MAKEEAN POLYMERS cc: MAKEEAN POLYMERS FACTORY ATMOSPHERIC EMISSIONS LICENCE; CITY OF TSHWANE METROPOLITAN MUNICIPALITY - GAUTENG PROVINCE DRAFT ...
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MAKEEAN POLYMERS cc: MAKEEAN POLYMERS FACTORY ATMOSPHERIC EMISSIONS LICENCE; CITY OF TSHWANE METROPOLITAN MUNICIPALITY – GAUTENG PROVINCE DRAFT SCOPING REPORT GDARD Reference: GAUT 002/20-21/E2548. 24 August 2020
DRAFT SCOPING REPORT
FOR LISTED ACTIVITIES ASSOCIATED WITH THE ATMOSPHERIC
EMISSION LICENCE REQUIREMENTS ON A PORTION OF THE REMAINING
EXTENT OF THE FARM CHRYSLER PARK 423, IN THE TSHWANE
METROPOLITATN MUNICIPALITY, GAUTENG PROVINCE.
APPLICATION FOR ENVIRONMENTAL AUTHORISATION (EA):
SUBMITTED FOR ENVIRONMENTAL AUTHORISATIONS IN TERMS OF THE NATIONAL
ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL AIR
QUALITY ACT, 2004 IN RESPECT OF LISTED ACTIVITIES THAT ARE TRIGGERED.
Name of Applicant: Makeean Polymers cc
Tel No: +27 12 803 7180
Postal Address: PO Box 912-578 Silverton, 0127, South Africa.
Physical Address: 236 Propshaft Rd, Samcor Park, Waltloo, Pretoria, South Africa
Document prepared by: Kongiwe Environmental (Pty) Ltd
Document Date: 24 August 2020
Makeean Polymers cc: Makeean Polymers Atmospheric Emissions licence project - GAUT 002/20-21/E2548
Draft Scoping Report
© 2020 Kongiwe Environmental (Pty) Ltd
Draft Scoping Report Information
PROJECT: THE ENVIRONMENTAL AUTHORISATION REQUIRED FOR THE ATMOSPHERIC
EMISSIONS LICENCES FOR THE MAKEEAN POLYMER FACTORY
The Environmental Authorisation for the Atmospheric emissions licence for
Report Title:
the Makeean Polymers factory.
GDARD Reference
GAUT 002/20-21/E2548
Number:
Applicant: Makeean Polymers cc
Project No: GOND#001
Compilation Date: 24 August 2020
Status of Report: Draft Scoping Report for Public review
VERIFICATION CAPACITY NAME SIGNATURE DATE
By Author EAP Foord Ceronio 2020/08/18
Reviewed Legal
Michael Hennessy 2020/08/20
by: Director
Technical
Reviewed Director
Gerlinde Wilreker 2020/08/20
by: (EAPASA /
Pr.Sci.Nat)
Chief
Authorised
Executive Bradly Thornton 2020/04/24
by
Officer
Copyright © 2020 Kongiwe Environmental (Pty) Ltd
All rights reserved. Absolutely no part of this report may be reproduced, distributed, or transmitted in any form or by any means, including
photocopying, recording, or other electronic or mechanical methods, without the prior written consent of Kongiwe Environmental (Pty) Ltd. All
content and methodologies remain intellectual property of Kongiwe Environmental (Pty) Ltd. Where applicable, the contents of this document
are confidential and protected by legal privilege and must not be distributed to other parties without prior written permission. This report is to
be used for the sole purpose intended and should not be used for any other purpose without prior written permission.
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SECTION 1:
SCOPING REPORT OVERVIEW
Important Notice
In terms of Regulation 16(3) (b) of the Environmental Impact Assessment Regulations 2017, any report
submitted as part of an application must be prepared in a format that may be determined by the
Competent Authority (CA) and in terms of Regulation 17 (1) (c) the CA must check whether the application
has considered any minimum requirements applicable or instructions or guidance provided by the CA to
the submission of applications.
It is therefore an instruction that the prescribed reports required in respect of applications for an
environmental authorisation for listed activities triggered by an application for a right or permit are
submitted in the exact format of, and provide all the information required in terms of, this template.
