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DRAFT SCOPING REPORT PROPOSED CHROME CHEMICALS PLANT AND WASTE DISPOSAL SITE FOR: LANXESS CISA (PTY) LTD NEWCASTLE, KZN

KZNDAEA REF: EIA/NODC25/0006/08 June 2008

ENVIRONMENTAL SCIENCE

ASSOCIATES

POSTAL ADDRESS:

PO Box 2950 Saxonwold

2132

PHYSICAL ADDRESS:

9 Victoria Street Oaklands

Johannesburg 2192

TEL: +27 11 7282683

FAX: +27 866 106703

WEBSITE: www.escience.co.za

EMAIL: [email protected]

DRAFT SCOPING REPORT FOR

PROPOSED CHROME CHEMICALS PLANT AND

WASTE DISPOSAL SITE AT

NEWCASTLE, KWAZULU-NATAL

PREPARED FOR: Lanxess CISA (Pty) Ltd

Karbochem Road, Newcastle Private Bag X6600, Newcastle, 2940

Tel: +27 34 370 1641 Fax: +27 866 144 538

PREPARED FOR APPROVAL BY: KWAZULU-NATAL DEPARTMENT OF AGRICULTURE & ENVIRONMENTAL AFFAIRS (DAEA)

Tel: +27 33 355 9100 Fax: +27 33 355 9122

Private Bag X9059 Pietermaritzburg

3200

PREPARED BY: ENVIRONMENTAL SCIENCE ASSOCIATES

PO Box 2950, Saxonwold, 2132 9 Victoria Street, Oaklands, Johannesburg

Tel: +27 11 7282683 Fax: +27 866 106703

E-mail: [email protected]

June 2008

Lanxess CISA CHROME CHEMICALS PLANT – Scoping Report & Plan of Study for EIA Environmental Science Associates Page i

TABLE OF CONTENTS

1. EXECUTIVE SUMMARY........................................................................................................... 1 2. BACKGROUND............................................................................................................................ 2 3. LEGAL AND POLICY FRAMEWORK .................................................................................... 4

3.1 ENVIRONMENTAL IMPACT ASSESSMENT................................................................................. 4 3.1.1 Listed ACTIVITY 1(c)...................................................................................................... 4 3.1.2 Listed ACTIVITY 1(e)...................................................................................................... 4 3.1.3 Listed ACTIVITY 1(g)...................................................................................................... 5 3.1.4 Listed ACTIVITY 1(j)....................................................................................................... 5 3.1.5 Listed ACTIVITY 1(a)...................................................................................................... 5

3.2 AIR QUALITY........................................................................................................................... 5 3.3 WASTE ..................................................................................................................................... 6 3.4 OCCUPATIONAL HEALTH AND SAFETY .................................................................................... 7

4. PROJECT DESCRIPTION.......................................................................................................... 8 4.1 DESCRIPTION OF ACTIVITY TO BE UNDERTAKEN.................................................................... 8 4.2 MOTIVATION FOR THE DEVELOPMENT.................................................................................. 24 4.3 PROPERTY PARTICULARS ...................................................................................................... 25

4.3.1 Name of Property .......................................................................................................... 25 4.3.2 Local Authority.............................................................................................................. 25 4.3.3 Land Use Zoning ........................................................................................................... 25

4.4 LOCAL AUTHORITY AND SERVICES PROVIDER ..................................................................... 25 5. PARTICIPATION PROCESS ................................................................................................... 26 6. DESCRIPTION OF THE ENVIRONMENT AND POTENTIAL IMPACTS...................... 27

6.1 SURROUNDING LAND USE.............................................................................................. 27 6.2 STATE OF THE ENVIRONMENT .......................................................................................... 29

6.2.1 Ambient Air Quality....................................................................................................... 29 6.2.2 Geological and Geohydrological Environment............................................................. 30 6.2.3 Surface Water ................................................................................................................ 31

6.3 SOCIO-ECONOMIC ENVIRONMENT .............................................................................. 31 6.3.1 Places of Archaeological and Cultural Importance...................................................... 31 6.3.2 Residential Areas in Vicinity of the Plant...................................................................... 31 6.3.3 Major Access Routes ..................................................................................................... 32 6.3.4 Sensitive Environmental Receptors ............................................................................... 32

7. ENVIRONMENTAL ASPECT & IMPACT REGISTER....................................................... 33 7.1 CONSTRUCTION IMPACT ASSESSMENT AND MITIGATION ............................................... 36

7.1.1 Noise.............................................................................................................................. 36 7.1.2 Construction Waste ....................................................................................................... 36

7.2 OPERATIONAL IMPACT ASSESSMENT AND MITIGATION ................................................. 36 7.2.1 Emissions to Air............................................................................................................. 36 7.2.2 Generation and Disposal of Hazardous Waste ............................................................. 36 7.2.3 Energy and Raw material Usage................................................................................... 37 7.2.4 Groundwater Contamination......................................................................................... 37 7.2.5 Effluent Generation and Management .......................................................................... 37 7.2.6 Noise.............................................................................................................................. 38

8. ALTERNATIVES ....................................................................................................................... 39 8.1 SITE ALTERNATIVES.............................................................................................................. 39 8.2 PROCESS AND PRODUCT ALTERNATIVES....................................................................... 39 8.3 NO-GO OPTION ...................................................................................................................... 40

9. PLAN OF STUDY FOR EIA ..................................................................................................... 41

Lanxess CISA CHROME CHEMICALS PLANT – Scoping Report & Plan of Study for EIA Environmental Science Associates Page ii

9.1 SPECIALIST STUDIES AND REPORTING .................................................................................. 41 9.1.1 Air Quality Impact Assessment...................................................................................... 41 9.1.2 Hexavalent Chromium Ambient AIR Impact Assessment .............................................. 46 9.1.3 Handling Treatment And Disposal Of Hazardous Waste.............................................. 47 9.1.4 Geotechnical Assessment............................................................................................... 49 9.1.5 Geohydrological Assessment......................................................................................... 50 9.1.6 Hydrological Assessment............................................................................................... 51 9.1.7 Soil Assessment.............................................................................................................. 51 9.1.8 Occupational Health & Safety....................................................................................... 51

9.2 CONSULTATION WITH THE COMPETENT AUTHORITY............................................................ 52 9.3 IMPACT ASSESSMENT METHODOLOGY ................................................................................. 52 9.4 PUBLIC PARTICIPATION PROCESS........................................................................................... 52

10. REFERENCES CITED .......................................................................................................... 54 11. APPENDIX 1: IMPACT ASSESSMENT METHOD .......................................................... 55

11.1 DETERMINANTS OF IMPACT SIGNIFICANCE .......................................................................... 55 11.1.1 nature............................................................................................................................. 55 11.1.2 Extent............................................................................................................................. 55 11.1.3 Duration ........................................................................................................................ 55 11.1.4 Intensity ......................................................................................................................... 55 11.1.5 Probability..................................................................................................................... 56 11.1.6 Mitigation or Enhancement........................................................................................... 56 11.1.7 reversibility.................................................................................................................... 56

11.2 CALCULATING IMPACT SIGNIFICANCE .................................................................................. 57 11.3 UNDERSTANDING IMPACT SIGNIFICANCE ................................................................ 57 11.4 ASSIGNING IMPACT PRIORITY ............................................................................................... 59

12. APPENDIX 2: PUBLIC PARTICIPATION......................................................................... 60 12.1 INTRODUCTION ...................................................................................................................... 60 12.2 IDENTIFICATION OF I&APS ................................................................................................... 60 12.3 PUBLIC MEETING................................................................................................................... 64 12.4 AUTHORITIES MEETING......................................................................................................... 67 12.5 COMMENTS FROM I&AP’S .................................................................................................... 75

13. APPENDIX 3: DETERMINATION OF HEXAVALENT CHROMIUM IN AMBIENT AIR 76

13.1 INTRODUCTION ...................................................................................................................... 79 13.2 SUMMARY OF METHOD ......................................................................................................... 79 13.3 INTERFERENCES AND LIMITATIONS....................................................................................... 79

13.3................................................................................................................................................ 79 13.4 INSTRUMENT AND EQUIPMENT.............................................................................................. 79 13.5 MATERIALS AND CHEMICALS................................................................................................ 80 13.6 PREPARATION OF ELUENT ..................................................................................................... 81 13.7 PREPARATION OF POST-COLUMN REAGENT ......................................................................... 81 13.8 PREPARATION OF HEXAVALENT CHROMIUM STANDARDS AND CONTROLS......................... 82 13.9 PREPARATION OF SODIUM BICARBONATE IMPREGNATING SOLUTION ................................. 82 13.10 PREPARATION OF HEXAVALENT CHROMIUM FILTERS ...................................................... 82 13.11 FILTER LOG-IN .................................................................................................................. 83 13.12 FILTER ANALYSIS .............................................................................................................. 83 13.13 QUALITY CONTROL ........................................................................................................... 84 13.14 HAZARDOUS WASTE.......................................................................................................... 85 13.15 REFERENCES...................................................................................................................... 85

14. APPENDIX 4: EXPERTISE OF THE EAP ......................................................................... 86 14.1 CURRICULUM VITAE.............................................................................................................. 86 14.2 ROGER DIAMOND .................................................................................................................. 86

Lanxess CISA CHROME CHEMICALS PLANT – Scoping Report & Plan of Study for EIA Environmental Science Associates Page iii

14.2.1 Key Experience.............................................................................................................. 86 14.2.2 Employment History & Project Experience .................................................................. 87 14.2.3 Education....................................................................................................................... 90

14.3 CURRICULUM VITAE.............................................................................................................. 92 14.4 ABDUL EBRAHIM................................................................................................................... 92

14.4.1 Key Experience.............................................................................................................. 92 14.4.2 Employment History & Project Experience .................................................................. 93 14.4.3 Education....................................................................................................................... 97

14.5 CURRICULUM VITAE.............................................................................................................. 98 14.6 THEO FISCHER ....................................................................................................................... 98

14.6.1 Key Experience.............................................................................................................. 98 14.6.2 Employment History & Project Experience .................................................................. 99 14.6.3 Education..................................................................................................................... 102

Lanxess CISA CHROME CHEMICALS PLANT – Scoping Report & Plan of Study for EIA Environmental Science Associates Page iv

Index of Figures Figure 2-1: Lanxess facilities in South Africa.......................................................................... 2 Figure 4-1: Overall Process Flow Diagram ............................................................................ 9 Figure 4-2: Milling Mixing and Roasting............................................................................... 10 Figure 4-3: Treatment of Kiln Off-Gases............................................................................... 11 Figure 4-4: Leach Tank........................................................................................................... 12 Figure 4-5: Residue Filtration Plant ....................................................................................... 13 Figure 4-6: Residue Treatment Process................................................................................ 14 Figure 4-7: Treatment of Recycled Material....................................................................... 15 Figure 4-8: Sodium Monochromate Purification – Vanadate Removal......................... 16 Figure 4-9: Sodium Monochromate Purification – Calcium Removal ............................ 17 Figure 4-10: Sodium Monochromate Concentration ....................................................... 18 Figure 4-11: Conversion of Sodium Monochromate to Sodium Dichromate ................ 19 Figure 4-12: SDC Crystallisation ............................................................................................ 20 Figure 4-13: Sodium Sulphate Plant ..................................................................................... 21 Figure 4-14: Chrome Oxide Plant......................................................................................... 22 Figure 4-15: Sodium Bicarbonate Calcining....................................................................... 23 Figure 4-16: Satellite image .................................................................................................. 25 Figure 6-1: General map of the area showing surrounding land use............................. 27 Figure 6-2: Oblique aerial photograph showing the Karbochem site, with the existing

Lanxess CISA chrome chemicals plant circled in red. .............................................. 28 Figure 6-3: Satellite image..................................................................................................... 28 Figure 6-4: Residential Areas in the vicinity of the site ...................................................... 32 Figure 8-1: Site Alternatives................................................................................................... 39 Figure 9-1: Plan of Study for Air Quality Impact Assessment............................................ 43 Figure 9-2: Waste treatment and generation processes.................................................. 47 Figure 9-3: Waste treatment and re-use stage gate decision process.......................... 49 Figure 12-1: Contents of Advertisement in The Newcastle Advertiser............................ 61 Figure 12-2: Site Notice Entrance Gate .............................................................................. 62 Index of Tables Table 4-1: Investment Summary........................................................................................... 24 Table 9-1: Consultation with the competent authority .................................................... 52 Table 11-1: Scoring for Significance Criteria ...................................................................... 57 Table 11-2: Final Significance Scoring................................................................................. 57 Table 12-1: List of I&APs ......................................................................................................... 63 Table 12-2: Public Meeting Attendance Register ............................................................. 65 Table 12-3: Public Meeting Register of Comments and Responses ............................... 66 Table 12-4: Authorities Meeting Attendance Register...................................................... 68 Table 12-5: Authorities Meeting Register of Comments and Responses........................ 69

Lanxess CISA CHROME CHEMICALS PLANT – Scoping Report & Plan of Study for EIA Environmental Science Associates Page 1

1. EXECUTIVE SUMMARY Environmental Impact Assessment aims to ensure effective compliance and governance concerning the environment, while simultaneously focusing on key issues such as stakeholder empowerment, providing access to relevant and concise information to enable informed decision making. This Scoping Report was compiled through the execution of a methodology set out to produce a report in compliance with the requirements of Section 29 of GNR385 Regulations in terms of Chapter 5 of the National Environmental Management Act, 1998. The objective of this Scoping and Environmental Impact Assessment report is to identify and discuss issues of potential environmental significance, and where possible, indicate the significance of those impacts. The identification and assessment of environmental impacts reveals the following potentially significant environmental aspects which require further detailed assessment: o Impact on Air Quality - Air quality assessment entailing a study of criteria pollutants

emitted by various sections of the proposed plant to inform preventative measures and abatement requirements

o Emission of particulates containing Hexavalent Chrome - Hexavalent chromium ambient air quality baseline and emission assessment to determine current exposures and investigating emission and abatement of Hexavalent chromium from the plant specifically

o Waste disposal - Waste disposal assessment investigating requirements for waste handling, storage treatment and disposal with a specific focus on hazardous wastes generated by the process

o Geohydrological and Geotechnical site assessment to determine soil and groundwater baselines and inform waste disposal site location

o Potential Impact on surface water – Assessment of generation, containment and management of contaminated surface water

o Review of the major hazardous installation site management requirements as defined in terms of the Occupational Health and Safety Act, 1993, and Major Hazardous Regulations promulgated thereunder.

The Scoping report sets out a Plan of Study for the Environmental Impact Assessment, indicating the process to be followed and the expected outputs for informing the authorities’ and IAP’s review of EIA.


2. BACKGROUND It is the intention of Lanxess CISA to establish at its Newcastle site a world class chrome chemicals production facility. This facility will make use of existing infrastructure, raw material sources and new equipment to broaden its current production scope and increase its beneficiation capacity. Although South Africa has about 70% of the world’s total chrome reserves, (almost exclusively in the Bushveld Igneous Complex), and produces 75% of the world’s ferrochrome, South Africa only produces approximately 8% of the world’s chrome chemicals at present. The proposed Lanxess CISA chrome chemicals production facility is anticipated to increase South Africa’s production to 17% of the world’s chrome chemicals. As such the development will significantly contribute to the beneficiation of South Africa’s chrome resources. This will result in significant foreign exchange earnings for South Africa, as more than 90% of the products will be exported. Chromium chemicals are generally used for pigments and other chemicals used in chrome plating, etching, tanning, water treatment, and catalysis. Lanxess currently operates a chrome mine at Rustenburg on the western limb of the Bushveld Igneous Complex, chrome chemicals plants at Newcastle and Merebank, and a rubber chemicals plant in Isithebe. The South African head office is in Johannesburg.

Figure 2-1: Lanxess facilities in South Africa The chief products from the proposed development will be: Sodium Dichromate - 30 000 tonnes per annum (tpa)

Rustenburg (BU LEA, Chrome Ore)

Newcastle (BU LEA, Chrome Chemicals)

Isithebe (BU RUC, Rubber Chemicals)

Merebank (BU LEA, Chrome Tanning Salts)

Cape Town

Isando Head Office (Admin & Finance, Sales & Marketing) Johannesburg

Durban


Chrome Oxide - 20 000 tpa Sodium Sulphate - 20 000 tpa Total Production ~ 70 000 tpa of sodium dichromate equivalents.

The overall process is briefly illustrated in Figure 4-1: Overall Process Flow Diagram. More detailed descriptions of various distinct sections of the process are illustrated in the relevant sections of this document dedicated to process descriptions. By virtue of the complexity of the process, a broad spectrum of interactions with the environment is predicted. Where possible pre-emptive design considerations have been incorporated to prevent/mitigate deleterious environmental impacts. The potential efficacy of these design considerations will be assessed during the environmental impact assessment process and the outcomes thereof will be used to inform detailed design and implementation phases of the project.


