAL IMPACT STATEMENT Taking the assessment of potential impacts into account, please provide an environmental impact statement that sums up the impact that the proposal and its alternatives may have on the environment after the management and mitigation of impacts have been taken into account with specific reference to types of impact, duration of impacts, likelihood of potential impacts actually occurring and the significance of impacts.

Proposal

The site is located within an industrial area and has already been cleared for the construction of the relevant structures and infrastructure. The applicant, Naturecell, is a tenant within this establishing industrial park. Construction of the applicant’s warehouse structure is furthermore being undertaken by the industrial park developer and operator, Growthpoint Properties, and as such construction impacts resulting from the activities of the applicant is limited to the installation of the fibre recovery and manufacturing plant and technology within the warehouse structure allocated to Naturecell as the tenant. Impact on the surrounding natural environment will, therefore, be negligible, with the main concern being the handling and management of waste within the applicant’s site. With the implementation of the proposed mitigation, any potential impacts relating to the management of waste within Naturecell’s site will be Low as a designated waste management area has been included in the design of the plant. It is therefore concluded that impacts resulting from the management and storage of waste will be unlikely during the construction and operational phases of the development, and in the event that such impacts may occur the impact significance will be Low as a result of mitigating procedures and policies in place. Other potential impacts resulting from the construction and operational phases of the proposed fibre recovery and manufacturing plant are associated with the employment of labour. A significant positive impact that will result is definite employment opportunities for local skilled and unskilled labour. This proposed development, including the establishment of other tenants within the industrial park, will provide a number of employment opportunities during construction and operational phases. Potential negative impacts associated with the employment of labour include protest action or community action where disputes between employer and employees cannot be resolved. Unfortunately, the management of such incidents is difficult to predict and control. As such the likelihood of this impact occurring will remain probable. However, if the proposed mitigation measures, which include amongst others the development of a procurement policy taking local community’s needs and expectations into account, will contribute to reducing the impact significance to Low and the likelihood of such impact occurring unlikely.

Alternative 1

No site alternatives were identified as the proposed site is owned by Growthpoint and has an Environmental Authorised for development of the entire industrial park. Naturecell will only sub-lease an industrial plot within the greater industrial park and will, therefore, be a tenant.

Alternative 2

N/A

No-go (compulsory)

This option assumes that a conservative approach would ensure that the environment is not impacted upon any more than is currently the case. It is important to state that this assessment is informed by the current condition of the area. Should the GDARD decline the application, the ‘No-Go’ option will be followed, and the status quo of the site will remain. The adverse impact resulting from this is that the demand for fibre mat insulating products in the market will likely not be met. The applicant’s product will furthermore sufficiently supply the demand by producing high quality and competitively priced fibre mat insulating products. Anticipated employment opportunities that are needed in the surrounding communities and will be provided by the applicant will also not materialise resulting in a missed opportunity to contribute to social and economic upliftment of households in the community that has benefitted from employment at the proposed plant.

15 November 20019 69 18028

6.IMPACT SUMMARY OF THE PROPOSAL OR PREFERRED ALTERNATIVE For proposal:

The impacts have been identified and assessed during the BA process. Based on the impact assessment, impacts will be predominantly limited to the site and study area. The impacts will mostly occur during the construction phase of the fibre recovery and manufacturing plant, which will be approximately 3 to 6 months. All of the impacts identified during the construction phase can be mitigated to acceptable limits and the majority of the impacts showed a MODERATE significance before and a LOW significance after mitigation measures are implemented. The establishment of the proposed plant is therefore not likely to significantly impact the remaining surrounding environment. It is, therefore, the EAP’s recommendation that GDARD grants Environmental Authorisation for the proposed development.

For alternative:

No alternatives are applicable to this application.

Having assessed the significance of impacts of the proposal and alternative(s), please provide an overall summary and reasons for selecting the proposal or preferred alternative.