Furthermore, please be advised that failure to submit the information required in the format provided in
this template will be regarded as a failure to meet the requirements of the Regulations and will lead to the
Environmental Authorisation being refused.
It is furthermore an instruction that the Environmental Assessment Practitioner (EAP) must process and
interpret his/her research and analysis and use the findings thereof to compile the information required
herein. (Unprocessed supporting information may be attached as appendices). The EAP must ensure that
the information required is placed correctly in the relevant sections of the Report, in the order, and under
the provided headings as set out below, and ensure that the report is not cluttered with un-interpreted
information and that it unambiguously represents the interpretation of the applicant.
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Objective of the Scoping Process
1) The objective of the scoping process is to, through a consultative process—
(a) identify the relevant policies and legislation relevant to the activity;
(b) motivate the need and desirability of the proposed activity, including the need and desirability of
the activity in the context of the preferred location;
(c) identify and confirm the preferred activity and technology alternative through an impact and risk
assessment and ranking process;
(d) identify and confirm the preferred site, through a detailed site selection process, which includes
an impact and risk assessment process inclusive of cumulative impacts and a ranking process of all
the identified alternatives focusing on the geographical, physical, biological, social, economic, and
cultural aspects of the environment;
(e) identify the key issues to be addressed in the assessment phase;
(f) agree on the level of assessment to be undertaken, including the methodology to be applied, the
expertise required as well as the extent of further consultation to be undertaken to determine the
impacts and risks the activity will impose on the preferred site through the life of the activity,
including the nature, significance, consequence, extent, duration and probability of the impacts to
inform the location of the development footprint within the preferred site; and
(g) identify suitable measures to avoid, manage, or mitigate identified impacts and to determine the
extent of the residual risks that need to be managed and monitored.
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Public Participation Plan for the Draft Scoping Report
Although the Directions Regarding Measures to Address, Prevent and Combat the Spread of COVID-19,
relating to the National Environmental Management Permits and Licences, published by the Minister of
the Environment, Forestry and Fisheries in GN 650 of 5 June 2020 are, in terms of Section 10, only
applicable during Alert Level 3, the Public Participation Process for the Draft Scoping Report will be carried
out in accordance with these Directions (the Directions) as a matter of best practice. In particular, the
provisions of Annexure 3 to the Directions will apply. A Public Participation Plan (PP Plan) will be discussed
with and approved by the Competent Authority and thereafter this will be communicated to all Interested
and Affected Parties and other Stakeholders.
Availability of the Draft Scoping Report for Public Review and Comment
Pursuant to the Directions, only electronic copies of the Scoping Report and Environmental Impact
Assessment Report/Environmental Management Programme will be made available. All stakeholders will
be encouraged to download the reports from Kongiwe Environmental’s website:
http://www.kongiwe.co.za/publications-view/public-documents/. A non-technical summary of the report
will be compiled and distributed to stakeholders, in particular, to stakeholders with no access to the
internet. Hard copies of the non-technical summary will be distributed through any relevant community
representatives. If required, an electronic copy (CD) of the reports can be made available upon a request
directed to the stakeholder engagement team. To curb the spread of COVID-19, all hard copies will be
enclosed in a plastic folder and sanitised.
The DSR will be made available to stakeholders for a 30-day comment period from Friday 28 August 2020
to Monday, 28 September 2020. Notification of the availability of the documentation for review was
distributed on Tuesday, 25 August 2020.
Accessing the Draft Scoping Report for public review and comment
Electronic copies:
Kongiwe Environmental website: www.kongiwe.co.za/ public documents
An electronic copy (CD) of the DSR will be made available upon a request directed to the stakeholder engagement
team. Stakeholders are encouraged to contact the stakeholder engagement team (Sibongile Bambisa/ Vanessa
Viljoen), Tel: (012) 003 6627, Email: stakeholders@kongiwe.co.za should they require assistance with accessing
the DSR/ have queries regarding the proposed project.
Hard copies:
A non-technical summary of the Draft Scoping Report will be compiled and distributed through community
representatives and/or couriered to stakeholders who send a request to the stakeholder engagement team.