3. LEGAL AND POLICY FRAMEWORK 3.1 ENVIRONMENTAL IMPACT ASSESSMENT The operation includes several activities listed in Government Notice R387, promulgated under Section 24(5) of the National Environmental Management Act (Act 107 of 1998), namely:

Listed activity 1(c) Listed activity 1(e) Listed activity 1(g) Listed activity 1(j) Listed activity 1(a)

Thus the proposed development qualifies on several grounds for a Scoping and EIA process as outlined in Regulation 385. 3.1.1 LISTED ACTIVITY 1(C) “1 (c) the above ground storage of a dangerous good, including petrol, diesel, liquid petroleum gas or paraffin, in containers with a combined capacity of 1 000 cubic metres or more at any one location or site including the storage of one or more dangerous goods, in a tank farm;“ Reason: Storage of Cr(VI) products 3.1.2 LISTED ACTIVITY 1(E) “1 (e) any process or activity which requires a permit or license in terms of legislation governing the generation or release of emissions, pollution, effluent or waste and which is not identified in Government Notice R386 of 2006;” Reason: Schedule II of the Atmospheric Pollution Prevention Act (Act 45 of 1965) includes: Process No 50: Chrome Processes – Processes in which any chrome ore or concentrate is treated for the production there from of chromium compounds or processes in which chromium metal is made or recovered by dry methods giving rise to noxious or offensive gasses. This is for the proposed chrome chemicals plant. Process No 30: Iron and steel processes - That is to say, processes- (a) in which iron, iron ores, steel or ferro-alloys are produced or processed so as to give rise to noxious or offensive gases; or (b) involving the cleaning of castings and handling of casting mould materials. This is for the potential smelting of process residue to produce ferrous alloys. Process No.29: Power generation processes - That is to say, processes in which- (a) fuel is burned for the generation of electricity for distribution to the public or for purposes of public transport; (b) boilers capable of burning fuel at a rate of not less than 10 tons per hour are used to raise steam for the supply of energy for purposes other than those mentioned in (a) above;


(c) any fuel burning appliance is used that is not controlled in terms of Part III of this Act, excluding appliances in private dwellings. This is for the proposed generation of electricity onsite. These APPA Schedule II processes are not identified in R386. 3.1.3 LISTED ACTIVITY 1(G) “1 (g) the use, recycling, handling, treatment, storage or final disposal of hazardous waste;” Reason: Handling, storage, treatment and final disposal of Cr(VI) contaminated wastes 3.1.4 LISTED ACTIVITY 1(J) “1 (j) the bulk transportation of dangerous goods using pipelines, funiculars or conveyors with a throughput capacity of 50 tons or 50 cubic metres or more per day;” Reason: Handling of Cr(VI) products and contaminated wastes 3.1.5 LISTED ACTIVITY 1(A) “The construction of facilities or infrastructure, including associated structures or infrastructure, for - (a) the generation of electricity where – (i) the electricity output is 20 megawatts or more; or (ii) the elements of the facility cover a combined area in excess of 1 hectare;” Reason: Potential generation of electricity on site, possibly exceeding 20MW.

3.2 AIR QUALITY Environmental legislation applicable to air quality includes the Atmospheric Pollution Prevention Act (Act 45 of 1965) (APPA), the National Environmental Management Act of (Act 107 of 1998) (NEMA) and the National Environmental Management Air Quality Act (Act 39 of 2004) (NEMAQA). In terms of Listed Process No. 50 in Schedule II to APPA, a “chromium process” is defined: “50. Chromium processes: That is to say, processes in which any chrome ore or concentrate is treated for the production there from of chromium compounds or processes in which chromium metal is made by dry methods giving rise to noxious or offensive gases.” Chrome chemicals manufacture therefore meets the above definition of ‘Chromium Processes’. As such a registration certificate is required in terms of this Act. Smelting of process residue to produce ferrous alloys has been identified as a potential alternative to waste disposal. This process would fall within the definition of an “Iron and Steel Process” as defined in schedule 2 to APPA. Process No 30: Iron and steel processes - That is to say, processes-

(a) in which iron, iron ores, steel or ferro-alloys are produced or processed so as to give rise to noxious or offensive gases; or (b) involving the cleaning of castings and handling of casting mould materials.

Electricity will be generated onsite for use onsite. The use of a boiler to produce steam to drive a turbine connected to a generator is an option for electricity generation. The proposed generation plant may meet the definition of a power generation processes


in terms of listed Process No.29 in Schedule II to APPA. “Power generation processes” are defined as: No.29: Power generation processes - That is to say, processes in which- (a) fuel is burned for the generation of electricity for distribution to the public or for purposes of public transport; (b) boilers capable of burning fuel at a rate of not less than 10 tons per hour are used to raise steam for the supply of energy for purposes other than those mentioned in (a) above; (c) any fuel burning appliance is used that is not controlled in terms of Part III of this Act, excluding appliances in private dwellings. Although sections of NEMAQA particularly relevant to the operations of Lanxess CISA have not been enacted as yet, the duty of care imposed by Section 28 of NEMA is relevant in the case of emissions of particulates and waste gases from the processes. Process emissions to air where significant risk of particulate emissions is present will be passed through electrostatic precipitators and/or other abatement equipment, thus limiting particulate emissions. Gaseous emissions namely NOx (oxides of Nitrogen) and SO2 emission levels from the existing facility and proposed facility will be evaluated as part of the Air Quality Impact Assessment, however SO2 emissions are not expected to be significant as the plant is fired by Sasol gas. If an alternative fuel source is used for the Cogeneration plant, this will be re-evaluated.

3.3 WASTE In terms of the definitions in the Environment Conservation Act (Act 73 of 1989) (ECA), “waste” is defined as: “Any matter (whether gaseous, liquid or solid or any combination thereof) which is an undesirable or superfluous by-product, emission, residue or remainder of any process which originates from any residential, commercial or industrial area and which is: a) discarded by any person; or b) is, accumulated and stored by any person with the purpose of eventually discarding it, with or without prior treatment connected with the discarding thereof; or c) is stored by any person with the purpose of recycling, re-using or extracting a useable product from such matter and d) building rubble used for filling or levelling purposes. “Excluded from the definition is - a) waste water disposed of in accordance with the National Water Act; b) French drains and septic tanks; c) minerals, tailings, waste-rock or slimes produced by or resulting from activities at a mine or works as defined in section 1 of the Mines and Works Act, 1956; and d) radio-active waste.” (Other laws regulate the excluded categories.) Furthermore, a "disposal site" is defined as: “a site used for the accumulation of waste with the purpose of disposing or treatment of such waste;” Waste generated from various processes will be accumulated on site and this therefore qualifies as a waste disposal activity as outlined above. One of the alternatives under consideration is the use of a silica-iron-chrome waste as raw material for a ferrochrome smelter that will be built on site. By strict interpretation of the law this means that the


area where waste is being stored, treated, or from which a valuable constituent is recovered, is regarded as a waste handling facility which should be permitted (or exempted from permitting) in terms of Section 20(1) of the ECA. Alternatively, it is anticipated that process residue will be disposed of in a dedicated mono-disposal (i.e. single waste type) facility to be constructed and operated for sub-aqueous disposal of treated residue. According to Section 20(1) of the ECA, “no person shall establish, provide or operate any disposal site without a permit issued by the Minister of Water Affairs...”. The standards for establishing, operating and closure of waste disposal sites are informed by the DWAF Minimum Requirements Waste Management Series (DWAF 1998a, DWAF 1998b, DWAF 1998c) documents. The second edition was released in 1998 and the 3rd edition is now also available, but still in draft form. By amendment to the ECA the Minister of Environmental Affairs and Tourism now replaces the Minister of Water Affairs to issue Section 20 waste disposal site permits. Provision is made for the Minister to grant exemptions from the permitting requirements. In conclusion, Lanxess CISA will therefore need to apply for: a waste disposal site permit in terms of Section 20(1) of the ECA

3.4 OCCUPATIONAL HEALTH AND SAFETY The Occupational Health and Safety Amendment Act, Act No. 181 of 1993, (OHSA) and regulations refer, specifically Regulation 7122 - Major Hazard Installations. In the OHSA it is stated that a: “ ‘major hazard installation’ means an installation: (a) where more than the prescribed quantity of any substance is or may be kept, whether permanently or temporarily; or (b) where any substance is produced, used, handled or stored in such a form and quantity that it has the potential to cause a major incident.” The quantities and type of substances referred to in (a) are prescribed in the General Machinery Regulation 8 and its Schedule A, of notifiable substances. A major incident as referred to in (b) is defined as follows: “a “major incident” means an occurrence of catastrophic proportions, resulting from the use of plant or machinery, or from activities at a workplace.” The site is already a registered MHI by virtue of storage of SO2 in pressurised tanks. The MHI status and associated legal and risk management requirements will be reviewed as part of the EIA phase.


4. PROJECT DESCRIPTION 4.1 DESCRIPTION OF ACTIVITY TO BE UNDERTAKEN Chromium chemicals are produced through the alkaline roasting of chromite ore in a rotary kiln where it is oxidized from its trivalent state - Cr(III) - to its hexavalent state - Cr(VI) - in the form of sodium monochromate, which is the basis for the production of sodium dichromate and chrome oxide, amongst other products. Refer to Figure 4-1: Overall Process Flow Diagram, for a brief illustration of the process. Chrome chemicals are typically used in leather tanning, metal treatment, wood preservation, refractory applications, pigments, chrome electroplating, aerospace and other exotic alloys. The manufacturing process technology and pollution abatement technology to be used in the SDC section of the plant are based on proven unit processes, currently in operation at Lanxess CISA’s Newcastle site. The plant will incorporate processes that minimize undesirable by-product formation, and maximize recycling streams. This will ensure that it meets world standards in process efficiency, health, safety and environmental control. The roasting kiln will use Sasol gas as fuel, provided it is available, as opposed to coal, and therefore avoid production and emission of sulphur dioxide (SO2). The plant will use water. Several containment facilities will be installed to contain all spillage and run-off from areas where water may become contaminated and all contaminated water will be recycled back into the process. The Chrome Oxide section of the facility will use process technology developed by an outside party. Some process effluent may be generated that needs to be disposed as process effluent. Detail process engineering will confirm the viability to reuse this effluent within the process. Lanxess may consider the installation of a cogeneration plant as a source of electricity and steam. This option is still under investigation. A Cogeneration unit would be sourced from a proven supplier and will comply with all regulations applicable to the type of process. If a reliable supply of electrical energy and process steam can be secured from existing operations, the investigation into a Cogeneration facility will be discontinued. One of the alternatives to waste disposal being evaluated is to use a metallurgical process to convert the ore residue (containing traces of hexavalent chromium) to a chrome material that can be sold as raw material to the Metal manufacturing industry. The availability of electrical energy and excessive capital requirements might limit the viability of incorporating this into the current project. The plant will produce the following range and tonnages of final product: Sodium Dichromate - 30 000 tonnes per annum (tpa) Chrome Oxide - 20 000 tpa Sodium Sulphate - 20 000 tpa Total Production ~ 70 000 tpa of sodium dichromate equivalents.

The ensuing diagrams provide illustration and descriptions of the various plant processes.

Lanxess CISA CHROME CHEMICALS PLANT – Scoping Report and Plan of Study for EIA Environmental Science Associates Page 9

Recycled Soda Ash

Recycle of residues

Gas NeutralizationOxygen

Purification Evaporation Acidification(concentration) (CO2)

Evaporation(concentration)

NeutralizationPurificationSales

Air purification (scrubber)

Ammonium dichromate

Chr

omite

46%

C

r2O

3,

moi

stur

e m

axim

um 3

%

Chrome oxideSales

Ore mill Mixing station

Mill

ed o

re

Kiln

Res

idue

s

Soda

ash

Hot air

Prec

ipita

to

SDC SolutionAmmonium sulfate

Sodium Sulfate

SDC packing and sales SDC solution

Soda

Ash

Leach tank

Disposal of residues

SDC crystallization

Kiln SMC solution

Dry

ing

(h

ot a

ir)

Residues

Figure 4-1: Overall Process Flow Diagram


Figure 4-2: Milling Mixing and Roasting Chromite ore is ground to less than 100µm, then mixed with soda ash and recycled material (residues from downstream leaching processes) in specific quantities and fed into a rotary kiln fired by Sasol gas. The kiln operates at a temperature of ≈1100ºC.


Figure 4-3: Treatment of Kiln Off-Gases Hot exhaust gases leave the kiln at approximately 800 °C. Entrained particulate matter is removed by a combination of cyclones and electrostatic precipitation. Heat energy is recovered by recuperation for reuse in other plant processes.


Figure 4-4: Leach Tank The kiln product is introduced to a leach tank where sodium monochromate (SMC) is taken into solution. The vapour produced is collected using a wet scrubber and condenser and returned to the leach tank. The resultant clean gas stream is passed to the atmosphere. All liquid streams are returned to the process.


Figure 4-5: Residue Filtration Plant The solid residue from the leach tank is treated on a vacuum belt filter to remove residual soluble chrome. The sodium monochromate solution filtered out is passed on to a concentration plant. The washed material is transferred to the recycling stream or to the residue treatment plant. The vacuum extract is passed through a wet scrubbing system..


Figure 4-6: Residue Treatment Process The solid residue from the filter belt is transferred to a series of vessels where it is reacted with reducing agents to convert any residual Cr (VI) to Cr (III). The exhaust gases from the process are routed to atmosphere after passing through a wet scrubber.


Figure 4-7: Treatment of Recycled Material The portion of solid residue required for recycling in the kiln is transferred to a flash drier to remove moisture. The wet residue is mixed with dry material before introduction into a hot gas stream. The material is carried by the gas stream to cyclone separators where it arrives dry and is separated from the gas stream. The resulting gas stream is routed through the electrostatic precipitator (ESP) before venting to atmosphere via the ESP stack..


Figure 4-8: Sodium Monochromate Purification – Vanadate Removal Vanadium is removed from the sodium monochromate solution by pH adjustment and filtration. The resulting calcium vanadate removed is transferred to the vanadium recovery plant.


Figure 4-9: Sodium Monochromate Purification – Calcium Removal Calcium is removed from the sodium monochromate solution by precipitation of calcium carbonate. The cake is transferred to the residue treatment plant


Figure 4-10: Sodium Monochromate Concentration The purified SMC is concentrated up in a 4 stage vacuum evaporator. The vapour is routed to atmosphere after cleaning. The condensate recovered is used as clean process water in the process.


Figure 4-11: Conversion of Sodium Monochromate to Sodium Dichromate CO2 gas is used to acidify the Solution and convert to SDC. Sodium Bicarbonate is separated and sent to a Calcining plant for recycling back into the process.


Figure 4-12: SDC Crystallisation SDC solution is concentrated in an evaporator. The concentrate is crystallised and dried in a rotary drier. Vaporous emissions from the crystalliser and evaporator are scrubbed before exhausting to atmosphere


Figure 4-13: Sodium Sulphate Plant The sodium sulphate is treated with a reducing agent to remove any residual Cr(VI). The resulting product is filtered and the resulting sodium sulphate solution concentrated by evaporation and drying to produce a solid sodium sulphate.


Figure 4-14: Chrome Oxide Plant SDC and ammonium sulphate are reacted to produce ammonium dichromate and sodium sulphate. The sodium sulphate is transferred to the purification plant. The ammonium dichromate is recovered as crystals and converted to chrome oxide in a rotary kiln. The product is quenched and filtered, dried in a rotary drier and packaged. All gas streams are vented to atmosphere via a bag house/scrubber. All effluents are reintroduced into the process via the mixing tank. Bag house dust is recycled back to the furnace.


Figure 4-15: Sodium Bicarbonate Calcining Sodium bicarbonate from the SMC-SDC acidification is passed trough a fluidised bed calciner. Hot air from the calciner is recycled through a bag house. A percentage of the air is bled off through a wet scrubber to maintain the efficiency of the process.


4.2 MOTIVATION FOR THE DEVELOPMENT The extraction and beneficiation of South African chromium ore reserves plays a key role in the global chrome supply system. South African reserves account for approximately 70% of the world’s total chrome reserves (mostly derived from the Bushveld Igneous Complex). Correspondingly, South Africa produces 75% of the world’s ferrochrome, yet only produces approximately 8% of the world’s chrome chemicals. The proposed Lanxess CISA chrome chemicals production facility is anticipated to produce 8% of the world’s chrome chemicals. Consequently the plant will be a major contributor to the beneficiation of South Africa’s chrome resources. With the increased beneficiation capacity come numerous direct and indirect positive socio-economic impacts in the local and national context: Increased export hence:

increased foreign revenue earnings positive effect on balance of trade

Job creation: approximately 100 permanent direct employment opportunities approximately 1600 employment opportunities during the construction phase.

From an environmental perspective, producing lower volume, higher value products closer to the raw resource saves on transport costs and the associated emissions and consumption of fuel. Proximity to an existing chrome chemicals facility will result in suitable expertise being available to manage environmental impacts, including avoidance and minimisation of potential negative impacts. Table 4-1: Investment Summary product investment direct

employment opportunities

local content contribution to development

indirect employment opportunities

tonnes/a Rands persons percentage persons sodium dichromate 70 000 1 500 m 100 70% oxide pigment 20 000 300 m 20 90% sodium sulphate 20 000 200 m 20 80% total 2 000 m 140 1600 These estimates are based on knowledge of the existing facilities and processes.


4.3 PROPERTY PARTICULARS 4.3.1 NAME OF PROPERTY Subsection 2 of Lot 13661 and Subsection 3 of Lot 13661. Karbochem Road Newcastle KwaZulu-Natal 4.3.2 LOCAL AUTHORITY The subject property is located within the jurisdiction of the Newcastle Municipality. 4.3.3 LAND USE ZONING The land is presently zoned for industrial use.

4.4 LOCAL AUTHORITY AND SERVICES PROVIDER Newcastle Municipality.

Figure 4-16: Satellite image


5. PARTICIPATION PROCESS The scoping phase included the following public participation components: Identification and registration of I&AP’s on a database using Newspapers advertisements On site notices Personal invitations to pre-identified persons and organisations Disseminating information and noting comments through Distribution of a background information document Public meeting Authorities meeting

For full details of the process undertaken, minutes of public and focus group meetings and issues discussed see appendix 2: Public Participation Report.


6. DESCRIPTION OF THE ENVIRONMENT AND POTENTIAL IMPACTS

6.1 SURROUNDING LAND USE

Figure 6-1: General map of the area showing surrounding land use.


Figure 6-2: Oblique aerial photograph showing the Karbochem site, with the existing Lanxess CISA chrome chemicals plant circled in red.

Figure 6-3: Satellite image The proposed site is on the Karbochem site in Newcastle, where Lanxess CISA already has a chrome chemicals plant. The existing Lanxess CISA chrome chemicals plant shares the Karbochem site with three other industrial tenants. To the north of the site is the Newcastle Airfield; whilst to the south is a small tributary of the Ngagane River and then open ground. To the west is the N11 highway and then a residential suburb (Arbor


Park) of Newcastle, whilst to the east is open land and then the Ngagane River, that here flows northwards.