Naturecell intends to construct a cellulose recovery and manufacturing plant on a part of Portion 273 of the farm Kilppoortie No 110-IR and Part of Erf 876 Wadeville X 50 which falls within the jurisdiction of the Ekurhuleni Metropolitan Municipality. The site is located north of Moore street, east of Arnold Road, south of Lamp / Snapper street and west of Osborn road. The site is very well suited to industrial uses due to its location to an existing industrial node along the N17 Freeway. The cellulose recovery plant will be constructed on a piece of land that is owned by Growthpoint Properties (Pty) Ltd. An Environmental Authorisation (EA for Wadeville Ext 50 – GAUT 002/06-07/N0126) has been obtained for this greater industrial park development. Therefore, clearing of the site and the establishment of other tenants has commenced within the greater industrial park. All construction activities associated with the clearance of vegetation, infilling and landscaping of the development site, installation of bulk services and construction of warehousing structures and infrastructure have therefore been authorised already and were therefore not considered in this application. The significance of impacts on ecology resulting from Naturecell establishing the proposed fibre recovery and manufacturing plant within the greater industrial park is therefore negligible, though there are measures that should be taken during construction to ensure management of the destructed ecosystems. The significance of impacts on heritage and palaeontology in the area is low. Removal of any heritage and palaeontology resources is prohibited and SAHRA should be notified should any palaeontological resource be spotted on site. The proposed development will have a positive impact on the socio-economic environment of the area, as it brings employment opportunities during construction and also during the operational phase. Therefore considering that all anticipated impacts that may result from the applicant’s construction and operational activities can be mitigated to acceptable levels through the implementation of proposed mitigation measures, the EAP has concluded that there are no impacts or sensitivities that would prevent the establishment of the proposed fibre recovery and manufacturing plant within the proposed site allocated to Naturecell as a tenant within the greater industrial park.

7.SPATIAL DEVELOPMENT TOOLS Indicate the application of any spatial development tool protocols on the proposed development and the outcome

thereof.

Use of GIS tool for mapping (using data from GDARD such as EMF, GAPA and GIDSv10, and other data), refer to attached maps in Appendix A.

8.RECOMMENDATION OF THE PRACTITIONER

15 November 20019 70 18028

Is the information contained in this report and the documentation attached hereto sufficient to make a decision in respect of the activity applied for (in the view of the Environmental Assessment Practitioner as bound by professional ethical standards and the code of conduct of EAPASA).

YES

If “NO”, indicate the aspects that require further assessment before a decision can be made (list the aspects that require further assessment):

N/A

If “YES”, please list any recommended conditions, including mitigation measures that should be considered for inclusion in any authorisation that may be granted by the competent authority in respect of the application:

The EAP recommends that the proposed development of a cellulose recovery plant be authorised at the proposed location. The EAP recommends the following conditions to be included in the Environmental Authorisation:

• All mitigation proposed in the Environmental Management Programme (EMPr) (refer to Appendix H) must be implemented and adhered to by the applicant/developer.

• The applicant must adhere and implement any strategy, policy or plan developed by the operator of the industrial park, Growthpoint Properties (Pty) Ltd, and applicable to all tenants within the park, relating to the prevention of pollution and protection of the environment.

9.THE NEEDS AND DESIRABILITY OF THE PROPOSED DEVELOPMENT (as

per notice 792 of 2012, or the updated version of this guideline)

The rate of urbanization in metropolitan areas has created major pressures to provide job opportunities for new arrivals, especially in the lower-income employment group. In order to achieve this economic growth is paramount. One of the avenues to contribute to economic growth and job creation is the establishment of industrial areas, parks or zones. This is especially evident in the South African government’s efforts to establish Special Economic Zones (SEZs), which are large scale Industrial Development Zones (IDZs) geared up to stimulate economic growth and job opportunities in South Africa, underpinned by the Special Economic Zones Act, No 16 of 2014. The Wadestone Industrial Park development, therefore, contributes, albeit at a smaller scale, to this overall economic development objective by providing the space and amenities for the commercial and industrial business to establish itself within the complex. The proposed cellulose recovery plant is one of the developments that will establish within the Wadestone Industrial Park. The plant’s objective is to recover cellulosic fibres, which are blended and treated to ultimately form a bonded mat product, which is then cut into batts and packaged as a final product for use in thermal and acoustical insulation applications. The development is, therefore, responding to high demand for these end products through the supply of a competitive and affordable quality product, made possible through the recycling of pre-and post-consumer newsprint.