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Executive Summary:
Kongiwe has been appointed by Gondwana Environmental Solutions (Gondwana) as the Independent
Environmental Service Provider tasked with conducting the Scoping and Environmental Impact
Assessment (S&EIA) as part of the Atmospheric Emissions licencing process. This is done with accordance
with the National Environmental Management: Air Quality Act, No. 39 of 2004 (NEM:AQA), as well as with
the National Environmental Management Act, No. 107 of 1998 (NEMA), as amended.
The Application for Environmental Authorisation will be submitted to the Gauteng Department of
Agriculture and Rural Development (GDARD) on (24 August 2020). The DSR will be made available for
public review from (28 August – 28 September 2020).
Project Introduction and Background
Gondwana was approached by Makeean Polymers cc (Makeean), which is a polymer generation factory in
Samcor Park, Waltloo, City of Tshwane. The factory was visited by the City of Tshwane on a routine
inspection and Makeean was informed that an Atmospheric Emissions Licence (AEL) is required.
Following this visit, Makeean contacted Gondwana to assist with the AEL. As part of the legal requirements,
the application for an AEL requires an application for Environmental Authorisation, supported by a Scoping
and Environmental Impact Assessment (S&EIA) process. Kongiwe was approached by Gondwana to assist
with the environmental authorisation aspects of the licencing requirements.
The facility has been in existence and operational since 1989 and is on a piece of land roughly 0.30 Ha in
extent in a light industrial zone within Samcor Park, Waltloo, City of Tshwane. The residential area of
Silverton is located approximately 650m west of the currently active facility. The community of Nellmapius
is located a kilometre east of the factory. Willow Park Manor is located roughly a kilometre to the south
and the community of Meyerpark can be found approximately 600m to the south west of the project area.
Project Alternatives
The factory is currently operational, and this Environmental Authorisation is being conducted as part of
the requirements from the City of Tshwane’s for an AEL. Due to this no project alternatives will be
evaluated.
Environmental Impact Process
The Department of Environment, Forestry and Fisheries (DEFF) identified the need for the alignment of
Environmental Authorisations (EAs) and promulgated a single environmental system under the National
Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA). This has resulted in simultaneous
decisions in terms of NEMA, the National Environmental Management: Air Quality Act, 2004 (Act No. 39
of 2004) (NEM:AQA) and other specific environmental management Acts.
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As from 2 September 2014 the statutory dispensation regarding environmental management changed
with the implementation of the One Environmental System and the commencement of the National
Environmental Management Laws Amendment Act (Act No. 25 of 2014) (NEMLAA). In line with the One
Environmental System, the Environmental Impact Assessment Regulations, 2014 (EIA 2014 Regulations)
were promulgated and came into force on 8 December 2014. The EIA 2014 Regulations have subsequently
been amended on the 7th of April 2017. With reference to the aforementioned, this S&EIA, prepared in
support of the EA application, will comply with the requirements of the EIA 2014 Regulations, as amended.
The Proposed Project therefore requires Environmental Authorisation (EA) in terms of the NEMA and the
NEM:AQA and will follow a S&EIA process in terms of the EIA 2014 Regulations, as amended. The aforesaid
regulations enforce a strict timeframe and require a decision by the competent authority (CA), GDARD,
within 300 days from submission of the EA application.
The nature and extent of the licencing processes, as well as the potential environmental impacts
associated with the operation of this facility is assessed and presented in this DSR.
Legal Background and Requirements
This Draft Scoping Report (DSR) has been compiled in terms of the provisions of Appendix 2 of the EIA
Regulations 2014, as amended. Table 1-1 cross-references the various sections in this report with these
requirements.
Table 1-1: Structure of the Scoping Report in line with the Appendix 2 of the EIA 2014 Regulations, as
amended.