6.2 STATE OF THE ENVIRONMENT The State of the Environment report for the KwaZulu Natal province had not been finalised. Consequently a general overview of the state of the environment for the region is not available. The ensuing section will however cover the important environmental concerns relevant to the proposed development, based observations in the area, knowledge of processes and industry in the area, and general issues of national concern. 6.2.1 AMBIENT AIR QUALITY Air quality is an issue of concern in many other parts of South Africa. A wide variety of air pollution sources exist in the province and nationally. Nationally, atmospheric sources which have been noted to be contributing to air quality limit exceedances and which are associated with increasing emissions include:

o road vehicle exhaust emissions, o coal-fired power stations, o airport releases (specifically international airports) and o poorly controlled industrial operations.

A variety of pollutants including heavy metal containing particulates, Oxides of Nitrogen, Sulphur Dioxide, and volatile organic compounds are emitted from these activities. Numerous sources of air pollutants exist in areas close to the proposed site. Several large scale industrial facilities operate in proximity to Lanxess. These include

o Ferroalloy operations o Pyro-metallurgical facilities o Manufacturers of organic chemical products, and more.

In addition the town of Newcastle hosts various industrial operations. Oxides of nitrogen (NOx), nitrogen oxide (NO), nitrogen dioxide (NO2), inhalable particulates (PM10) and sulphur dioxide (SO2) are potential air qualities issues of concern. The state of ambient air quality will be considered based on measurements from Lanxess facility and industry in the area who undertake ambient monitoring. This will form part of the ambient air quality impact assessment.

Sulphur dioxide The kiln and rotary drier to be used in the proposed process will be fired by Sasol gas, thus it is not expected that there will be a significant contribution to the current ambient sulphur dioxide levels.


Oxides of nitrogen The kiln and rotary drier to be used in the proposed process will be fired by Sasol gas. Nitrogen oxides form, when fuel is burned at high temperatures, thus the combustion processes have the potential to generate and emit oxides of nitrogen. The potential impact of these emissions will be evaluated as part of the Air Quality Impact Assessment. At a national level nitrogen dioxide air quality limit exceedances are currently mainly restricted to high density traffic-related sites and exceedances of limits for short-term averaging periods, the spatial extent and frequency of exceedance is anticipated to be increasing due to increased rates of vehicle activity. Ozone concentrations have been found to exceed health limits at most sites at which this pollutant is measured [DEAT 2007].

Particulates Increasing emphasis is being placed on PM10 due to the issuing of linear dose-response curves for this pollutant by health organisations such as the World Health Organisation and the implementation of very strict limits for this pollutant by European and Australasian countries. [DEAT 2007]. Ambient air levels of particulates will be measured during the air quality impact assessment. Any data which is available from existing ambient monitoring stations will also considered during the assessment in order to determine the projected cumulative impact from the proposed development. Ambient concentrations of hexavalent chrome have been monitored by Lanxess, and are currently sampled and measured on three week basis. The concern with hexavalent chrome lies in its chronic health effects, and international ambient limits for atmospheric pollutants are generally quoted in terms of 24hr limits, daily limits (i.e. 24hr), and/or annual limits. Consequently it will be necessary to correlate the existing data with measurements to be taken on a 24hr basis. These can then be extrapolated using accepted methodologies to annual limits. Annual guideline limits are expected to be of particular value by virtue of the risks associated with chronic inhalation of hexavalent chrome. 6.2.2 GEOLOGICAL AND GEOHYDROLOGICAL ENVIRONMENT According to an EIA undertaken by the CSIR for Lanxess CISA in 1997, the area is underlain by sandstone, mudstone and shale of the Vryheid Formation. Ecca Group. It varies in thickness from 260 - 320 m. The disposition of the Karoo sediments locally is strongly influenced by the numerous dolerite intrusions, in the form of sheets and dykes. Limited alluvial deposits, seldom more than 2 m thick, generally occur along and in the channels of the larger streams and rivers. The development of secondary aquifers due to weathering and dolerite intrusions controls to a large degree the water bearing characteristics of the formations around Newcastle. The CSIR postulated that two aquifer types are present in the study area. The first is an upper aquifer situated in the weathered and fractured sandstone above the first dolerite sheet. The second is a lower semi-confined aquifer associated with the fractured dolerite/sandstone contact at the base of the first dolerite sheet and the sediments below this contact.


Typical of the Karoo Sequence, the majority of ground water is associated with contacts of the dolerite intrusions (dykes and sills), within fractured intrusions. To a lesser degree it also occurs within fractured sandstones and shales. The ground water levels are shallow and accordingly some areas are prone to water logging. [CSIR 1997] 6.2.3 SURFACE WATER The Karbochem site occurs in the Buffalo River catchment, the most northerly secondary catchment of the Tugela River catchment. The Ngagane River flows north east toward Newcastle passing within about 2 km of the Karbochem site. The Chelmsford Dam is some 25 km to the south and upstream of the Karbochem site. ISCOR is situated downstream of Karbochem and is a major user of water from the Ngagane River. The Ncandu River, occasionally contaminated with various industrial runoff waters, flows in a north easterly direction some 6.5 km north west of the Karbochem site. The Karbochem spruit flows in a north-easterly direction, immediately to the south of the Karbochem site, into the Ngagane River. It has little or no flow upstream of the Karbochem site during dry periods. Downstream flow is predominantly discharged treated effluent and runoff from Karbochem. [CSIR 1997]

6.3 SOCIO-ECONOMIC ENVIRONMENT A significant percentage of households in South Africa are considered to be living in poverty and a considerable fraction of the population are considered poor. Literacy and education is also a problem, and there has also been a decrease in life expectancy, probably due to HIV/AIDS, and is expected to decrease even further. Unemployment in KwaZulu-Natal is on the increase (from 1996 to 2002 the unemployment rate increased from 39.5% to 47%). Unemployment in rural areas is a particular problem and is as much as 74% [KZN DAEA report 2004]. It is estimated that approximately 100 direct employment opportunities will become available for the operating phase. About 1600 employment opportunities are anticipated during the construction phase, upstream processes, downstream process and service provision related to the industry. 6.3.1 PLACES OF ARCHAEOLOGICAL AND CULTURAL IMPORTANCE The site falls within an established industrial site. As the site has a long term industrial history, evidence of any cultural and archaeological nature which may be present is neither visible nor accessible. Due to the established nature of the site and its location in an industrial area it is not expected that any places of archaeological or cultural importance occur on the site itself. Any finds, of archaeological importance, made during the geohydrological and geotechnical studies will be reported and accordingly considered in the EIA and formulation of EMPs. 6.3.2 RESIDENTIAL AREAS IN VICINITY OF THE PLANT Arbor Park is the closest residential area and is approximately 1.3km to the north west of the proposed plant site. Newcastle airport lies approximately 500m north of the main process plant site. It is anticipated that the air quality in these populated areas in the vicinity of the site may be impacted upon. An air quality impact assessment will be conducted as part of


the Environmental Impact Assessment to evaluate the potential impact and thus contribute towards the identification and implementation of effective emission control strategies.

Figure 6-4: Residential Areas in the vicinity of the site 6.3.3 MAJOR ACCESS ROUTES The main access route to the site is from the N11 highway. 6.3.4 SENSITIVE ENVIRONMENTAL RECEPTORS The nearest significantly populated area is Arbor Park. Approximately 1.3km North West of the proposed site. This area may be impacted upon by atmospheric emissions from the proposed plant. The impact on air quality due to the proposed development will be assessed as part of the Environmental Impact Assessment.

Lanxess CISA CHROME CHEMICALS PLANT – SCOPING REPORT & PLAN OF STUDY FOR EIA Environmental Science Associates Page 33

7. ENVIRONMENTAL ASPECT & IMPACT REGISTER Refer to Appendix 1: Impact Assessment Method, for a detailed breakdown of the method used for the assessment of environmental aspects and their associated impacts. Differentiation between impact significance and impact management priority is determined by existence of applicable legislation.

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Low

Noise Noise pollution Site Temporary Definite Low

Low

National Air Quality Management Act of 2004.

Low

Noise during installation and assembly of equipment, expected to have no significant impact outside of the site. People working on-site will wear ear protection as per Lanxess CISA Health and Safety rules.

Low

Construction waste

Contribution to landfill Locally Permanent Definite Low

Low

Minimum Requirements for the Handling Classification and Disposal of Hazardous Waste

Low

The project does not include any significant changes to, or additional, building structures. Construction waste produced will be minimal.

Low

Installation

Installation waste

Contribution to landfill Locally Permanent Definite low

Low

Minimum Requirements for the Handling Classification and Disposal of Hazardous Waste

Low

Small amounts of steel and electric cabling waste, and possible packaging waste will be produced.


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Noise Noise pollution Site Long Term Definite Low

Low

National Air Quality Management Act of 2004.

Low

Noise generated as a result of running machinery is expected to have no significant impact outside the site. People onsite will wear ear protection as per Lanxess CISA’s Health and Safety rules.

High Gaseous and particulate emissions from Kiln and Rotary Driers

Air pollution Regional Long term Definite Medium

Low

National Environmental Management Air Quality Act: 2004

High

Air emissions to air will be treated via cyclone separators, bag-filter plants and electrostatic precipitation.

low Other gaseous emission including vapour emissions

Air pollution Regional Long term Definite Medium

Low

National Environmental Management Air Quality Act: 2004

High These emissions will be treated via scrubbers after condensation.

High

Groundwater contamination

Water pollution Local Long term Unlikely Moderate

Low

National Water Act of 1998;

High

Provided that raw materials and waste are adequately stored, handled and disposed of it is unlikely that groundwater contamination will result from the proposed development

Operation

Effluent generation

Water pollution Regional Short term Definite Medium Medium National

Water Act of High Water and solutions generated/used in the


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Low 1998 process will largely be recycled.

Medium Job creation Socio-

economic Locally Long term Definite Medium

LOW

Low Use of raw materials and energy

Depletion of natural resources

Regionally Long term Definite Low Low

Environmental Conservation Act: 1989,

Low

Energy and raw material usage to be monitored and managed to ensure optimal usage

High

Handling and disposal of hazardous waste

Surface and ground Water pollution

Local Long term Definite Moderate

Low

National Environmental Management Act (Act No. 107 of 1998). Department of Water Affairs and Forestry Minimum Requirements for the Handling, Classification & Disposal of Hazardous Waste.

High

Hazardous waste containing chrome, aluminium and other metals will be generated by the process, hazardous waste to classified and hazard rated, handled and disposed of as per the Minimum Requirements for the Handling, Classification & Disposal of Hazardous Waste.


7.1 CONSTRUCTION IMPACT ASSESSMENT AND MITIGATION 7.1.1 NOISE The generation of noise during installation of the proposed facilities is rated as low with or without mitigation. The closest built up area to the proposed sites is the adjacent Karbochem industrial site, and given that heavy industrial activities are undertaken on the site it is highly unlikely that noise from the construction of the proposed development will pose a nuisance. The closest other built up and inhabited area is approximately 2km west of the proposed sites - due to this distance it is highly unlikely that noise from the construction of the proposed development will pose a nuisance. 7.1.2 CONSTRUCTION WASTE It is expected that minimal waste will be generated during the installation of the proposed structures and equipment, most of which will be rubble, steel and general waste. Consequently, generation of construction waste is rated as low, with and without mitigation.

7.2 OPERATIONAL IMPACT ASSESSMENT AND MITIGATION 7.2.1 EMISSIONS TO AIR Emissions to atmosphere will include: particulate emissions Cr6+ containing particulate emissions oxides of nitrogen emission of vapours from various mixing and vacuum separation processes.

Emissions to atmosphere will be treated via a combination of: condensers scrubbers cyclone separators bag filter plants electrostatic precipitation.

These technologies will be applied as appropriate to the source and nature of the emission. See the process illustrations for further detail. Emissions to atmosphere are the aspects of the greatest significance due to their potential impact on ambient air quality and proximity of populated receiving areas, especially in view of the carcinogenic potential of Cr6+ via inhalation. 7.2.2 GENERATION AND DISPOSAL OF HAZARDOUS WASTE The following major waste streams, including more minor streams not being listed here, will need to be considered in terms of handling, storage, treatment, re-use and disposal options: Electrostatic precipitator and bag filter dusts - generated as a result of emissions

abatement - this is recycled directly back to the process.


Post treatment residue filter cake - following the leaching of chromium product, residue is treated to reduce Cr6+ to Cr3+ - this waste stream needs to be handled and disposed.

Scrubber sludges will be recycled back to the process. Slag produced from smelting of residue will also have to be investigated. It is

expected that the slag will be classified as product to be sold to third parties for downstream process uses.

These are all potentially hazardous wastes due to the presence of chrome (potentially containing Cr6+), trace amounts of other heavy metals, as well as sodium and its salts (as a result of stochiometric excess of soda ash used in the kiln). 7.2.3 ENERGY AND RAW MATERIAL USAGE The chief sources of energy in the process will be Sasol gas, electricity and steam. If a Cogeneration facility needs to be erected, the main energy source will likely be coal. Various raw materials including water will be fed into the process. Note that the process has been designed such that energy is recovered from high temperature processes and emissions for use in lower temperature processes thus improving energy efficiency. Various vapours, solids, and solutions produced are recycled to ensure maximum product extraction. 7.2.4 GROUNDWATER CONTAMINATION No significant interaction with groundwater is anticipated provided that raw materials, products and waste are handled and stored appropriately. Production will be undertaken on hard surfaced impermeable paving with HDPE (High Density Poly Ethylene) lining underneath, and an engineered drainage and leak detection system. The waste disposal site will be constructed, operated and decommissioned in such a way as to prevent any leakage to soil or groundwater, using the DWAF Minimum Requirements documents as guidelines. Alternative sites will be investigated to identify the most suitable site. 7.2.5 EFFLUENT GENERATION AND MANAGEMENT Process solutions will be introduced to improve extraction and input material efficiencies. The system will require water replenishment due to inherent losses, which in the main include: Evaporation Residue disposal – treated waste will be disposed of sub-aqueously. Water of crystallisation carried out in the product. A portion of the final product will be sold as liquid

The SDC plant will be a zero effluent plant. Detailed investigations need to be carried out to evaluate the viability of configuring the Chrome Oxide and Sodium Sulphate sections of the plant to also be zero effluent. Uncontaminated surface water approaching the site from upstream will be diverted around the site to prevent contamination. Potentially contaminated storm water will be collected in storm water dams for testing before release. If the water is contaminated, it may be treated before release or used as process water.


7.2.6 NOISE Noise generated by the process is not expected to be significant beyond the boundary of the site.


8. ALTERNATIVES 8.1 SITE ALTERNATIVES The establishment of the chrome chemicals plant also requires the building of a hazardous waste landfill. These two activities need to occur in tandem and so siting of the one will influence siting of the other. For both of these activities, a selection of alternative sites around the current Karbochem site is under consideration refer to the ensuing Figure 8-1: Site Alternatives. The reason for locating all alternative sites close to the current Lanxess CISA chrome chemicals plant is that the proposed chrome chemicals plant will be almost identical to the existing plant and therefore the expertise available on site will assist with the construction and operation of the proposed plant. The two operations will make use of current infrastructure and will also share in a common raw material supply and final product dispatch system. Furthermore, this expertise includes the management of environmental impacts – clustering of the proposed plant and the existing plant prevent the spreading of environmental impacts further afield by containing all such operations in one area.

Figure 8-1: Site Alternatives

8.2 PROCESS AND PRODUCT ALTERNATIVES The core chrome chemicals process is a proven process and the existing plant will essentially be replicated in the proposed plant. One significant process alternative is, however, under consideration. This is to use the ore residue from the process as feedstock for a ferrochrome smelter that could be built on site. This constitutes beneficial


use of a waste product, but will entail further capital investment and running costs (energy, etc).

8.3 NO-GO OPTION The no-go option has the potential to prevent both negative and positive impacts on the environment. The no-go option will be evaluated as part of the main EIA, and will be particularly relevant should it be found that detrimental impacts cannot be managed to an acceptable level.


9. PLAN OF STUDY FOR EIA This plan of study has been formulated to meet the requirements for a plan of study for Environmental Impact Assessment as set out in regulation 29.1(i) of GNR385 of the 2006 NEMA EIA Regulations: “29.1(i)a plan of study for environmental impact assessment which sets out the proposed approach to the environmental impact assessment of the application, which must include (i) a description of the tasks that will be undertaken as part of the environmental impact assessment process, including any specialist reports or specialised processes, and the manner in which such tasks will be undertaken; (ii) an indication of the stages at which the competent authority will be consulted; (iii) a description of the proposed method of assessing the environmental issues and alternatives, including the option of not proceeding with the activity; and (iv) particulars of the public participation process that will be conducted during the environmental impact assessment process;”

9.1 SPECIALIST STUDIES AND REPORTING The identification and assessment of environmental impacts reveals the following potentially significant environmental aspects which require further detailed assessment: air quality assessment: to study criteria pollutants emitted by various sections of the

proposed plant (in particular major sources of emissions, e.g. the kiln and rotary drier), to allow specification of emissions abatement technology and plant parameters (e.g. stack height)

hexavalent chromium ambient air quality baseline and emission assessment: to determine current exposures and investigating emission and abatement of hexavalent chromium from the plant

waste disposal assessment: to investigate requirements for waste handling, storage, treatment and disposal, with a specific focus on hazardous wastes generated by the process

geohydrological and geotechnical site assessments: to determine rock and soil properties and groundwater baseline quality and water levels in order to identify areas more or less suitable for locating the plant and waste disposal facilities

storm water management study: to investigate the generation of contaminated water from the process or the site and recommend strategies for the containment and management of storm water

MHI risk assessments: a review of the facilities MHI status and updating requirements in terms of registration and risk management will be undertaken by an approved MHI Risk Assessor.