10. THE PERIOD FOR WHICH THE ENVIRONMENTAL AUTHORISATION IS REQUIRED (CONSIDER WHEN THE ACITIVTY IS EXPECTED TO BE CONCLUDED)

11. ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPr) (must include post

construction monitoring requirements and when these will be concluded.)

If the EAP answers “Yes” to Point 7 above then an EMP is to be attached to this report as an Appendix

EMPr attached Yes

The proposed operation of the fibre recovery and manufacturing plant is expected to continue indefinitely.

15 November 20019 71 18028

SECTION F: APPENDIXES The following appendixes must be attached as appropriate (this list is inclusive, but not exhaustive): It is required that if more than one item is enclosed that a table of contents is included in the appendix

Appendix A: Site plan(s) – (must include a scaled layout plan of the proposed activities overlain on the site sensitivities indicating areas to be avoided including buffers)

Appendix A-1: Locality Map Appendix A-2: Site and Layout Plan Map Appendix A-3: Cadastral and Neighbouring Properties Map Appendix A-4: Ward Delineation Map Appendix A-5: Infrastructure, Bulk Services and Servitudes Map YELLOW Appendix A-6: Historic Site Sensitivity Map YELLOW Appendix A-7: Current Site Sensitivity Map YELLOW Appendix A-8: Gauteng Pollution Buffer Zone Map YELLOW Appendix A-9: Geology Map YELLOW Appendix A-10: Topographical Map

Appendix B: Photographs Appendix C: Facility illustration(s)

Appendix C-1: Site Plan Drawing Appendix C-2: Fence Position Layout Appendix C-3: Plant Layout Drawing Appendix C-4: Plant Air Ring Main Drawing Appendix C-5: Manufacturing process flow diagram

Appendix D: Route position information Appendix E: Public participation information

Appendix E-1: Proof of site notice Appendix E-2: Written notices issued as required in terms of the regulations Appendix E-3: Proof of newspaper advertisements Appendix E-4: Communications to and from interested and affected parties Appendix E-5: Minutes of any public and/or stakeholder meetings Appendix E-6: Comments and Responses Report Appendix E-7: Comments from I&APs on Basic Assessment (BA) Report Appendix E-8: Comments from I&APs on amendments to the BA Report Appendix E-9: Copy of the register of I&APs

Appendix F: Water use license(s) authorisation, SAHRA information, service letters from

municipalities, water supply information Appendix F-1: Enviroserve Quotation Appendix F-2: Bulk Services Letter Appendix F-3: Bulk Water and Sewer Report Appendix F-4: Roads and Stormwater information Appendix F-5: Bulk Water Supply Layout Drawing Appendix F-6: Bulk Stormwater Infrastructure Layout Drawing

Appendix G: Specialist reports

Appendix G-1: Air Quality Assessment Opinion Letter Appendix G-2: Noise Assessment Opinion Letter Appendix G-3: Traffic Impact Assessment (part of GAUT: 002/17-18/E2053) Appendix G-4: Memo: Peak hour traffic calculations and assumptions Appendix G-5: Screening Report – Development footprint Appendix G-6: Screening Report – Development footprint 500m buffer

Appendix H: EMPr Appendix I: Other information

15 November 20019 72 18028

Appendix I-1: Wadeville Extension 50 Environmental Authorisation Appendix I-2: Wadeville Extension 51 Basic Assessment Report Appendix I-3: Wadeville Extension 51 Environmental Management Plan Appendix I-4: Wadeville Extension 51 GPEMF Letter (GPEMF19-20/0012) Appendix I-5: Detailed Impact Assessment Matrix Appendix I-6: Property information - affected properties Appendix I-7: Property information – Klippoortje 110 IR Ptn 215 Appendix I-8: CV of EAP

CHECKLIST To ensure that all information that the Department needs to be able to process this application, please check that:

➢ Where requested, supporting documentation has been attached; ➢ All relevant sections of the form have been completed.

proposed development of a cellulose recovery plant and ... · reg. no. 2000/000392/07 po box 6002...

Documents