REPORT PAGE
NO. REGULATION REQUIREMENT
SECTION NUMBER
(a) Details of -
(i) The EAP who prepared the report and;
(ii) The expertise of the EAP 1.4 5-6
including a CV
(b) The location of the activity, including –
(i) The 21-digit Surveyor General code of each cadastral land parcel
(ii) Where available, the physical address and farm name 2.1 7-10
(iii) Where the required information in terms of (i) and (ii) is not available, the
coordinates of the boundary of the property or properties
(c) A plan which locates the proposed activity or activities applied for at an
appropriate scale, or, if it is –
(i) A linear activity, a description and coordinates of the corridor in which
2 8
the proposed activity or activities is to be undertaken
(ii) On land where the property has not been defined, the coordinates within
which the activity is to be undertaken
(d) A description of the scope of the proposed activity, including – 2.4 14
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REPORT PAGE
NO. REGULATION REQUIREMENT
SECTION NUMBER
(i) All listed and specified activities triggered
3.1 21-22
(ii) A description of the activities to be undertaken, including associated
2.3 13
structures and infrastructure
(e) A description of the policy and legislative context within which the
development is proposed including an identification of all legislation,
policies, plans, guidelines, spatial tools, municipal development 3 15-22
planning frameworks and instruments that are applicable to this
activity and are to be considered in the assessment process
(f) A motivation for the need and desirability for the proposed
development including the need and desirability of the activity in the 4 23-24
context of the preferred location
(g) Period of environmental authorisation 5 25
(h) A full description of the process followed to reach the proposed
6 26-28
preferred activity, site and location within the site, including -
(i) Details of the alternatives considered 6.1 26-28
(ii) Details of the public participation process undertaken in terms of
regulation 41 of the Regulations, including copies of the supporting 7 29-36
documents and inputs
(iii) A summary of the issues raised by interested and affected parties, and an
indication of the manner in which the issues were incorporated, or the Appendix C9 N/A
reasons for not including them.
(iv) The environmental attributes associated with the alternatives focusing
on the geographical, physical, biological, social, economic, heritage and 8 37-53
cultural aspects
(v) The impacts and risks identified for each alternative, including the
nature, significance, consequence, extent, duration and probability of
the impacts, including the degree to which these impacts –
(aa) can be reversed; 9.2 58-59
(bb) may cause irreplaceable loss of resources; and
(cc) can be avoided, managed or mitigated
(vi) The methodology used in determining and ranking the nature,
significance, consequences, extent, duration and probability of potential 9.1 54-57
environmental impacts and risks associated with the alternatives
(vii) Positive and negative impacts that the proposed activity and alternatives
will have on the environment and on the community that may be affected
9.2 58-59
focusing on the geographical, physical, biological, social, economic,
heritage and cultural aspects
(viii) The possible mitigation measures that could be applied and level of 9.4 58-59
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REPORT PAGE
NO. REGULATION REQUIREMENT
SECTION NUMBER
residual risk
(ix) The outcome of the selection matrix 9.5 59
(x) If no alternatives, including alternative locations for the activity were
9.6 59
investigated, the motivation for no considering such
(xi) A concluding statement indicating the preferred alternatives, including
9.7 59
preferred locations of the activity
(i) A plan of study for undertaking the environmental impact assessment
10 60-67
process to be undertaken, including -
(i) A description of the alternatives to be considered and assessed within the
10.1 60
preferred site
(ii) A description of the aspects to be assessed as part of the environmental
10.2 60
impact assessment process
(iii) Aspects to be assessed by specialists 10.3 60-62
(iv) A description of the proposed method of assessing the environmental
10.4 63-67
aspects, including aspects to be assessed by specialists
(v) A description of the proposed method assessing duration significance 10.4.1 63
(vi) An indication of the stages at which the competent authority will be
10.4.2 63
consulted
(vii) Particulars of the public participation process that will be conducted
10.4.3 64
during the environmental impact assessment process
(viii) A description of the tasks that will be undertaken as part of the
10.4.4 64
environmental impact assessment process
(ix) Identify suitable measures to avoid, reverse, mitigate or manage
identified impacts and to determine the extent of the residual risks that 10.4.5 65
need to be managed and monitored
(j) An undertaking under oath or affirmation by the EAP in relation to –
(i) The correctness of the information provided in the report;
(ii) The inclusion of comments and inputs from stakeholders and
interested and affected parties; 11 68
(iii) Any information provided by the EAP to interested and affected
parties and any responses by the EAP to comments or inputs
made by interested or affected parties
(k) An undertaking under oath or affirmation by the EAP in relation to the
level of agreement between the EAP and interested and affected parties
11 68
on the plan of study for undertaking the environmental impact
assessment
(l) Where applicable, any specific information required by the competent
N/A N/A
authority
(m) Any other matter required in terms of section 24(4)(a) and (b) of the Act
N/A N/A
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Environmental Considerations
The Project will adopt the standards and environmental requirements as set out in the Constitution of the
Republic of South Africa, the National Environmental Management Act (Act No. 107 of 1998) as well as the
requirements of the National Environmental Management: Air Quality Act (Act No. 39 of 2004).