9.1.1 AIR QUALITY IMPACT ASSESSMENT A specialist study will be undertaken to determine the potential impact of gaseous and particulate emissions from the plant on ambient air quality. The following emissions from the proposed plant have been identified as potentially significant in terms of the possible effect on ambient air quality:


hexavalent chromium (Cr6+) containing particulates (specifically PM10) (Cr6+ will emissions will be in the form of particulates)

Oxides of nitrogen (NOx) SO2 if coal is used as primary fuel.

Although sulphur dioxide (SO2) is a regional issue of concern, the proposed project will not contribute to levels of SO2 in the atmosphere as the kiln will be fired by natural gas which is virtually sulphur free.

Objectives and Methods The air quality impact assessment will comprise the following activities: review and quantification of current air quality in the area, to establish a baseline for

the impact assessment and thus quantify cumulative impacts on air quality formulation of emissions inventory and calculation of emissions to atmosphere

emanating from to the proposed operations dispersion simulation to predict increases in ground level concentrations illustrated

through contour plots for projected emission dispersion iterative refinement of inventory and dispersion model validation of existing emission dispersion model results against actual monitoring data.

The proposed format for the study is illustrated in Figure 9-1: Plan of Study for Air Quality Impact Assessment


Figure 9-1: Plan of Study for Air Quality Impact Assessment


Background Air Quality Information Gathering Ambient air quality monitoring data which will be evaluated for the purposes of this study includes results from: Lanxess CISA’s site ambient air quality measurements taken in preceding years DEAT SAWS airborne survey Newcastle Municipality monitoring station DOAS airborne measurements Data from neighbouring sites if it exists and can be accessed

Data available for NOx concentrations may be limited to Newcastle municipality’s data. Ground level ambient measurements of Cr6+ are undertaken by Lanxess CISA. Additional Ambient monitoring of Cr6+ will be undertaken to inform the impact assessment. The method to be employed is outlined in Appendix 3: Determination of Hexavalent Chromium in Ambient Air.

Emissions inventory In order to allow the prediction of impacts to atmosphere by the chrome chemicals plant, an emissions inventory for the whole Karbochem site will be compiled. The emissions inventory and data for the proposed plant will be based on emission data from the existing chrome chemicals plants. The basic design data for the plant will be used to determine all potential emissions sources and the expected emissions rates and characteristics based on the design parameters and mass flow rates in comparison to the data obtained from similar operating plants.

Dispersion Modelling Atmospheric dispersion modelling is the mathematical simulation of how air pollutants disperse in the atmosphere surrounding a facility. It is performed with computer programs which solve mathematical equations and algorithms that simulate the pollutant dispersion. Various types of model have been developed for predicting the concentrations of chemicals emitted into the atmosphere in the vicinity of an emission source. The dispersion models are used to estimate or to predict the downwind concentration of air pollutants emitted from sources such as industrial plants and vehicular traffic. The models are typically employed to determine whether existing or proposed new industrial facilities are or will be in compliance with the ambient air quality standards (e.g. SANS 1929: Ambient Air Quality Limits for Common Pollutants, and National Environmental Management Air Quality Act of 2004 SCHEDULE 2: Ambient Air Quality Standards). The models also serve to assist in the design of effective control strategies to reduce emissions of harmful air pollutants. The dispersion models require the input of data such as: meteorological conditions: wind speed and direction, air temperature, atmospheric

turbulence and atmospheric characteristics such as the presence and nature of a temperature inversion layer


emissions parameters: source location, vent stack diameter, height, and exit velocity, exit temperature and mass flow rate

terrain and elevation at and between source and receptor locations location, height and width of any obstructions (such as buildings or other structures)

in the path of the plume. Prediction of the potential impact on ambient air quality will be undertaken using an ADMS dispersion model, or the CALPUFF Modelling System. ADMS has the ability to simulate a wide range of buoyant and passive releases to the atmosphere either individually or in combination. The model takes into account the effects of buildings, terrain and coastlines on dispersion. The development of ADMS 3 was undertaken by Cambridge Environmental Research Consultants (CERC) with technical assistance from the UK Meteorological Office and the University of Surrey. The model has been extensively validated against field data sets since 1992. (CERC 2004). CALPUFF is non-steady-state puff dispersion model that simulates the effects of time- and space-varying meteorological conditions on pollution transport, transformation, and removal. CALPUFF can be applied for long-range transport and for complex terrain [EPA CALPUFF]. The CALPUFF model is designed to simulate the dispersion of buoyant, puff or continuous point and area pollution sources as well as the dispersion of buoyant, continuous line sources. The model also includes algorithms for handling the effect of downwash by nearby buildings in the path of the pollution plumes [Wiki 2008]. Final selection of the preferred model will be undertaken based on consideration of meteorological and terrain data for the area.

Estimation of Cumulative Impact The emissions inventory and data used for the initial dispersion model will also take into account other significant emitters of priority pollutants (particulates (PM10), Cr6+ and NOx) as well emissions of Cr6+ in the vicinity of the proposed site. The inclusion of these emission sources will facilitate an estimation of the cumulative impact of the additional emissions from the proposed plant on ambient air quality.


9.1.2 HEXAVALENT CHROMIUM AMBIENT AIR IMPACT ASSESSMENT Chromium is a naturally occurring element found in rocks, animals, plants and soil. Chromium is present in the environment (natural and man-made) in several different forms, the most common of which are: chromium metal (Cr) trivalent chromium (Cr3+) hexavalent chromium (Cr6+).

In air, chromium compounds are present mostly as fine dust particles which eventually settle over land and water. Of the three oxidation states of chromium, hexavalent chromium (Cr6+) is known for its strong oxidising characteristics and many Cr6+ compounds are soluble in water. Cr6+ has been identified as a hazardous chemical compound due to its ability to readily penetrate biological membranes and the fact that it is carcinogenic through inhalation - it is a known inhalation irritant and associated with respiratory cancer. Hexavalent chromium of anthropogenic origin is generated from a number of commercial and industrial sources. Rain helps remove chromium compounds from air. Chromium compounds will usually remain in the air for fewer than 10 days (ATSDR 2000).

Objectives and Methods The objective of this study will be to determine the baseline ground level exposure values of the receiving environment up and downwind of present Cr6+ emissions sources in the vicinity of the proposed site. This will inform the estimation of the cumulative impact of Cr6+ emissions of the proposed chrome chemicals plant and the existing chrome chemicals plant. The methods to be applied include the following: confirmation and refinement in the selection of sampling sites based on prevailing

atmospheric conditions and initial monitoring results (sampling will be undertaken upwind and downwind

sampling with pump and filter discs and chemical analysis will be undertaken in accordance with California Environmental Protection Agency Standard Operating Procedure For The Analysis Of Hexavalent Chromium At Ambient Atmospheric Levels By Ion Chromatography (SOPMLDO39)

monitoring results will be compared to international ambient Cr6+ guidelines and standards as a baseline assessment

monitoring results will be used to inform a worst case scenario Cr6+ background level which will be used as background level for dispersion modelling to predict total ground level Cr6+ resulting from current and proposed activities; results will again be compared to international guidelines for ambient Cr6+ limits

Sampling and Analytical Procedure Refer to Appendix 3: Determination of Hexavalent Chromium In Ambient Air for detail of the California-EPA analysis procedure referred to above.

Sampling Locations In order to deduce the contribution of existing activities to the ambient Cr6+ concentrations in Newcastle, sampling will be undertaken both up and downwind of the Karbochem site simultaneously.


9.1.3 HANDLING TREATMENT AND DISPOSAL OF HAZARDOUS WASTE Sodium chromate and dichromate are produced by a process in which ground chrome ore and soda ash are mixed and roasted in an oxidizing atmosphere, whereafter the roasted ore is leached. The resulting leach liquor is separated from the remaining leach residue, which is treated with a reductant to reduce Cr6+ in the residue; refer to Figure 9-2: Waste treatment and generation processes.

Figure 9-2: Waste treatment and generation processes The following major waste streams, as well as other minor streams not listed here, will need to be considered in terms of handling, storage, re-use, recycling, treatment and disposal options: electrostatic precipitator and bag filter dusts - generated as a result of emissions

abatement - this is recycled back to the plant but needs to be handled post treatment residue filter cake - following the leaching of chromium product,

residue is treated to reduce Cr6+ to Cr3+ - this waste stream needs to be handled and disposed

scrubber sludges will be recycled back to the process. slag produced from smelting of residue will also have to investigated

These are all potentially hazardous wastes due to the presence of chrome (potentially containing Cr6+), trace amounts of other heavy metals, as well as sodium and its salts (as a result of stochiometric excess of soda ash used in the kiln).

Objectives and Methods The waste management assessment will comprise the following activities: review of literature


waste classification and hazard rating identification and evaluation of reuse and recycling options identification and evaluation and treatment and disposal options.

The Minimum Requirements for the Handling, Classification & Disposal of Hazardous Waste (DWAF, 1998) will further be used as a point of departure for discussion of storage, handling, treatment, and disposal procedures for hazardous waste.

Review of literature Waste classification and hazard rating in terms of the Department of Water Affairs and Forestry Minimum Requirements for the Handling, Classification & Disposal of Hazardous Waste will be undertaken based on existing waste stream analyses. A comprehensive body of information on the wastes from chrome chemicals production has been compiled by the US EPA so as to inform regulation of mineral processing wastes (EPA 1990, Chapter 4 Sodium Dichromate production), this will also be reviewed to inform the EIA. Information from the South African Ferro-Alloy Producers Association will also be reviewed for smelting wastes

Waste Classification and Hazard Rating The waste hazard characterisation process requires full chemical analysis of the by-products, which allows the risk assessment to focus on chemicals of potential concern. An attempt will be made to obtain post treatment residue filter cake samples from the existing Newcastle Lanxess chrome chemicals plant. These samples will be subjected to compositional analyses as well as to Toxicity Characteristic Leach Potential (TCLP) and/or Acid Rain Leach Tests to empirically determine and quantify the nature of the hazardous components that may leach. The TCLP and Acid Rain Leach Tests will be conducted in accordance with the requirements of the Department of Water Affairs and Forestry Minimum Requirements for the Handling, Classification & Disposal of Hazardous Waste.

Reuse and Recycling Options The following options for reuse of hazardous waste will be investigated as a minimum: the use of treated waste residue (after treatment to reduce Cr6+ to Cr3+) as

pozalanic or fine silicaceous material in concrete for civil and structural works the use of chromium bearing by-products as feed for a ferrochrome smelter.

Waste Treatment and Disposal Options The results of compositional analyses, TCLP and Acid Rain Leach Tests and the literature review will be used to identify treatment strategies to reduce the harmful components of the waste so as to minimise the potential impact of the waste on the environment.


Identification and evaluation of reuse, recycling, treatment and disposal methods will involve a generic gate process whereby wastes will be considered for re-use; refer to Figure 9-3: Waste treatment and re-use stage gate decision process.

Figure 9-3: Waste treatment and re-use stage gate decision process The disposal of treated residue to a suitably permitted waste disposal site will be assessed based on the outcomes of the classification and hazard rating exercise. When products from such wastes are disposed of, re-introduced into society, or when direct use of such materials for useful applications is allowed, the potential for exposure of a wide spectrum of members of the community has to be considered. The disposal and re-use options will be evaluated against each other in terms of: environmental impact exposure risk assessment economic feasibility.

9.1.4 GEOTECHNICAL ASSESSMENT The geotechnical assessment aims to understand the ground conditions across the site, to allow the selection of a suitable site in terms of safe construction and operation of the chrome chemicals plant.

Phase 1 Desk-top study of all relevant, available information, including a walk-over site visit.


Phase 2 Geophysical surveys at the proposed site to investigate general trends with respect to depth of weathering, nature of soil, presence of intrusions and/or structural features.

Phase 3 Site investigations, initially across the entire site to verify results of the geophysical surveys, followed by more detailed investigations at the proposed plant site area. The main investigation technique will be test pitting with an excavator to at least soft rock level, expected at a depth of not more than 5m. Soil will be profiled to obtain relevant engineering geological parameters, while representative samples be taken for laboratory testing. Laboratory testing will include foundation indicator, modified AASHTO compaction, consolidation and permeability tests. Limited chemical analyses will also be conducted on seepage water samples to determine soil aggressiveness towards concrete and mild steel.

Phase 4 Analysis and documentation will constitute the final phase of the work. All the results will be documented in a report, including drawings and maps with foundation recommendations for the various elements of the plant, while comments will also be made with respect to hazardous waste disposal. The report will also include recommendations for design level investigations required for the plant site. 9.1.5 GEOHYDROLOGICAL ASSESSMENT A geohydrological assessment will be conducted to determine the baseline groundwater conditions of the site and inform the locating of the chrome chemicals plant and the waste disposal site. In particular, the following are the envisaged outputs of this study: an overview of the geology and geohydrology in the study area the spatial distribution of geohydrological units, their main properties and the

hydraulic connections the hydraulic gradients and ground water flow directions and possibly an indication

of the velocities analysis of groundwater chemistry, specifically to identify any possible existing

contamination, both in nature and distribution geohydrological assessment of the suitability of proposed sites and identification of

inherent fatal flaws or no-go areas. Note that a major output of the geohydrological assessment is the set boreholes themselves, many of which will be useful as monitoring points during construction and operation of the proposed developments. The methods to be employed to achieve these outcomes will entail: a hydrocensus including the existing boreholes on site, as well as any known

boreholes on neighbouring properties, to determine groundwater quality and aquifer yield if known

drilling of 10 deeper (<30m) and 8 shallower (<10m) boreholes - these will be fitted with concrete pedestals and lockable steel caps to protect against contamination from surface activities, for future shallow ground water monitoring; surface casing


will be constructed into the concrete pedestals to allow for accurate measurement of water levels

purging, sampling and chemical analysis of groundwater taken from the various boreholes

survey of borehole elevations to allow construction of groundwater contours from water level data.

The siting of boreholes for the Geohydrological Assessment will be informed by the Geotechnical Assessment, both the test pits and the geophysical survey. 9.1.6 HYDROLOGICAL ASSESSMENT A basic assessment of the climate of the site will be conducted. This will be melded with the geohydrological assessment to inform major design and location considerations with respect to runoff, drainage, prevention of surface water contamination and emplacement of surface water management structures. The following will comprise the elements of this assessment: analysis of climate and weather data to understand likely rainfall events analysis of terrain to determine stormwater and runoff behaviour, including any

stream gauging stations that may be in the area recommendations and requirements for surface water management.

9.1.7 SOIL ASSESSMENT Further to the geotechnical assessment, a soil assessment may be undertaken. Soil will be analysed for purposes of detecting any contamination that may be present and to provide baseline site data prior to the establishment of the chrome chemicals plant. The methods used for this assessment will be: samples will be taken during the drilling at each borehole location - care will be

taken to avoid cross-contamination between the soil sampling sites a selection of representative soil samples will be analysed for major and trace

element geochemistry - selection may be informed by the geohydrological and geotechnical assessments.

9.1.8 OCCUPATIONAL HEALTH & SAFETY A Major Hazardous Installation is defined in terms of the Occupational Health and Safety Act as where any substance is produced, used, handled or stored in such a form and quantity that it has the potential to cause a major incident. A major incident is in turn defined as an occurrence of catastrophic proportions, resulting from the use of plant or machinery, or from activities at a workplace. It is impossible to put a specific value to “catastrophic” because it will always differ from person to person and from place to place. However, when the outcome of a risk assessment indicates that there is a possibility that the public will be involved in an incident, then the incident can be seen as catastrophic (Department of Labour 2005). None of the substances listed in Schedule A of the General Machinery Regulations will be used or stored in quantities exceeding the thresholds stated therein. The majority of the plant is not foreseen as having the potential to cause a ‘major incident’.


In view of these potential risks a desktop Major Hazardous Installation risk assessment will be conducted, this will inform the detailed design for the plant as well any obligations on the part of Lanxess CISA in terms of the Major Hazardous Installation regulations.

9.2 CONSULTATION WITH THE COMPETENT AUTHORITY Table 9-1: Consultation with the competent authority

Lodge application and declaration of interest Application Application Receive confirmation of application Lodge Scoping Report (Including Plan of Study for EIA) Consideration of Scoping Report/PoS for Environmental Impact Assessment

Scoping

Receive confirmation of acceptance of Scoping Report/PoS for Environmental Impact Assessment Lodge Environmental Impact Assessment Report5 Receive confirmation of acceptance EIR

EIR

Decision on application

9.3 IMPACT ASSESSMENT METHODOLOGY The following methodology to be followed for the assessment of impacts is detailed in Appendix 1. The methodology takes in account the following key components Determinants Of Impact Significance: Geographical Extent Temporal Duration Intensity Probability of occurrence

Impact Mitigation/Optimisation Assigning Impact Significance Impact Prioritisation

9.4 PUBLIC PARTICIPATION PROCESS The scoping phase included the following public participation components: Identification and registration of I&AP’s on a database using Newspapers advertisements On site notices Personal invitations to pre-identified persons and organisations Disseminating information and noting comments through Distribution of a background information document Public meeting Focus group meeting

The proposed public participation process for the remainder of the Environmental Impact Assessment will consist of: Presenting registered Interested and Affected Parties and stakeholders with the

opportunity to read and comment on environmental impact assessment report including specialist reports


Presenting registered Interested and Affected Parties and stakeholders with the opportunity to read and comment on draft environmental management plans compiled in terms of regulation

A public meeting to present and discuss the findings of the Environmental Impact Assessment and related specialist reports

Presenting registered Interested and Affected Parties and stakeholders with the opportunity to read and comment on the final reports submitted to MDALA.


10. REFERENCES CITED ATSDR 2000 Public Health Statement for Chromium, Agency for Toxic Substances and

Disease Registry United States Public Health Service, September 2000, CERC 2004 Cambridge Environmental Research Consultants, ADMS User Guide

Version 3.2, July 2004. CSIR 1997 CSiR (1 997). Environmental Impact Report for the Proposed Chrome

Chemicals Plant at the Karbochem Site, Newcastle. Report to Chrome International South Africa. CSIR, Pretoria. Report number ENVIPIC 9722 1.