Key Findings of the Scoping Report
The report provides a scoping-level identification of potential environmental impacts associated with the
Project, as well as a strategy for how these impacts will be investigated and assessed further in the EIA
Phase. The baseline environmental information provided in this DSR was compiled as a high-level desktop
investigation, and the project information is sourced from existing background information, relevant to
the Project. The preliminary environmental impacts identified in Table 1-2 will be further refined,
calculated and assessed for all the feasible alternatives identified. Mitigation and management measures
will also be suggested by the specialists for all impacts identified. The positive and negative impacts arising
because of the Project have also been summarised in the Table 1-2 overleaf.
It is important to keep in mind that the project set out for EA has already been constructed and has been
operational since 1989. This should mean that no additional negative impacts are expected by the licensing
of the facility.
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Table 1-2: Potential identified impact because of the Proposed Project
ENVIRONMENTAL COMPONENT TYPE POTENTIAL IMPACT SPECIALIST STUDY PLANNED FOR EIA
COMPONENT
Social and Economic Air Quality ❖ Possible presence of emissions which may result in a Air Quality Impact Assessment
Environment nuisance to the local environment;
❖ Possible presence of emissions which may result in a
polluting factor in the local environment;
❖ Health impacts on people in proximity to the project site due
to emissions during operation of the factory.
❖ Ensuring the continued operation of the facility resulting in
job security;
❖ Evaluating the potential possible emissions to the
environment as well as possible mitigation measures.
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Overall Conclusions
At this stage of the project no additional impacts are expected of the licencing of the existing factory. The
factory has been in existence and operational since 1989. No additional activities are planned for the site,
which is envisioned to continue its current levels of production. This would then mean that no new or
additional impacts should be expected. The act of undergoing the required air quality studies would help
Makeean determine the current impact actively occurring on site and as such help the licencing authorities
determine if the required AEL can be awarded.
Way Forward
This DSR has been undertaken with the aim of identifying potential positive and negative impacts on the
environment and gathering comments on concerns and queries from stakeholders. It documents the
process followed, the findings and recommendations of the Scoping Phase study, and the proposed Plan
of Study for the EIA Phase to follow. The overarching objectives of the EIA process will be to:
❖ Prepare integrated sensitivity maps for the study area based on the findings of specialist
assessments as input into the project design process;
❖ Identify and assess the significance of potential impacts associated with the project activities; and
❖ Recommend mitigation and enhancement measures to ensure that the development is
undertaken in such a way as to promote the positive impacts and to minimise the negative
impacts.
The future procedure for this study is as follows:
❖ Submit the finalised Scoping Report to the CA for permission to undertake the EIA Phase of the
project;
❖ Upon the decision to grant or refuse the final Scoping Report, all stakeholders will be notified. If
granted, stakeholders will also be notified of the conditions of the GDRAD for proceeding with the
Environmental Impact Assessment (EIA) Phase of the project;
❖ In the case of approval of the final scoping, execute the Plan of Study for the Impact Assessment
during the EIA Phase of the project;
❖ Incorporate and address comments and issues raised during the consultation period on the
Scoping Report into the EIA, and make changes to the report where relevant;
❖ Make the EIA Report and Environmental Management Programme report (EMPr) available to the
public, stakeholders and authorities;
❖ Finalise the EIA Report and EMPr and submit to the CA; and
❖ Authority review period and decision-making for 107 calendar days.
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Contents:
1 Introduction and Background ................................................................................................... 1
1.1 The History of Makeean Polymers ........................................................................................ 1
1.2 The Processes taking place on site ........................................................................................ 2
1.3 Scoping and Environmental Impact Assessment .................................................................... 2
1.3.1 Applications Relevant to the S&EIA Process ............................................................................ 2
1.3.2 Methodology applied to conducting the Scoping Process ....................................................... 3
1.3.3 S&EIA Timeframes ................................................................................................................... 3
1.3.4 Public Participation Process ..................................................................................................... 4
1.4 Details of the Environmental Consultant ............................................................................... 5
1.4.1 Contact Person and Corresponding Address............................................................................ 5
2 Project Description .................................................................................................................. 7
2.1 Description and Location of the Property .............................................................................. 7
2.1.1 Description of the Properties affected by the Project .............................................................. 9
2.2 Description of the Current Land Uses Applicable ................................................................. 11
2.3 Description of the Activities Currently Undertaken.............................................................. 13
2.4 Environmental Authorisation Application: Reason for EIA ................................................... 14
3 Policy and Legislative Context ................................................................................................ 15
3.1 Listed and Specified Activities............................................................................................. 21
4 The Need and Desirability of the Project ................................................................................ 23
4.1 Job Security ....................................................................................................................... 23
4.2 Pollution Monitoring and Licence Requirements ................................................................. 23
4.3 Conclusion ......................................................................................................................... 23
5 Period for which the environmental authorisation is required ................................................ 25
6 Description of the Process Followed to Reach the Proposed Preferred Site ............................. 26
6.1 The Consideration of Alternatives ....................................................................................... 26
6.1.1 The property on which or location where it is proposed to undertake the activity ..............26
6.1.2 The type of activity to be undertaken ...................................................................................26
6.1.3 The Design and Layout of the Activity...................................................................................27
6.1.4 The Technology to be Used in the Activity ............................................................................27
6.1.5 The Operational Aspects of the activity ................................................................................28
6.1.6 The “No-Go” option ...............................................................................................................28
7 Public Participation................................................................................................................ 29
7.1 Public Participation Process Objectives ............................................................................... 29
7.2 Summary of issues raised by stakeholder’s ......................................................................... 30
7.3 Identification of Stakeholders ............................................................................................. 30
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7.4 Land Claims........................................................................................................................ 31
7.5 Public Participation Materials ............................................................................................. 31
7.6 Stakeholder Consultations .................................................................................................. 32
7.7 Consultation Undertaken as Part of the Final Scoping Phase:............................................... 35
7.8 Consultation with Stakeholders during the EIA Phase .......................................................... 36
8 The Baseline Environment ..................................................................................................... 37
8.1 Climate .............................................................................................................................. 37
8.2 Topography ....................................................................................................................... 39
8.3 Geology ............................................................................................................................. 39
8.4 Soils, Land Capability and Land Use .................................................................................... 41
8.4.1 Soils ........................................................................................................................................41
8.4.2 Land Capability ......................................................................................................................42
8.4.3 Land Use ................................................................................................................................42
8.5 Surface Water and Ground Water ....................................................................................... 43
8.5.1 Surface Water ........................................................................................................................43
8.5.2 Groundwater..........................................................................................................................45
8.6 Fauna and Flora ................................................................................................................. 45
8.6.1 Flora .......................................................................................................................................47
8.6.2 Fauna .....................................................................................................................................47