DEAT 2007 State of the Environment, Atmospheric pollution, November 2007.

http://soer.deat.gov.za/themes.aspx?m=496 DWAF 1998 Minimum Requirements for Classification, Handling and Disposal of

Hazardous Waste, 2nd edition, Department of Water Affairs and Forestry, South Africa.

Department of Labour 2005 Explanatory Notes on the Major Hazard Installation

Regulations by Chief Directorate of Occupational Health and Safety in the Department of Labour. April 2005.

EPA 2006 California Environmental Protection Agency Air Resources Board

SOPMLDO39 Standard Operating Procedure For The Analysis Of Hexavalent Chromium At Ambient Atmospheric Levels By Ion Chromatography.

EPA 1990 Report to Congress on Special Wastes From Mineral Processing, July 1990,

EPA/OSWER – 66904. Chapter 4: Sodium Dichromate production. http://www.epa.gov/epaoswer/other/mineral/chapter4.pdf

EPA CLAPUFF Technology Transfer Network Support Center for Regulatory Atmospheric

Modeling, US Environmental Protection Agency, http://www.epa.gov/scram001/dispersion_prefrec.htm

ECE 1997 Environmental Contaminants Encyclopedia Chromium Vi (Hexavalent

Chromium) Entry, July 1997. KZN 2004 DAE report on agricultural development 2004,

http://agriculture.kzntl.gov.za/dae/index.aspx?ID=4 Wiki 2008 CALPUFF Wikipedia, http://en.wikipedia.org/wiki/CALPUFF


11. APPENDIX 1: IMPACT ASSESSMENT METHOD The following method is proposed to determine the significance of environmental impacts caused by the proposed project.

11.1 DETERMINANTS OF IMPACT SIGNIFICANCE The following criteria will be used to determine the significance of an impact. The scores associated with each of the levels within each criterion are indicated in brackets after each description [like this]. 11.1.1 NATURE Nature (N) considers whether the impact is: positive [- ¼ ] negative [+1].

11.1.2 EXTENT Extent (E) considers whether the impact will occur: on site [1] locally: within the vicinity of the site (a few kilometres) [2] regionally: within the local municipality (Newcastle) [3] provincially: across the province (KwaZulu-Natal) [4] nationally or internationally [5].

11.1.3 DURATION Duration (D) considers whether the impact will be: very short term: a matter of days or less [1] short term: a matter of weeks to months [2] medium term: up to a year or two [3] long term: up to 10 years [4] very long term: 10 years or longer [5].

11.1.4 INTENSITY Intensity (I) considers whether the impact will be: negligible: there is an impact on the environment, but it is negligible, having no

discernable effect [1] minor: the impact alters the environment in such a way that the natural processes

or functions are hardly affected; the system does however, become more sensitive to other impacts [2]

moderate: the environment is altered, but function and process continue, albeit in a modified way; the system is stressed but manages to continue, although not with the same strength as before [3]

major: the disturbance to the environment is enough to disrupt functions or processes, resulting in reduced diversity; the system has been damaged and is no longer what it used to be, but there are still remaining functions; the system will probably decline further without positive intervention [4]


severe: the disturbance to the environment destroys certain aspects and damages all others; the system is totally out of balance and will collapse without major intervention or rehabilitation [5].

11.1.5 PROBABILITY Probability (P) considers whether the impact will be: unlikely: the possibility of the impact occurring is very low, due either to the

circumstances, design or experience [1] likely: there is a possibility that the impact will occur, to the extent that provisions

must be made for it [2] very likely: the impact will probably occur, but it is not certain [3] definite: the impact will occur regardless of any prevention plans, and only

mitigation can be used to manage the impact [4]. 11.1.6 MITIGATION OR ENHANCEMENT Mitigation (M) is about eliminating, minimising or compensating for negative impacts, whereas enhancement (H) magnifies project benefits. This factor considers whether: a negative impact can be mitigated:

unmitigated: no mitigation is possible or planned [1] slightly mitigated: a small reduction in the impact is likely [2] moderately mitigated: the impact can be substantially mitigated, but the

residual impact is still noticeable or significant (relative to the original impact) [3] well mitigated: the impact can be mostly mitigated and the residual impact is

negligible or minor [4] a positive impact can be enhanced:

unenhanced: no enhancement is possible or planned [1] slightly enhanced: a small enhancement in the benefit is possible [2] moderately enhanced: a noticeable enhancement is possible, which will

increase the quantity or quality of the benefit in a significant way [3] well enhanced: the benefit can be substantially enhanced to reach a far

greater number of receptors or recipients and/or be of a much higher quality than the original benefit [4].

11.1.7 REVERSIBILITY Reversibility (R) considers whether an impact is: irreversible: no amount of time or money will allow the impact to be substantially

reversed [1] slightly reversible: the impact is not easy to reverse and will require much effort,

taken immediately after the impact, and even then, the final result will not match the original environment prior to the impact [2]

moderately reversible: much of the impact can be reversed, but action will have to be taken within a certain time and the amount of effort will be significant in order to achieve a fair degree of rehabilitation [3]

mostly reversible: the impact can mostly be reversed, although if the duration of the impact is too long, it may make the rehabilitation less successful, but otherwise a satisfactory degree of rehabilitation can generally be achieved quite easily [4].


11.2 CALCULATING IMPACT SIGNIFICANCE The table below summarises the scoring for all the criteria. Table 11-1: Scoring for Significance Criteria CRITERION SCORES - ¼ 1 2 3 4 5 N-nature positive negative - - - - E-extent - site local regional provincial national D-duration - very short short moderate long very long I-intensity - negligible minor moderate major severe P-probability - very unlikely unlikely likely very likely - M-mitigation - none slight moderate good - H-enhancement - none slight moderate good - R-reversibility - none slight moderate good - Impact significance is a net result of all the above criteria. The formula proposed to calculate impact significance (S) is, for a negative impact: S = N x (E+D) x I x P ÷ ½(M+R) and for a positive impact: S = N x (E+D) x I x P x (H). Negative impacts score from 2 to 200. Positive impacts score from – ½ to -200.

11.3 UNDERSTANDING IMPACT SIGNIFICANCE The following is a guide to interpreting the final scores of an impact (for negative impacts): Table 11-2: Final Significance Scoring final score (S) impact significance 0 – 10 negligible the impact should cause no real damage to the environment,

except where it has the opportunity to contribute to cumulative impacts

10 – 20 minor the impact will be noticeable but should be localized or occur over a limited time period and not cause permanent or unacceptable changes; it should be addressed in an EMP and managed appropriately

20 – 50 moderate the impact is significant and will affect the integrity of the environment; effort must be made to mitigate and reverse this impact; in addition the project benefits must be shown to outweigh the impact

50 – 100 major the impact will affect the environment to such an extent that permanent damage is likely and recovery will be slow and difficult; the impact is unacceptable without real mitigation or reversal plans; project benefits must be proven to be very substantial; the approval of the project will be in jeopardy if this impact cannot be addressed


100 – 200 severe the impact will result in large, permanent and severe impacts, such as local species extinctions, minor human migrations or local economic collapses; even projects with major benefits may not go ahead with this level of impact; project alternatives that are substantially different should be looked at, otherwise the project should not be approved

Two examples will help illustrate this system. SCENARIO 1 – An industrial facility proposes discharging effluent containing a high salt content into a nearby stream. These salts will cause temporary problems for the ecosystem, but are washed downstream, diluted and will have no long term effects. The short term damage to the stream can be reversed fairly easily, but only if the ecosystem has not been seriously damaged by the salts over a long time. A mitigation measure is also proposed whereby during low flow periods (dry season) a pulse of clean water is discharged into the stream after the saline effluent, diluting the salts and pushing them downstream faster, so that the salts become so dilute as to have little or no effect. From this scenario, the criteria are: nature = negative = 1 extent = local = 2 duration = medium = 3 intensity = moderate = 3 probability = very likely = 4 mitigation = moderate = 3 reversibility = moderate = 3, and therefore impact significance is: S = N x (E+D) x I x P ÷ ½(M+R) = 1 x (2+3) x 3 x 4 ÷ ½(3+3) = 60 ÷ 3 = 20. Note that the impact prior to mitigation is major, but that due to the mitigation and the fact that the ecosystem can recover easily from the effects of salt (high reversibility), the residual impact becomes minor/moderate. SCENARIO 2 – The above scenario applies, except that the effluent contains metals. These metals become adsorbed onto clay and organic matter in the stream bed and are accumulative toxins within the ecosystem, getting into the food chain and concentrating upwards into predator species. Fresh water flushing will only very slightly mitigate this and ecosystem recovery will not be easy or fast. From this scenario, the criteria are: nature = negative = 1 extent = local = 2 duration = very long = 5 intensity = moderate = 3 probability = very likely = 4


mitigation = slight = 2 reversibility = slight = 2, and therefore impact significance is: S = N x (E+D) x I x P ÷ ½(M+R) = 1 x (2+5) x 3 x 4 ÷ ½(2+2) = 84 ÷ 2 = 42. Note that in this case, the original impact (of the metals) is more serious than the salt, but it is the limited mitigation and reversibility that also act on the residual score and result in this score being moderate.

11.4 ASSIGNING IMPACT PRIORITY The priority for the management of an impact is the product of impact significance and existence of applicable legislation. Thus even insignificant impacts become high priorities if applicable legislation exists.


12. APPENDIX 2: PUBLIC PARTICIPATION 12.1 INTRODUCTION Public participation provides the opportunity for I&AP’s to participate on an informed basis, and to ensure that their needs and concerns are considered during the impact assessment process. In so doing, a sense of ownership of the project is vested in both the project proponent and interested or affected parties. The Public Participation Process is aimed at achieving the following:

o Provide a “vehicle” for input from I&AP’s and;

o Facilitate the consideration and integration of I&AP input to the development;

o Minimise negative impacts and optimise positive impacts; and

o Provide a proactive indication of issues which may inhibit project progress resulting in delays, or which may result in enhanced and shared benefits.

This section provides an account of the PPP conducted including: 1. A description of the PPP conducted thus far; 2. A list of issues raised to date

12.2 IDENTIFICATION OF I&APS Potential I&APs were identified through the following means:

1. Newspaper advertisement – an advertisement was placed in the local newspaper The Newcastle Advertiser (refer to Figure 12-1: Contents of Advert)

2. Site notices were erected at major entrances to the plant (refer to Figure 12-2) 3. Correspondence with government departments with jurisdiction related to the

proposed development (e.g. DEAT, DWAF, Newcastle Local Municipality) 4. Correspondence with the ward councillor for the area

Refer to Table 12-1: List of I&APs for details of I&APs.


Figure 12-1: Contents of Advertisement in The Newcastle Advertiser


Figure 12-2: Site Notice Entrance Gate


Table 12-1: List of I&APs Name Surname Organisation Tel Fax Cel Email Greg Scott DEAT 012 310 3084 083 781 0900 [email protected] Asith Brijball DWAF Julius Van Rooyen Newcastle Local Municipality 034 328 7732 034 328 7732 083 630 3556 [email protected] Geoff Muller Mittal Steel SA 034 3148187 034 3148285 083 309 0327 VLM Masina Ward Councillor 034 328 7737 034 312 1570 082 255 7888 PB Mthimkhulu DWAF 034 212 1158 034 218 1024 082 9085764 [email protected] George Thom Karbochem 034 3701 114 082 807 8887 [email protected] Hanalie Hettlie Uthukela Water 034 328 5105 082 3311 899 [email protected]

Stephen Hamilton Uthukela Water 034 312 9986 082 417 3004 Stephen.Hamilton@ uthukelawater.co.za

A Blair Uthukela Water 034 328 5000 034 328 5096 Shamitha Lalthaparsadh SA Calcium Carbide (Pty) Ltd 034 3701 272 034 3701 164 [email protected] S Maharaj Uthukela Water 034 3701 272 034 3701 164 082 466 1187 Sipho Mntambo Arcellor Mittal 034 314 8228 [email protected] Hendrik Terblanche Private 034 3701265 084 511 4041 [email protected] Leon Van Den Heever Civil Aviation Authority 011 545 1139 011 545 1451 [email protected] Umesh Lalthaparsadh 034 318 2021 082 336 1435 [email protected] Pat Le Cordier Karbochem 034 3701 900 083 657 1252 [email protected] Tony Stalberg SA Calcium Carbide (Pty) Ltd 034 370 1101 083 635 1932 [email protected] Sibu Sibisi 034 312 6081 034 318 1415 [email protected] Rico Euripido Groundwork [email protected] Municipal Manager Newcastle Municipality 034 328 7600 [email protected] Sikhali Mathenjwa KZN DAEA 034 319 3986 034 319 3986 082 926 1799 Siboniso Mbense KZN DAEA 035 5500 210 035 5500 218 082 331 9764 [email protected] Poovi Moodley KZN DAEA 034 315 3936 034 312 9986 084 803 3918 Ntuthuko Makhubu KZN DAEA 034 315 3936 034 312 9986 072 0804 699 Nhlaka Hlongwane KZN DAEA 034 315 3936 034 312 9986 072 7200 200 Thabile Nzimande KZN DAEA 034 315 3936 034 312 9986 082 797 0049 Qondiswa Mwandla KZN DAEA 035 792 1624 035 792 1620 078 024 7255 [email protected] Bonga B Sithole KZN DAEA 035 874 3396 035 874 3301 082 466 8032 [email protected] David Maritz KZN DAEA 034 299 9672 034 299 9674 083 305 4394 [email protected] Sengalela Mgaga KZN DAEA 034 315 3936 034 312 9986 073 549 3281


12.3 PUBLIC MEETING A public meeting was held introduce the proposed development to I&AP’s, impart information on the Scoping & EIA process, and obtain comments. I&AP’s were sent personal invites, and invitation to the public was issued through an advertisement in the Newcastle Advertiser (refer to Figure 12-1). A copy of the presentation and attendance register can be available upon request. Very few comments were raised at the public meeting. A summary of the meeting follows:


Title: Minutes of First Public Meeting Project: Lanxess CISA (Pty) Ltd proposed expansion Date: 10 April 2008 Time: 18:00h Venue: Arbor Park Recreational Centre , Newcastle, KZN Table 12-2: Public Meeting Attendance Register Name Email Tel Fax Cell Organization Hennie Terblanche [email protected] 034 3701265 0866 358 157 084 511 4041 Pieter Bouwer [email protected] 034 3701 629 034 315 1352 083 678 7903 Lanxess CISA Umesh Lalthaparsadh [email protected] 034 318 2021 082 336 1435 Pat Le Cordier [email protected] 034 3701 900 083 657 1252 Karbochem Shamitha Lalthaparsadh [email protected] 034 3701 272 034 3701 164 SA Calcium Carbide (Pty) Ltd Margarete Meyer [email protected] 011 921 5243 011 521 5124 082 651 9107 Lanxess CISA George Thom [email protected] 034 370 1416 082 807 8887 Karbochem Jacque Hunlun [email protected] 034 370 1641 034 370 1643 083 633 1391 Lanxess CISA Sibu Sibisi [email protected] 034 312 6081 034 318 1415 Malcolm Dawkins [email protected] 011 245 1000 011 248 1200 083 3888 267 SamancorCr Chris Labuschagne [email protected] 034 370 1610 082 807 8886 Lanxess CISA Michael Batz [email protected] 034 370 1442 083 633 8386 Lanxess CISA Dawie Van Der Merwe [email protected] 034 370 1607 034 315 1352 082 809 9512 Lanxess CISA Abdul Ebrahim [email protected] 011 728 2683 0866 106 703 072 268 1119 Environmental Science Associates Theo Fischer [email protected] 011 728 2683 0866 106 703 082 336 2729 Environmental Science Associates Tony Stalberg [email protected] 034 370 1101 083 635 1932 SA Calcium Carbide (Pty) Ltd

Proceedings An introductory presentation was given by Michael Batz. A presentation on the EIA process and the proposed development was given by Theo Fischer Questions, responses and comments were minuted by Abdul Ebrahim.


Register of Comments and Responses Table 12-3: Public Meeting Register of Comments and Responses Name Question/Comment Response Name George Thom

Will the expansion require new tailings dams Will H:h dams be required?

Yes, the new facility will be similar to the existing facility which is permitted in terms of current legislation.

Chris Labuschagne

Tony Stalberg

CO2 is a by product but its not contained in the presentation.

Yes it is a by-product, it is more of concern as a greenhouse gas than as a priority pollutant.

Theo Fischer


12.4 AUTHORITIES MEETING A meeting was arranged to present the proposed development and impart information on the anticipated Scoping & EIA process to officials from the KZN DAEA, the Newcastle Municipality and DWAF. Issues discussed are summarised in the ensuing sections:


Title: Minutes of First Authorities Meeting Project: Lanxess CISA (Pty) Ltd proposed expansion Date: 10 April 2008 Time: 10:00h Venue: Newcastle Club, Scott street, Newcastle, KZN Table 12-4: Authorities Meeting Attendance Register Name Email Tel Fax Cell Organization Malcolm Dawkins [email protected] 011 245 1000 011 248 1200 083 3888 267 SamancorCr Sikhali Mathenjwa 034 319 3986 034 319 3986 082 926 1799 KZNDAEA Siboniso Mbense [email protected] 035 5500 210 035 5500 218 082 331 9764 KZNDAEA Poovi Moodley 034 315 3936 034 312 9986 084 803 3918 KZNDAEA Ntuthuko Makhubu 034 315 3936 034 312 9986 072 0804 699 KZNDAEA Nhlaka Hlongwane 034 315 3936 034 312 9986 072 7200 200 KZNDAEA Thabile Nzimande 034315 3936 034 312 9986 082 797 0049 KZNDAEA Qondiswa Mwandla [email protected] 035 792 1624 035 792 1620 078 024 7255 KZNDAEA Jacque Hunlun [email protected] 034 370 1641 034 370 1643 083 633 1391 Lanxess CISA Zama Mathenjwa [email protected] 034 315 3936 034 312 9986 082 822 2496 KZNDAEA Julius Van Rooyen 034 328 7732 034 328 7732 083 630 3556 Newcastle Municipality Bonga B Sithole [email protected] 035 874 3396 035 874 3301 082 466 8032 KZNDAEA David Maritz [email protected] 034 299 9672 034 299 9674 083 305 4394 KZNDAEA Sengalela Mgaga 034 315 3936 034 312 9986 073 549 3281 KZNDAEA Chris Labuschagne [email protected] 034 370 1610 082 807 8886 Lanxess CISA Michael Batz [email protected] 034 370 1442 083 633 8386 Lanxess CISA Dawie Van Der Merwe [email protected] 034 370 1607 034 315 1352 082 809 9512 Lanxess CISA Abdul Ebrahim [email protected] 011 728 2683 0866 106 703 072 268 1119 Environmental Science Associates Theo Fischer [email protected] 011 728 2683 0866 106 703 082 336 2729 Environmental Science Associates

Proceedings An introductory presentation was given by Michael Batz. A presentation on the EIA process and the proposed development was given by Theo Fischer


Questions, responses and comments were minuted by Abdul Ebrahim. Register of Comments and Responses Table 12-5: Authorities Meeting Register of Comments and Responses Name Question/Comment Response Name Zama Mathenjwa

Are there any relevant air quality monitoring stations, if so where?

There are 4 air quality monitoring stations owned and operated by the CSIR at the following locations:

o Aborpark School o Newcastle Airport o Keyway Motors filling station o Karbochem Effluent Plant

These have been in operation since July 1998

Jacque Hunlun

Zama Mathenjwa

Is the Newcastle Municipality station operational?

The station has been in operation intermeittently for the past year approximately as there have been some difficulties with the monitoring station.

Julius Van Rooyen

Poovi Moodley

Why is it concluded that emissions of SO2 will not be of concern?

The plant will be fired by sasol gas which does not have any appreciable amounts of SO2.

Theo Fischer

Sengalela Mgaga

How often does Lanxess get monitoring reports from the CSIR?

Air is sampled over a 3 week period, the samples are analysed by the CSIR. CSIR submits a report every 4 months, and also a consolidated annual report.

Jacque Hunlun

Sengalela Mgaga

Does Lanxess have an environmental discussion forum where CSIR results from the monitoring stations are discusse?

Lanxess is certified in terms of the ISO14001 environmental management system, and has periodic management meetings to discuss environmental performance and the environmental management system as per the requirements of the standard. These are internal meetings, there is no external forum.

Jacque Hunlun


Table 12-5: Authorities Meeting Register of Comments and Responses Name Question/Comment Response Name Julius Van Rooyen

If there is insufficient sasol gas will Lanxess use coal instead?

No, the process is not designed to use coal and is sensitive to the level of sulphur contained in coal.

Chris Labuschagne & Dawie Van Der Merwe

Zama Mathenjwa

Will there be sufficient gas supply?

Yes, the existing facilities and infrastructure were designed with adequate supply capability. Sasol gas supply may be adequate, but this will need to be confirmed.

Chris Labuschagne

Poovi Moodley

Are there any fugitive SO2 emissions from the facility?

Emissions from process which use SO2 are scrubbed, and have an SO2 analyser for exhaust gases which is interlocked to the process. The process will shut down if a pre-determined level is exceeded.

Dawie Van Der Merwe

Poovi Moodley

Will the current SO2 abatement system be adequate for the proposed plant?

The planned expansion will require a corresponding new abatement system.

Dawie Van Der Merwe

Poovi Moodley

Is there dust from conveyors and raw material transfer?

The ore is wet and thus not prone to dust emission. Also the ore contains trivalent chromium not hexavalent chromium.

Malcolm Dawkins

Yes, the stack from electrostatic precipitator is monitored.

Theo Fischer

All stacks with potential for dust generation are monitored annually.

Dawie Van Der Merwe

Sengalela Mgaga

Is dust emission monitored?

Personal and static ambient exposure monitoring undertaken as well.

Jacque Hunlun.


Table 12-5: Authorities Meeting Register of Comments and Responses Name Question/Comment Response Name

Hexavalent Chromium, Total Chromium and Total Suspended Particulate.

Jacque Hunlun.

Sengalela Mgaga

What is monitored at the air quality monitoring stations?

The Newcastle station monitors gases NO2, SO2, Ozone.

Theo Fischer.

Siboniso Mbense

How is existing waste being disposed of?

Residue is being disposed of sub-aquaeously (slurried in a reducing solution) in a permitted mono disposal facility owned and operated by Lanxess CISA. The new facility will be designed along the same principles.

Chris Labuschagne

Siboniso Mbense

Is it not feasible to use the existing mono disposal facility?

Plant capacity is being increased, so disposal facility capacity must be increased accordingly.

Chris Labuschagne.

Also the waste is treated and reduced with ferrous chloride; this diminishes the potential reuse of the process residue, so alternatives will be researched. Unfortunately the iron content is of the residues is not sufficient to use it as a substitute for iron ore.

Theo Fischer

Poovi Moodley

How does new plant tie into vanadium recovery plant?

The new facility will be largely the same as existing one. But synergies will be considered where possible to optimise resources, however capacity constraints must be considered.

Chris Labuschagne

Qondiswa Mwandla

How does local community benefits from Lanxess?

Lanxess has a record of support to schools, donations to charity and also providing training and skills development.

Michael Batz


Table 12-5: Authorities Meeting Register of Comments and Responses Name Question/Comment Response Name

The EIA will identify applicable environmental legislation. The EIA will inform applications for APPA registration certificate or Atmospheric Emission Licence, waste disposal permit, Major Hazardous Installation registration, water use licences, and dam safety risk registration for the waste lagoon.

Theo Fischer. and Jacque Hunlun

Sengalela Mgaga

How will permitting be undertaken.

Authorities with jurisdiction will be engaged as stakeholder to inform permitting requirements.

Abdul Ebrahim

Zama Mathenjwa

What are the existing water requirements?

Average consumption is +/-1100 m3 /d this is used mainly for steam, process water, cooling water make up, and potable water use. The maximum water use is about 1600 m3 /d. Lanxess is permitted to use a maximum of 2583 m3/d

Jacque Hunlun

Julius Van Rooyen

Is there any existing borehole water use by Lanxess?

Lanxess only has environmental monitoring boreholes.

Jacque Hunlun

Siboniso Mbense

Is water stored anywhere before it is used in the process?

Water is extracted directly from the supply pipeline into the process. There is some buffer water storage on site especially for process water as it is passed from one process to another.

Dawie Van Der Merwe

The current facility is a zero-effluent plant with the exception of sewage. The EIA and design will determine if there will be any facility effluent, but is expected that the proposed facility will be very similar to the existing one.

Chris Labuschagne

Siboniso Mbense

Will any effluent to be discharged from the proposed development?

It is easier and cheaper to reuse chromium contaminated water than to treat and discharge it.

Dawie Van Der Merwe


Table 12-5: Authorities Meeting Register of Comments and Responses Name Question/Comment Response Name Zama Mathenjwa

Will the EIA focus on current products or will downstream products be part of this EIA as well.

The manufacture of downstream products within the laxness group is decided strategically. Lanxess CISA will consider exactly which products will be produced at this site.

Chris Labuschagne

Zama Mathenjwa

How will cumulative impacts be addressed

Impacts for proposed plant will modelled/predicted and will be superimposed on existing impacts for example modelled air emissions will be added to baseline concentrations.

Theo Fischer

Skilled resources are in some instances difficult to find. Lanxess has thus developed an internal skills development programme.

Michael Batz

Siboniso Mbense

With respect to employment, are there difficulties with sourcing skilled personnel from local community?

This is one of very few chemical industries in the area hence the required skills are not typically found. It has been Lanxess CISA’s experience that people responding to vacancies are often from the area although they may be located elsewhere at the time.

Chris Labuschagne

Siboniso Mbense

Comment- it is important to clarify that the jobs to be created will not be entirely 100% for local community, but depends on skills availability.

Zama Mathenjwa

Comment - It’s important to know if there are a lot of skills coming in because this may imply that there may be a significant social impact. A social Impact Assessment may be required.


Table 12-5: Authorities Meeting Register of Comments and Responses Name Question/Comment Response Name Thabile Nzimande

Does Lanxess have internal education programmes to educate employees of the importance of environmental compliance?

All new employees go through environment, health, and safety induction and are subsequently tested.

Jacque Hunlun.

Sikhali Mathenjwa

Will there be any negative impacts in terms of the spatial development framework?

Environmental Science Associates will consider the SDF, and the proposed development will be discussed with the municipality.

Theo Fischer

Municipal IDPs typically addresses community needs. This is a unique project hence it is unlikely to be in the IDP.

Theo Fischer.

Sikhali Mathenjwa

Bulk services requirements must be budgeted for in the municipalities IDP for electricity, water, sewage, has this expansion been budgeted for by the municipality?

The IDP is based on community serve provision needs.

Julius Van Rooyen

Siboniso Mbense

Where will the proposed site be with respect to existing site.

Indicated on aerial photograph where the proposed site alternatives are.

Chris Labuschagne

Sengalela Mgaga

What tonnages of general waste are produced at present, and what is projected.

About 10m3/mth domestic waste and 33m3/mth hazardous waste. The hazardous waste is disposed of at Holfontein. It is anticipated that these volumes will double.

Jacque Hunlun.

Sengalela Mgaga

Expressed concern that Newcastle landfill is close to closure and municipality will need to plan for increased waste disposal needs.

10m3/mth is a very small quantity, and is comparable to the monthly waste generation by some households.

Theo Fischer

Sengalela Mgaga

Are there plans to reduce waste disposal

All empty drums, scrap metal,plastic and cardboard are recycled.

Jacque Hunlun


12.5 COMMENTS FROM I&AP’S No comments from I&AP’s had been received at the time of submission of the Scoping report. No comments were received during the public meeting either. Should any comments be received before the approval of the scoping report, these will be forwarded to the Competent Authority.


13. APPENDIX 3: DETERMINATION OF HEXAVALENT CHROMIUM IN AMBIENT AIR


TABLE OF CONTENTS

13.1 INTRODUCTION ...........................................................................................................................79 13.2 SUMMARY OF METHOD ..............................................................................................................79 13.3 INTERFERENCES AND LIMITATIONS............................................................................................79 13.4 INSTRUMENT AND EQUIPMENT...................................................................................................79 13.5 MATERIALS AND CHEMICALS.....................................................................................................80 13.6 PREPARATION OF ELUENT ..........................................................................................................81 13.7 PREPARATION OF POST-COLUMN REAGENT...............................................................................81 13.8 PREPARATION OF HEXAVALENT CHROMIUM STANDARDS AND CONTROLS ..............................82 13.9 PREPARATION OF SODIUM BICARBONATE IMPREGNATING SOLUTION ......................................82 13.10 PREPARATION OF HEXAVALENT CHROMIUM FILTERS ...........................................................82 13.11 FILTER LOG-IN........................................................................................................................83 13.12 FILTER ANALYSIS ...................................................................................................................83 13.13 QUALITY CONTROL ................................................................................................................84 13.14 REFERENCES ...........................................................................................................................85


SOP MLD 039 STANDARD OPERATING PROCEDURE FOR THE ANALYSIS OF HEXAVALENT CHROMIUM AT

AMBIENT ATMOSPHERIC LEVELS BY ION CHROMATOGRAPHY

13.1 INTRODUCTION The California Air Resources Board identified hexavalent chromium (Cr6) as a toxic air contaminant in January 1986. Chromium is a natural constituent of the earth’s crust and present in several oxidation states. Trivalent chromium (Cr3) is naturally occurring, environmentally pervasive and a trace element in man and animals. Hexavalent chromium is anthropogenic from a number of commercial and industrial sources. It readily penetrates biological membranes and has been identified as an industrial toxic and cancer causing substance. Hexavalent chromium is a known inhalation irritant and associated with respiratory cancer. Exposure is primarily associated with the chrome plating and anodizing process, and emissions from chromate treated cooling towers. Hexavalent chromium has been measured in ambient air at sites located throughout California. Cellulose filters are exposed to ambient air using a Xontech 920 toxic air sampler. Samples are taken every twelve days, year round. To achieve lower detection limits, in certain cases the exposed filters may be composited from the same site and analyzed as a group. The analysis procedure for hexavalent chromium from exposed 37mm cellulose filters is described in this document.

13.2 SUMMARY OF METHOD Method MLDO39 determines Cr6 from bicarbonate impregnated ashless cellulose filters exposed to ambient air, which are submitted to the laboratory by site operators. The filters are extracted in deionized water via sonication for three hours. The extract is analyzed by ion chromatography using a system comprised of a guard column, analytical column, a post-column derivatization module, and a UV-Vis detector. In the analysis procedure, Cr6 exists as chromate due to the near neutral pH of the eluent. After separation through the column, hexavalent chromium forms a complex with the diphenylcarbohydrazide (DPC) which is detected at 520 nm. The peak analysis is determined using Dionex Peaknet chromatography software, version 5.1.

13.3 INTERFERENCES AND LIMITATIONS 13.3.1 Sodium carbonate used as the stabilizing media in Cr6 filters was observed to cause interferences with the analysis. 13.3.2 Higher concentrations of the sodium bicarbonate impregnating solution may cause flow restrictions during ambient air sampling. The use of smaller pore size impregnated filter has shown to cause definite restrictions during sampling.

13.4 INSTRUMENT AND EQUIPMENT This SOP assumes familiarity with the installation and operation of the Dionex ion chromatographic system. For detailed instructions in the operation of the Dionex ion


chromatograph (IC), refer to the Dionex operations manual. 4.1 The Dionex Ion Chromatographic System is comprised of modular units purchased from the Dionex Corporation:

1. Dionex gradient pump; 2. Reagent delivery module; 3. Variable wavelength detector; 4. Automated sampler, which is controlled directly from the PeakNet workstation.

4.2 IC Operating conditions:

13.5 MATERIALS AND CHEMICALS 13.5.1 Materials:

1. 37mm diameter cellulose filters 2. Black filter ring holders 3. Plastic petri dishes, large enough to hold a 37mm filter 4. Circular labels specifying the Cr6 program 5. Volumetric flasks: 1 L and 2L sizes 6. Wide-mouth polyethylene storage bottles: 500mL and 1 L sizes 7. Analytical balance 8. Pipettor with disposable pipet tips: 1 OOpt and 2.5 mL pipettors 9. Teflon centrifuge tubes with caps 10. Ultrasonicator 11. Hot plate/stir plate 12. Large glass petri dish 13. High purity helium 14. Repipettor 25 Ml

13.5.3 Chemicals: All chemicals are at least spectrophotometric grade.

1. Pyridine 2,6-Dicarboxylic Acid (PDCA) 2. Disodium hydrogen phosphate heptahydrate (Na2HPO4-7H20) 3. Sodium Iodide (Nal) 4. Ammonium Acetate (CH3CO2NH4)

Sample loop volume 4OOL

Analytical column Dionex, Ion Pac C55 Guard column Dionex, Ion Pac CG5

Eluent solution

2mM Pyridinedicarboxlic acid (PDCA) 2mM Disodium hydrogen phosphate heptahydrate 10mM Sodium iodide 50mM Ammonium acetate 2.8mM Lithium hydroxide monohydrate

Eluent flow rate 1.0 mL/min

Post-column reagent 2mM Diphenylcarbohydrazide (DPC) 10% Methanol 0.9N Sulfuric acid

Post-column flow rate 0.5 mL/min Mixing device Reaction coil Detector wavelength 520nm Acquisition Software Dionex Peaknet, version 5.1


5. Lithium hydroxide monohydrate (LiOH) 6. 1 ,5-diphenylcarbohydrazide (DPC) 7. Methanol (CH3OH) 8. Sulfuric acid (H2504) 9. Sodium bicarbonate (NaHCO3) 10. Nanopure ASTM Type 1 deionized water (>16 MO-cm)

15.5.3 Hexavalent chromium stocks are National Institute of Science and Technology (N 1ST) certified. Two stocks solutions are purchased, one for making working standards, the other for making a working control. The two solutions are of different sources, whether they are from different lot numbers or different companies.

13.6 PREPARATION OF ELUENT 13.6.1 Stock eluent is prepared in nanopure water. The following list describes the concentrations of each chemical when making a 1 liter solution of eluent stock: Chemicals Concentrations

PDCA 20mM (3.34g/L)

Disodium hydrogen phosphate heptahydrate 20mM (5.36g/L)

Sodium Iodide 100mM (15.Og/L)

Am mon ium Acetate 500mM (38. 5g/L)

Lithium hydroxide monohydrate 28.0mM (1.lOgL)

Heat approximately 700mL nanopure deionized water in a 1 L volumetric flask on a hot plate/stir plate. Do not boil water. Add the PDCA and let dissolve before adding the remaining chemicals. The PDCA is slow to dissolve. When the PDCA has dissolved add the remaining chemicals to the flask. Once all chemicals have dissolved, turn off the heat and let the flask cool. Bring to volume with nanopure and transfer eluent stock to a 1 L wide-mouth polyethylene storage bottle. 13.6.2 The working eluent is prepared by diluting lOOm L of the eluent stock to volume in a 1 L volumetric flask. Transfer the eluent to the eluent reservoir on the IC. The pH of the diluted eluent is between 6.70 and 6.80.

13.7 PREPARATION OF POST-COLUMN REAGENT Dissolve 0.5g of DPC in lOOmL of HPLC grade methanol in alL volumetric flask. When all DPC has dissolved, add about 500mL of nanopure water, then 25mL of 96% spectrophotometric grade sulfuric acid. Bring to volume with nanopure water. Transfer the post-column reagent to a wide-mouth 1 L bottle that will then be placed in the post-column reagent delivery module on the IC.