8.7 Air Quality ......................................................................................................................... 49
8.8 Noise ................................................................................................................................. 50
8.9 Traffic ................................................................................................................................ 50
8.10 Visual................................................................................................................................. 51
8.11 Heritage and Palaeontology ............................................................................................... 51
8.12 Socio-Economic .................................................................................................................. 51
9 Potential Impacts Identified during the Scoping Phase ............................................................ 54
9.1 Methodology for determining the Significance of Environmental Impacts ............................ 54
9.1.1 Part A: Defining Consequence in Terms of Magnitude, Duration and Spatial Scale .............56
9.1.2 Part B: Determining Consequence Rating .............................................................................57
9.1.3 Part C: Determining Significance Rating ...............................................................................57
9.2 Possible Positive and Negative Impacts identified ............................................................... 58
9.3 Cumulative Impacts............................................................................................................ 58
9.4 Application of Possible Mitigation Measure ........................................................................ 58
9.5 Outcome of the Site Selection Matrix. The Final Site Layout Plan ......................................... 59
9.6 Motivation where no Alternative sites were considered ...................................................... 59
9.7 Statement motivating the Preferred Site ............................................................................ 59
10 Plan of Study for the Environmental Impacts Assessment ....................................................... 60
10.1 Alternatives to be considered, including the “No-Go” Option .............................................. 60
10.2 Aspects to be assessed as part of the Environmental Impact Process ................................... 60
10.3 Terms of Reference for Specialist Studies ............................................................................ 60
10.4 Methodology proposed ...................................................................................................... 63
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10.4.1 Assessment of the Duration of significance ...........................................................................63
10.4.2 Stages at which the Competent Authority will be consulted .................................................63
10.4.3 Public Participation to be undertaken during the EIA Phase .................................................64
10.4.4 Tasks to be undertaken during the Environmental Impact Phase .........................................64
10.4.5 Mitigation, Management and Monitoring of Identified Impacts ..........................................65
10.5 Other Information Requirements ....................................................................................... 67
11 Declaration of Independence ................................................................................................. 68
11.1 Undertaking Regarding Correctness of Information ............................................................. 68
11.2 Undertaking Regarding Level of Agreement ........................................................................ 68
12 References ............................................................................................................................ 69
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Appendices
Appendix A: EIA Project Team CV’s
Appendix B: A3 Maps
❖ Locality Map
❖ Land use Plan
❖ Gauteng C-Plan
Appendix C: Public Participation Information
❖ Appendix C1 – Stakeholder Database
❖ Appendix C2 – Land Claims Letters
❖ Appendix C3 – Background Information Document
❖ Appendix C4 – Newspaper Advert
❖ Appendix C5 – Site Notice Report and Map
❖ Appendix C6 – Announcement Notification
❖ Appendix C7 – Application Acknowledgement Letter
❖ Appendix C8 – Stakeholder Correspondence
❖ Appendix C9 – Comments & Response Report
❖ Appendix C10 – Public Participation Plan
Appendix D – Site Photographs
Appendix E – Environmental Screening Tool
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Figures
Figure 1-1: Different phases of S&EIA ........................................................................................................... 3
Figure 2-1: Locality map of the Proposed Project ......................................................................................... 8
Figure 2-2: Land Tenure map surrounding the Proposed Project ............................................................... 10
Figure 2-3: Land use map surrounding the Project area ............................................................................. 12
Figure 2-4: Process Diagram of the Makeean polymer production per reactor unit. ................................. 13
Figure 8-1: Precipitation and Minimum and maximum monthly temperatures for the Project
(https://www.meteoblue.com/en/weather/historyclimate/climatemodelled/pretoria_south-
africa_964137.) .................................................................................................................................... 38
Figure 8-2: Maximum temperatures for Pretoria during the year
(https://www.meteoblue.com/en/weather/historyclimate/climatemodelled/pretoria_south-
africa_964137) ..................................................................................................................................... 38
Figure 8-3: Wind rose for Pretoria during the year
(https://www.meteoblue.com/en/weather/historyclimate/climatemodelled/pretoria_south-
africa_964137). .................................................................................................................................... 39
Figure 8-4: Geological Map of the Project Area. ......................................................................................... 40
Figure 8-5: Soils Map of the Project Area.................................................................................................... 41
Figure 8-5:Figure illustrating the rivers in Gauteng. ................................................................................... 44
Figure 8-6: Project area superimposed on the Gauteng C-plan. ................................................................. 46
Figure 8-7: Vegetation type in and around the Project area ...................................................................... 48
Figure 8-8:Air Quality indicators within Mamelodi for the 29 of February until the 1 of March 2020 (SAAQIS,