13.8 PREPARATION OF HEXAVALENT CHROMIUM STANDARDS AND CONTROLS

Both hexavalent chromium calibration and control stocks are NIST traceable. Hexavalent chromium stocks are usually in 1000ig/mL concentrations. All standards are stored in the refrigerator until ready for use. The solutions are brought to room temperature prior to analysis. 13.8.1 Both the calibration and control standards are prepared from a lOOng/mL Cr6 solution. It takes two dilutions to make a lOOng/mL sub-stock. First dilute 0.5mL of 1 000ig/mL Cr6 stock into a 5OmL volumetric flask. This makes a 1 0ig/mL Cr6 solution. Place 0.5mL of the 1 0ig/mL Cr6 sub-stock in a 5OmL volumetric flask. Bring to volume. This second sub-stock solution concentration is lOOng/mL hexavalent chromium. 13.8.2 Calibration Standards: Dilute appropriately to make a sub-stock with a concentration of lOOng/mL. The working standards are prepared in lOOmL volumetric flasks:

13.8.3 Control Standards: The control is prepared from a secondary source stock. The control concentration is 1 .Ong/mL. Prepare a sub-stock with a concentration of lOOng/mL. Place 1.OmL of the lOOng/mL sub-stock in a lOOmL volumetricflask. Bring to volume.

13.9 PREPARATION OF SODIUM BICARBONATE IMPREGNATING SOLUTION Filters are soaked in a 0.12mM sodium bicarbonate solution. Dissolve 5.0 g of sodium bicarbonate in nanopure water in a 500mL volumetric flask. Bring to volume and transfer the solution to a wide-mouth polyethylene storage bottle.

13.10 PREPARATION OF HEXAVALENT CHROMIUM FILTERS Whatman #41 37 mm cellulose filters are handled with either clean Teflon-coated or plastic tweezers or with disposable PVC gloves. Pour part of the sodium bicarbonate impregnating solution in a large clean glass petri dish. After inspecting the filters for any tears, holes, or contamination, place the cellulose filters in the solution. Make sure all filters are soaking in the impregnating solution. After soaking the filters a few minutes, remove the filters from the solution and place them on a plastic net or drying rack. Place the dried filters in a Ziploc bag. On the outside of the bag place the following information: lot number of the filters, date of filter preparation, and initials of the preparer. Place in the freezer until filters are needed. The freezing reduces the sodium bicarbonate from reacting with possible interfering substances present in the air. 10.1 Filter Mail-Out Preparation: The filters are sent to the site operators in black rings that are placed in plastic petri dishes. First place a circular label on each petri dish. This label contains spaces where the site operator will write down the site and sampling date. Place the female portion of the black ring on a clean surface or clean towel. Place a prepared filter onto the ring. Snap the male portion of the ring on top. Place

Concentration (nglmL) Aliquot (mL) of lOOng/mL 0.5 0.5 1.0 1.0 1.5 1.5 2.0 2.0


the filter into the plastic petri dishes. Packs with nine filters are then shipped out. Mail-outs occur about two weeks before the end of the quarter. Place these filters in a cool, dry place.

13.11 FILTER LOG-IN Filters are received in the laboratory with site name and sampling date written on the plastic petri dishes. A strip of paper with data (i.e. date received, average flowrate, duration, and volume) from the Xontech 920 sampler is taped to the outside of this petri dish. This data is logged into the Laboratory Information Management System (LIMS) (i.e. SQL*LIMS). All filters are assigned a barcode identification number. Remove the black ring holders, and place the filter in the petri dish. Place all samples in the freezer until ready for analysis. 11.1 The following is a list of invalid reasons: Filter contamination

Filters are either dropped or contaminated by any foreign matter (i.e. dirt, finger marks, ink, liquids)

Damaged or torn

Filters with tears or pinholes which occurred before or during sampling

Flowrate Average flowrate is less than 9.OLPM

Flowrate Average flowrate is greater than 14.OLPM

Flowrate Start and stop flowrates differ by more than ±10%

Flowrate Average flowrate differs from the start or stop flowrates by more than ±10%

Duration Samplers starting before 2300 hours and after 0100 hours

Duration Samplers operating less than 23 hours or more than 25 hours

Power failure Duration parameters are violated due to a power failure

Printout Sample printout is not complete or missing and data cannot be retrieved

13.12 FILTER ANALYSIS Due to oxidation/reduction and the conversion of Cr3 and Cr6, the extraction is performed immediately prior to analysis. Hexavalent chromium concentrations have been shown to increase significantly with time. It is important that the IC be equilibrated and ready for analysis. Calibrate the IC using four standards prior to analyzing samples.


After the calibration is performed a control, check standard, water blank, filter blank, and filter spike are determined. The ambient air samples are analyzed along with a check standard after every tenth sample. At the end of the sample run a check standard and a control are again determined. 12.1 First, printout a hexavalent chromium worklist to confirm which samples need to be extracted and analyzed. Prepare the water and filter blanks, filter spikes, and ambient air samples by placing the proper filter into an assigned 5OmL Teflon test tube using disposable PVC gloves. Add l5mL of nanopure water and cap the test tube tightly. Place the rack of test tubes in a sonicator bath for three hours. After three hours, remove the rack of test tubes. 12.2 Transfer approximately 5mL of extracted sample to a corresponding Dionex IC autosampler vial, which is in an autosampler cartridge. For replicate samples, pour approximately 2.5 mL of the extracted sample into a vial. This conserves Cr6 samples. Place the cartridge on the autosampler to be analyzed. Extracts are refrigerated until all analyses are completed.

13.13 QUALITY CONTROL 13.13.1 Limit of detection (LOD) is a value that is based on statistical information. The LOD is described as the lowest concentration an analyst can quantify with a certain confidence level. The calculated limit of detection for the method is determined by analyzing a low standard (i.e. 0.25 ng/ml) seven times The method’s calculated limit of detection is determined according to 40 CFR, Appendix B, as follows:

LOD = T( 1.1 O99)(sd) where, T(1099) = 3.143 for seven replicates Sd = standard deviation of seven replicate analyses of a standard solution The published LOD, which is the LOD that is used when reporting finalized data to the public, is 0.2 ng/mL. This LOD considers variation of instrument performance over time due to degradation of columns, lamps, and detectors. The published LOD is based on the calculated LOD and the chemist’s experience of the method and instrument. 13.13.2 Four known standards are analyzed for the linear regression calibration curve. Check the linear curve and correlation coefficient. If the correlation coefficient is less than 0.950, the standards are re-analyzed. 13.13.3 Controls are prepared from a second source of Cr6 stock. They are analyzed after the calibration is complete and at the end of the sample run. Control limits are historically derived from previously analyzed control samples. The limits are determined by calculating the mean and standard deviation (sd) of historical data. The limits are defined as below:

Upper Control Limit (UCL) = mean + 3sd Upper Warning Limit (UWL) = mean + 2sd Lower Warning Limit (LWL) = mean - 2sd Lower Control Limit (LCL) = mean - 3sd.


If one or both of the control values are out of the acceptable limits, then the instrument is evaluated for problems and appropriate corrective action is taken. Affected samples are re-analyzed until the control is within limits. 13.13.4 Check standards are the 1.0 ng/mL calibration standard analyzed every tenth sample. Check standard limits are ±20% of the target concentration. If one or more check standards are not within limits, affected samples are re-analyzed until all check standards are in control. 13.13.5 There are two types of blanks: a filter blank and a water blank. Blanks are analyzed with each set of extracted filters. Water and filter blanks are analyzed in the beginning of a sample run. Water and filter blanks test for any contamination either in the nanopure water used to extract the sample set or on the filter. 13.13.6 Spikes are unexposed filters spiked with 1 Spt of the 1 .0ig/mL Cr6 solution. Place the dried filters in a storage bag with the appropriate identification, such as date filters were spike and the chemist’s initials. Place the bag in the freezer until ready to use. A spike is extracted and analyzed with each sample set. It is usually analyzed after the filter blank. The filter spike calculated concentration is 1 .O ng/mL. The spike recovery limit is ±20%.

13.14 HAZARDOUS WASTE 13.14.1 The eluent waste is acidic. Neutralize the waste by dissolving sodium hydroxide to the solution. The waste, originally clear, will change to a pink hue when it is close to being neutral in pH. Use pH strips to confirm the pH level. The waste removed from the satellite area should be neutral before placing into the appropriately labelled drum. For location of the hazardous waste drum and more information concerning the removal of hazardous waste contact the hazardous waste coordinator. 14.2 In the laboratory there should be a satellite hazardous waste container for the hexavalent chromium working standards. Keep the stock standards in their individual containers. Do not place the stock standards in the working standards hazardous waste container. Contact the Hazardous Waste Coordinator for the removal of hexavalent chromium stock and working standards.

13.15 REFERENCES 1. California Air Resources Board Method 105: Procedure for the Analysis of

Hexavalent Chromium at Ambient Atmospheric Levels by Ion Chromatography.

2. Dionex Technical Note TN24: Determination of Chromium by Ion Chromatography, Dionex Corporation, July 1991.


14. APPENDIX 4: EXPERTISE OF THE EAP

14.1 CURRICULUM VITAE 14.2 ROGER DIAMOND Name Roger E Diamond Date of Birth 4 July 1972 Nationality South African Identity Number 7207045059080 Sex Male Marital Status Unmarried Language English and Afrikaans Qualifications BSc (Geology) University of Cape Town 1993 BSc(Hons) Geochemistry University of Cape Town 1994 MSc Geology University of Cape Town 1997

14.2.1 KEY EXPERIENCE One year experience in exploration geology in Western Australia. Three years experience in hydrogeology in Western Australia. Four years experience in environmental management in the Western Cape, specializing in waste management. Gold exploration utilizing geophysics, geochemistry, field mapping and extensive

drilling across a variety of prospects, including proving resources that have since been mined.

Groundwater quality investigation of agricultural pollution of groundwater that feeds a river and an estuary. Drilling, sampling, analysis and reporting, including presentation to the community.

Aquifer pumping tests of a semi-confined and unconfined aquifer. Salinity investigations relating to naturally occuring saline groundwater and

changes in the hydrological regime due to extensive agriculture. Construction of 500m deep monitoring bores in public water supply aquifers that

feed Perth. Investigation of mine dewatering and pit voids, possibly leading to salinization of the

aquifer. Interrogation of State database and use of GIS to prospect for town water supply. Various groundwater quality investigations around a municipal waste site, a

sewerage treatment works, an industrial facility, etc.


Establishment of a corporate environmental responsibility programme, including branding, marketing and education. Established an indigenous roof garden on a city centre office block.

Development of health care waste management legislation, including research, drafting, workshopping with stakeholders, publishing in the government gazette, etc.

Promotion of cleaner production in the hospitality sector through auditing of several establishments (water, energy and waste) and conceptualization of a green rating system.

Review and commenting on environmental impact assessments including projects such as regional landfills, transfer stations, composing facilities, a fertilizer factory site remediation and the Pebble Bed Modular Reactor Nuclear Power Station.

Design and supervision of environmental remediation by local authorities, including wetlands and streamlines.

Promotion of recycling through extensive networking, knowledge sharing and assisting the public.

14.2.2 EMPLOYMENT HISTORY & PROJECT EXPERIENCE Environmental Science Associates June 2007 - Present Project Management & Development Manager Key Projects SASOL Synfuels environmental legal compliance audit. Groundwater site investigation for a proposed chrome chemicals plant. Irrigation water quality and floodplain impact assessment for a sports field

bordering an estuary. Cape Peninsula University of Technology March 2006 - Present Part Time Lecturer Lecturing introductory earth science to B.Tech (Environmental Management) students. Western Cape Department of Environmental Affairs and Development Planning November 2003 – June 2007 Principal Environmental Officer, Waste Management Policy and Programmes Projects

Created and managed this project that established recycling and energy efficient

behaviours throughout the Department; installed a roof garden on the Departmental office building in central Cape Town; retrofitted lighting and developed a draft green procurement policy.

This project was more about education and marketing the idea to people than about simple hard interventions. A 2Wise2Waste brand was developed and is


evolving as the project progresses. This project is fully supported by the MEC, Tasneem Essop, and gets mentioned annually in her budget speeches to Provincial Cabinet.

Presented a paper at the biennial Wastecon – see publications list below. Hospitality Cleaner Production A project with 9 hotels/lodges in the Western Cape that audited, educated and

implemented energy, water and waste saving measures. This project was about selling the idea of initial capital outlay to gain continued savings – use of the payback period concept was critical to its success.

A green rating system was proposed as a way of furthering these goals – in this case, the concepts of sustainable development and responsible tourism were introduced to the participants, as well as the value of marketing green accreditation.

Western Cape Cleanup Operation Supervised rehabilitation work in Kannaland and Oudtshoorn Municipalities. Involved with designing a rehabilitation project on the Khayelitsha Wetlands on the

Kuils River – met with the KDF (Khayelitsha Development Forum) and SANBI to establish an indigenous tree nursery; liased with CapeNature, Working for Wetlands; attend Western Cape Wetlands Forum meetings; partnering with the City of Cape Town to implement the project.

Western Cape Health Care Waste Management Bill and Regulations Conducted research around health care waste handling and best practice. Assisted with legal drafting. Organised workshops around the Province for all stakeholders (municipal officers,

state and private nurses and health administrators, health care waste handlers, etc.).

Other duties Complaints Investigated and reported on illegal dumping, burning, etc. Ministerial complaints/requests – paper recycling crisis; `Butts Out` cigarette litter

proposal; Provincial Government `Peak Oil` position. Comments EIAs – Milnerton AECI site rehabilitation, Pebble Bed Modular Reactor

Demonstration Power Plant at Koeberg, Breede River Winelands Municipality Regional Landfill, Struisbaai Drop-off, Piketberg Transfer Station, Faure Landfill Closure EMP, etc.

LEGISLATION – NEMA EIA regulations, NEMA Waste Bill, Provincial Energy Strategy. Representing Government AGMs – PETco, Fairest Cape Association, Oasis Association. Launches – Isotherm, SA Glass Recycling Agreement. Other meetings – WESSA 80th anniversary, Waste Management Recycling Interest

Group (IWMSA), ESKOM compact fluorescent disposal workshop, etc. Parsons and Associates Specialist Groundwater Consultants October 2002 – December 2002


Contract Hydrogeologist Groundwater pollution investigation around the Everite Factory, Brackenfell,

entailing drilling of monitoring boreholes within the urban area. Groundwater pollution investigation around the Brackenfell Landfill, including

sampling for tritium (3H). Groundwater pollution investigation around the Zandvleit Sewerage Treatment

Works. Water & Rivers Commission, Government of Western Australia March 1999 – February 2002 Hydrogeologist Projects Groundwater quality investigation of agricultural pollution on the Scott coastal plain. This sandy coastal plain is underlain by a deep sedimentary basin with large, fresh water aquifers. Centre-pivot irrigation and fertilization results in significant nutrient pollution that also affects the surface water bodies, including a relatively pristine estuary where toxic cyanobacteria algal blooms occurred. Drilling, logging, pumping tests, sampling, analysis and interpretation of the nutrient data were all performed, summarized in several reports and presented to the agricultural community concerned. Construction of monitoring boreholes in public water supply aquifers north east of Perth. These aquifers form part of the supply for Perth’s drinking water that is 50% sourced from groundwater. Boreholes up to 500m deep were constructed into several different aquifers to enable better monitoring of groundwater levels. A borehole construction report was completed and a hydrogeological review of the area was updated with the new information. Investigation into the pisolitic palaeochannel iron ore deposits and surrounding geological formations of the western Pilbara. Large pit voids after mining threaten to salinize the aquifer and affect downstream water users, including agriculture and Aboriginal heritage sites. Mine dewatering also alters the hydrological regime. Several salinity investigations in the Western Australia Wheatbelt. Salinity is the single biggest environmental crisis faced in Australia today. Wholesale clearing of woodland to make way for extensive agriculture has resulted in changed hydrological regimes allowing saline groundwater to desertify land. Several drilling investigations were conducted in different catchments in the Wheatbelt as part of the government’s response to salinity. Networking was done with agricultural communities and other government agencies to increase understanding and promote positive responses to salinity. Groundwater potential evaluation around Albany. Interrogation of the State groundwater database and display of information using GIS to highlight areas with potential for drinking water supply for the town of Albany. A report and presentation were completed. Other duties Answering public groundwater enquiries.


Providing quality control and comment on Aquabase, the WA State groundwater database.

Sons of Gwalia Ltd. June 1997 – April 1998 Exploration Geologist Duties The following activities were undertaken in the search for gold on the Archaean amphibolite facies Southern Cross Greenstone Belt in Western Australia: Supervise drilling: RAB, aircore, reverse circulation and diamond. Hand augering for soil samples for geochemical analysis. Log geology encountered in drillholes and input into database. Sample pit walls, send for analysis and interpret data. Field mapping. Reporting. Prospect assessment, involving compilation and analysis of all available

information. 14.2.3 EDUCATION Further Technical Training 1998 – Present Interpretation and Structural Analysis of Aeromagnetic Data – Southern Cross, Western Australia Groundwater Course – Centre for Groundwater Studies, Perth ArcView GIS Courses – Perth and Cape Town Environmental Law – Potchefstroom University Environmental Risk Assessment – Rhodes University Environmental Economics – Rhodes University Environmental Management Inspector training – DEAT, TRAFFIC, University of Pretoria Policy Writing – University of Stellenbosch

University of Cape Town 1991 – 1997 BSc in Geology, including Climatology, Oceanography, Environmental and

Geographical Science and Astronomy. Attained the Dean’s Merit List and won 3 class medals.

BSc(Hons) in Geochemistry. Honours project on hydrothermal fluids and metamorphism at the unconformity between the Malmesbury Group and Table Mountain Group. Field mapping, microscope work and XRF analyses of major, minor and trace element geochemistry.

MSc in Geology. Stable Isotopes of the Thermal Springs of the Cape Fold Belt. This study made use of oxygen and hydrogen isotope data from spring water, rain water and various rocks, all collected during the study. Analysis was by mass spectrometer. The study revealed information on the source of recharge and possible circulation of deep groundwater in the Cape Fold Mountains. The information is now used by those prospecting for groundwater in the Cape Fold Mountains.


Schooling 1979 – 1990 Matriculated at Westerford High School, Cape Town, with A aggregate.


14.3 CURRICULUM VITAE 14.4 ABDUL EBRAHIM Name Abdul H Ebrahim Date of Birth 7 December 1977 Nationality Zimbabwean Identity Number (RSA) 7712076019184 Sex Male Marital Status Unmarried Language English (French & Portuguese) Qualifications and Memberships BSc(Hons) (Mech Eng) University of Zimbabwe 2000 BEng(Hons) (Chem Eng - Environmental) University of Pretoria in progress

Member of the Engineering Council of South Africa – registration number 20075012

14.4.1 KEY EXPERIENCE Four years of engineering and process control with British American Tobacco in Zimbabwe. Three years of environmental management with Environmental Science Associates. Implementation of statistical methods for evaluating process experiments, selecting

measuring instrumentation and doing cause-effect analyses in a tobacco processing plant

Machine design and installation including conveyor belts that resulted in reduced downtime, baghouse and dust extraction plant, various tobacco processing machinery

Automation of mass flow control, primary and secondary leaf conditioning, re-drying and steam control to improve product moisture consistency

Development and implementation of environmental management systems for several large industrial facilities

Environmental impact assessment for various proposals or developments, including heavy industry and recreational facilities

Soil and groundwater contamination assessment for different industrial clients Environmental due diligence assessments including environmental liabilities for

mining, mineral processing and industrial sites Environmental legal compliance audits of various mining, minerals processing, and

industrial operations, Air quality assessment and emissions plans for various industrial installations Cleaner production and process optimizations at several processing plants ISO 14001 audits of industrial and mining operations


Training including development of training materials for government and private institutions

14.4.2 EMPLOYMENT HISTORY & PROJECT EXPERIENCE Environmental Science Associates 2004 – 2007 Projects Manager Environmental management system development & implementation: Lafarge Gypsum Aspects Identification, Rating, Assessment and Development of

EMPs Environmental Aspects Identification, rating and formulation of EMPs for Samancor

Metalloys Meyerton Environmental Aspects Identification, rating and formulation of EMPs for DMS

Powders. Holcim Slagment development & implementation of EMS components including

waste and air quality management Holcim Roodepoort development & implementation of EMS components including

waste and air quality management Environmental impact assessment: Samancor chrome chemicals plant development Kanhym Biogas project Turfontein Race Course night racing Alumicor secondary aluminium recovery rotary salt furnaces Hays Lemmerz Aluminium smelters, furnace and alloy die casting Plettenburg Polo Estates PG Bison Decorative Panels British Aerospace Land Based OMC Systems

Specialist Training Course Development & Presentation 2007&8 Bridging Training for Environmental Management Inspectors

Repsonsible for development of NEMA EIA Review Course and Adminstrators EIA Review Manual, theoretical and practical training material, and training of Government Officials repsonsible for EIA Review - responsible for the whole manual other than Law applicable to EIA Review. As at May 2007 approximately 400 officials from DEAT and 9 Provinces have been trained. Project is to be extended to cover the training of officials from DME and additonal officials from provinces. 2005&6 Bridging Training for Environmental Management Inspectors

ESA was part of a consortium selected to develop the EMI Bridging Training. ESA compiled and presented the chapter on routine inspections. A total of 420 officials have completed the training, which was an IAIAsa Premium Project finalist in 2006. Soil and groundwater contamination assessment: Lafarge Gypsum Kanhym Estates SABAT (Pty) Ltd Johannesburg – investigation of heavy metal contamination of soils

and groundwater Chemiphos SA (Pty) Ltd – investigation of phosphate and heavy metal

contamination of soils and groundwater


Castrol Lubricants Zimbabwe Environmental due diligence audits, including assessment of environmental liability: Determination and quantification of financial provision for the environmental

rehabilitation and closure requirements of smelting operations for Highveld Steel & Vanadium operations:

Highveld Iron and Steel Works Vanchem Transalloys Rand Carbide Mapochs Mine

Determination and quantification of financial provision for the environmental

rehabilitation and closure requirements of smelting operations for TransAlloys Determination and quantification of financial provision for the environmental

rehabilitation and closure requirements of mining operations for Samancor Chrome: Middelburg Ferrochrome Ferrometals Tubatse Ferrochrome Western Chrome Mines Eastern Chrome Mines

Environmental legal compliance assessment: NATCOS Petrochem SASOL Synfuels Angloplatinum Base Metals Recovery Samancor Hotazel Manganese Mines PG Bison (Pty) Ltd MDF manufacturing Samancor Manganese Division Samancor Metalloys Meyerton Holcim SA (Pty) Ltd Cement Plants:

Dudfield Ulco Roodepoort

Natal Portland Cement Plants: Newcastle

South African Airways (Pty) Ltd Technical Division TWK forestry strategic environmental legal compliance assessment Inergy Automotive Systems(Pty) Ltd

Air quality assessment, including emissions management: Hayes Lemmerz SA Aluminium Wheel Manufacturing Samancor Chrome Chemicals Aluminicor secondary aluminium recovery rotary salt furnaces – assisted using

Screen 3 Model Holcim Roodepoort Cement Mills and Materials Management – assisted using

Screen 3 Model Cleaner production audits and project implementation: Premier Foods Pretoria Wheat Mill Kanhym Estates Biogas Generation from piggery effluent Brittish American Tobacco:

Tobacco Processors Zimbabwe


Souza Cruz Brasil ISO14001 auditing: Debswana Orapa and Letlhakane Mines Ingwe Colliery Arnot Colliery FOSECO South Africa (Pty) Ltd Lafarge Gypsum

Environmental Management Systems Samancor Metalloys Ferro Silicon Manganese and FerroSilicon production DMS FeSi dense media prodcution Lafarge Gypsum

British American Tobacco (plc) Graduate Engineering Trainee 2000 - 2002 Process Control Manager 2002 - 2004 Introduction of statistical process control and use of cause effect fishbone analysis

to identify root causes of assignable process variation in tobacco processing plant Introduction and lead of quality circles as a means of identifying opportunities for

process improvement as well as a means of operator training in SPC ideology Introduction of the use of statistical methods to evaluate the results process

improvement experimentation Introduction of the use of statistical methods for selection of key measuring

instrumentation based on repeatability and accuracy under varying process conditions

Formulation and implementation of best practices for belt conveyor design, fabrication and assembly based on statistical root cause analysis of downtime, resulting in 54% reduction in conveyor related downtime

Bundle busting machine design and fabrication resulting in increased production line federate from 3000kg/h to 4000kg/h for a subsidiary line.

Dust extraction and baghouse plant fabrication and erection (designed externally) Buts Line Rate control Design, Fabrication and Automation for improved product

mass flow rate control and consistency Automation of primary and secondary tobacco leaf conditioning to improve

control of conditioning and reduce deviation of product moisture content Redryer Automation resulting in improved product quality consistency, reduced

deviation in final product moistures. Automated supply steam control for tobacco processing plant to improve steam

supply consistency resulting in an average 8% improvement in final moisture variation.

Redesign of threshing baskets to optimise yield and improve PSD variation, resulting in significant measurable improvements in all Particle Size Distribution components as well as improved yield


Implementation of integrated Quality and Environmental management systems and successful certification to ISO 14001:1996 and ISO9001:2000 for Tobacco Processors Zimbabwe.

Implementation of integrated Quality and Environmental management systems and successful certification to ISO 14001:1996 and ISO9001:2000 for Export Leaf Tobacco (Pty) Ltd.

Cleaner production assessment for Souza Cruz & Export Leaf Tobacco Company, Santa Cruz Do Sul, Brazil.

Cleaner production assessments for Tobacco Processors Zimbabwe


14.4.3 EDUCATION Further Technical Training

Course Year Institute Government Certificate of Competence Occupational Health and Safety

2006 University of Potchefstroom South Africa

Environmental Management Accounting

Tshwane University of Technology South Africa

Air Resources Engineering 2005 Witwatersrand University South Africa

SCADA WonderWare InTouch 2003 Futuristix Johannesburg, South Africa

Programmable Logic Control Networks 2002 & 2004

Schneider South Africa South Africa

SCADA InSQL Sever 2002 & 2004

Futuristix Johannesburg, South Africa

Instrumentation and Automation 2002 TM Training Initiative Welkom, South Africa

Programmable Logic control 2002 TM Training Initiative Welkom, South Africa

WonderWare QI Analyst 2002 Futuristix South Africa

WonderWare Industrial SQL Server 2002 Futuristix South Africa

Certificate in Electrical & Electronics Engineering

2002 City & Guilds UK – by correspondence

ISO 14001: 1996 implementation 2001 Sharp Point Zimbabwe

ISO 9001: 2000 implementation 2001 Sharp Point, Zimbabwe

Certificate in Quality Management 2001 City & Guilds UK – by correspondence

BSc (Hons) Engineering 2000 University of Zimbabwe Zimbabwe

University of Zimbabwe 1996 – 2000 BSc(Hons) in Mechanical Engineering. Achieved 2nd place in class of 36 graduates.


14.5 CURRICULUM VITAE 14.6 THEO FISCHER Name Theo E Fischer Date of Birth 20 January 1974 Nationality South African Identity Number 7401205004081 Sex Male Marital Status Unmarried Language English and Afrikaans Qualifications and Memberships BSc Nat Sci (Chemistry & Geography) University of Pretoria 1996 Membership National Association of Clean Air (NACA) International Association of Impact Assessment (IAIAsa) Institute for Waste Management Geological Society of South Africa

14.6.1 KEY EXPERIENCE Ten years of environmental management experience, largely in the industrial and natural resource sectors. Major focus areas include: ISO 14001 environmental management system development and implementation for

clients such as Holcim, Samancor and others. Auditing industrial installations across various sectors, including Shell Petroleum

Development Company Nigeria. Environmental impact assessment and EIA project management. Mine rehabilitation and closure planning. Due diligence assessments. Environmental liability modelling, including Samancor and Highveld Steel & Vanadium. Contaminated land and groundwater rehabilitation such as at Chemiphos, Kanhym

and others Management of hazardous waste including handling, storage, analysis and

classification as well as the development of waste minimisation, treatment and recycling strategies for clients including Alumicor and Hayes Lemmerz.

Air quality management including the Ekurhuleni Air Quality Management Plan, emissions inventories and reduction strategies for Alumicor and Hayes Lemmerz.

Developed air quality biomonitoring methods for monitoring Chrome (VI). Environmental legal compliance assessment as a technical specialist at Holcim, Natal

Portland Cement, Tongaat Huletts, PG Bison, Mondipak and others.


Specialist training including environmental compliance enforcement training for DEAT Environmental Management Inspectors (Green Scorpions).

Presented papers at the NACA, IAIAsa and IWMSA annual conferences. Published peer reviewed papers dealing on air quality biomonitoring and waste

management legislation applicable to the EIA process respectively. Interests range from the use of metallurgical slags (by-products of the ferroalloy

industry) as aggregate replacements in the construction industry, to the use of lichens as biomonitors of air quality.

14.6.2 EMPLOYMENT HISTORY & PROJECT EXPERIENCE Environmental Science Associates 2000 – Present Specialist Training Course Development & Presentation 2007&8 Bridging Training for Environmental Management Inspectors

Repsonsible for development of NEMA EIA Review Course and Adminstrators EIA Review Manual, theoretical and practical training material, and training of Government Officials repsonsible for EIA Review - responsible for the whole manual other than Law applicable to EIA Review. As at May 2007 approximately 400 officials from DEAT and 9 Provinces have been trained. Project is to be extended to cover the training of officials from DME and additonal officials from provinces. 2005&6 Bridging Training for Environmental Management Inspectors

ESA was part of a consortium selected to develop the EMI Bridging Training. ESA compiled and presented the chapter on routine inspections. A total of 420 officials have completed the training, which was an IAIAsa Premium Project finalist in 2006. 2004&5 Training of EIA Component of SABS Environmental Law Course

Environmental assessment Environmental impact assessments for the following development proposals: Alumicor secondary aluminium recovery rotary salt smelters Hays Lemmerz Aluminium furnace & alloy die casting Expansion of Chemiphos SA (Pty) Ltd Phosphoric Acid Plant Teza Quarry and Access Road Development Steelpoort residential development Waterval Prison Agricultural Sewerage System Upgrade Bluegumsbosch Cemetery Qua-Qua Swaziland Main Roads MR2 And MR20 South African Provincial Road K77 The Ressano Garcia/Komati Poort Combined Borderpost

Environmental impact assessment review: Resort development on farm Epsom 189 KT Limpopo Province

Strategic environmental assessment: Steelpoort Town Development Csakvar International Airport

Air quality assessment and emissions modelling Contributed to the development of the Ekurhuleni Air Quality Management Plan and

assisted in various emissions screening assessments using the US EPA Screen 3 Model


Assisted in screening assessment of Alumicor secondary aluminium recovery rotary salt furnaces: Screen 3 Model

Assisted in screening assessment of Holcim Roodepoort Cement Mills and Materials Management: Screen 3 Model

Air quality biomonitoring: asbestos First application of lichen bio-monitoring as an indicator of environmental asbestos

pollution (Fischer TE & Cukrowska E, 2004, unpublished). Air quality Biomonitoring: chrome (VI) First application of lichen metal content bio-monitoring as an indicator of ambient air

quality in South Africa (Fischer TE & Cukrowska E, 2002, unpublished). Lichens were analysed for Chrome(VI) to determine Cr(VI) fallout levels from a nearby ferrochrome smelter.

Environmental management system auditing Auditing Shell Petroleum Development Company (SPDC) of Nigeria environmental management systems as Lead/ Process Auditor for KPMG Environmental Health & Safety Unit, KPMG Sustainability Services. SPDC Production Area West PCW SPDC Production Area East PAE SPDC Pipelines East SPDC Pipelines West SPDC Bonny Crude Oil Export Terminal SPDC Forcados Crude Oil Export Terminal SPDC Geomatics SPDC Seismics Environmental management system development and implementation Holcim Slagment, including air emission and waste management Holcim Roodepoort, including air emission and waste management Foskor Richards Bay Division Chemiphos SA (Pty) Ltd

Due diligence assessment Due diligence assessment on behalf of the buyer: Environmental due diligence audits, including assessment of environmental liability: Determination and quantification of financial provision for the environmental

rehabilitation and closure requirements of smelting operations for Highveld Steel & Vanadium operations:

Highveld Iron and Steel Works Vanchem Transalloys Rand Carbide Mapochs Mine

Determination and quantification of financial provision for the environmental

rehabilitation and closure requirements of smelting operations for TransAlloys Determination and quantification of financial provision for the environmental

rehabilitation and closure requirements of mining operations for Samancor Chrome:


Middelburg Ferrochrome Ferrometals Tubatse Ferrochrome Western Chrome Mines Eastern Chrome Mines

Environmental management programme reports and closure plans EMPR’s in terms of the Minerals Act of 1991 and the Minerals & Petroleum Resources Development Act of 2004: Teza Borrow Pit EMPR and closure plan Montrose Diamond Mine EMPR and closure plan

Environmental Legal Compliance Audits Environmental legal compliance assessments, where necessary in conjunction with environmental law specialists, for the following companies and operations: Samancor Manganese Division: Samancor Metalloys Meyerton Holcim SA (Pty) Ltd: Dudfield, Ulco, Roodepoort and Slagment cement plants Tongaat Hulette: Hillhead and Tongaat sugar cane estates Tongaat Hulette: Amitakulu, Felixton, Maidstone and Darnall sugar mills Rand Water (Waste legislation): Zwartkopjes, Vereeniging, Zuikerbosch pumping

stations, Rand Water (Waste legislation): Rietfontein and Central depot sites Natal Portland Cement: Durban, Newcastle, and Simuma (Port Shepstone) cement

plants South African Airways Technical Division (Johannesburg International Airport) TWK Holdings Forestry (Pty) Ltd Chemiphos SA (Pty) Ltd Dunlop Africa (Pty) Ltd Eskom Rotek Engineering (Pty) Ltd

Cleaner production, waste treatment and management strategies Waste minimisation, re-use or treatment processes: Alumicor Sa (Pty) Ltd: rotary smelter salt slag treatment and recycling strategies SAB Miller SA (Pty) Ltd: SAB Chamdor Brewery: filtration waste treatment and

recycling strategies Chemiphos SA (Pty) Ltd: arsenic sludge treatment and disposal options to prevent

leaching of arsenic Ferrochrome producers: chrome (VI) containing bag filter dust treatment to reduce

chrome (VI) and prevent leaching of metals Waste classification and hazard rating in terms of the DWAF Minimum Requirements or US EPA. Development of waste treatment processes for hazardous waste delisting. Soil and groundwater contamination assessment and rehabilitation SABAT (Pty) Ltd Johannesburg: investigation of heavy metal contamination Chemiphos SA (Pty) Ltd: investigation of soil phosphate and heavy metal

contamination

Landscape Architects Uys & White (Pty) Ltd 1997 – 1999 Senior Environmental Manager


Environmental Assessment: environmental impact assessment strategic environmental assessment environmental management frameworks

Resource Development Planning: analysis of resource and tourism asset bases tourism potential assessment and development planning

Gouws Uys & White (Pty) Ltd 1996 – 1997 Environmental Scientist Environmental Assessment: environmental impact assessment strategic environmental assessment environmental management frameworks

Du Boisson & Partners 1995 – 1996 Biochemistry Laboratory Assistant Specialising in pathological analysis, responsibilities included: routine chemical analysis of samples gas chromatographic, UV spectrophotometric analysis of samples reagent preparation miscellaneous lab assistance

14.6.3 EDUCATION 1980-1986 Queenswood Primary School 1987-1991 Willows Secondary School 1992-1996 BSc Nat Sci (Chemistry & Geography) University of Pretoria 1998 Understanding SABS ISO 14001 South African Bureau of Standards 1998 Groundwater Modelling MODFLOW University of Zululand 2000-2001 BSc(Hons) Env Mgt [year 1 of 2 part time] University of Pretoria

draft scoping report environmentalescience.co.za/project_pdf/nwcc/scoping report 2008... · the...

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