2020). ................................................................................................................................................... 49
Figure 8-9: Acceptable Zone Sound Levels for noise in districts (from SANS 10103:2008) ........................ 50
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Tables:
Table 1-1: Structure of the Scoping Report in line with the Appendix 2 of the EIA 2014 Regulations, as
amended. ............................................................................................................................................... vi
Table 1-2: Potential identified impact because of the Proposed Project ...................................................... x
Table 1-1: Details of Environmental Consultant............................................................................................ 5
Table 1-2: Peer Review .................................................................................................................................. 6
Table 2-1: Description of the Directly and Indirectly Affected Properties .................................................... 9
Table 2-2: Property Details ............................................................................................................................ 9
Table 2-3: 21-digit Surveyor General Code for each Farm Portion ............................................................... 9
Table 2-4: Project perspective and technical details................................................................................... 14
Table 3-1: Applicable National Legislation and Guidelines ......................................................................... 16
Table 3-2: Applicable Provincial and Local Policies, Guidelines and By-Laws ............................................. 19
Table 2-5: Listed Activities Triggered by the Proposed Project................................................................... 22
Table 6-1: The advantages and disadvantages of the operation of the Makeean Polymers Factory –
Preferred .............................................................................................................................................. 27
Table 7-1 : PPP activities.............................................................................................................................. 29
Table 7-4: PPP activities during the Draft Scoping Phase ............................................................................ 34
Table 7-5: PPP activities to be undertaken during the Final Scoping Phase ............................................... 36
Table 8-1: Socio-economic baseline information: Gauteng at a glance ...................................................... 52
Table 9-1: Typical tables used to identify and classify the significance of identified impacts .................... 54
Table 9-2: Potential Impacts Identified for the Project ............................................................................... 55
Table 9-3: Consequence Rating Methodology ............................................................................................ 56
Table 9-4: Consequence Rating Methodology ............................................................................................ 57
Table 9-5: Significance Rating Methodology ............................................................................................... 57
Table 10-1: Terms of Reference for Specialist Studies. ............................................................................... 61
Table 10-2: High Level Mitigation Measures for Potential Impacts Identified for the Makeean Project. .. 66
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Abbreviations
ABBREVIATION/ DESCRIPTION
SYMBOL
AQIA Air Quality Impact Assessment
BID Background Information Document
CA Competent Authority/Authorities
CRR Comments and Response Report
CoT City of Tshwane
DALRRD Department of Agriculture, Land Reform and Rural Development
DEFF Department of Environment, Forestry and Fisheries
DoH Department of Health
DSR Draft Scoping Report
EA Environmental Authorisation
EAP Environmental Assessment Practitioner
EIA Environmental Impact Assessment
EMF Environmental Management Framework
TMM Tshwane Metropolitan Municipality
EMPr Environmental Management Programme Report
FSR Final Scoping Report
GDARD Gauteng Department of Agriculture and Rural Development
Ha Hectare
IDP Integrated Development Plan
Km Kilometre
M Metre
NDP National Development Plan
NEMA National Environmental Management Act, 1998 (Act No. 107 of 1998)
NEM:AQA National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004)
NEMLAA National Environmental Laws Amendment Act, 2014 (Act No. 25 of 2014)
PPP Public participation process
RoD Record of Decision
S&EIA Scoping and Environmental Impact Assessment
SDF Spatial Development Framework
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SECTION 2:
The Environmental Authorisation for the Required Atmospheric Emissions
license for the Makeean Polymers Factory
1 Introduction and Background
1.1 The History of Makeean Polymers
Makeean Polymers is a producer of water based emulsion products for a wide range of industries. This
production facility converts an oil-based substance into a water-based chemical. The production of these
products occur at an already existing and operational facility which has been in existence and operational
since 1989. The facility has undergone numerous upgrades since the start of its operation. Currently the
site is composed of a multistorey factory with its own workshop, a multistorey administration block, a
laboratory, multiple store rooms, a packaging and loading area as well as a straining area.
Photo 1-1: Entrance to the administration building Photo 1-2: Entrance to the Polymer Factory
Photo 1-3: Entrance to the Polymer Factory
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1.2 The Processes taking place on site
The factory is built around the production process, with each floor of the factory dedicated to a specific
part of the production. The process starts with the raw material (which is flammable), this is stored
underground. From underground, the raw material is pumped up into a pre-mixer where it is mixed with
other chemicals. From the pre-mixer the material then makes its way to the reactor where it is processed
(heated by steam from the boiler which travels through “jackets” that cover the reactor tanks).The product
then moves to a mixer where the product is finalised. The process converts the oil-based substance into a
water-based non-flammable substance.
Fumes generated during the process are captured in a series of knock-out pots and a condenser where the
fumes are then circled back into the process, to ensure that no dangerous fumes escape the process or
the facility. The knock-out pots return the fumes back into the reactor units and the mixer unit. The only
source of emission from combustion on site is the boiler which uses approximately 300 L of burner fuel
daily. Furthermore, the factory is equipped with a diesel generator on site which is used during the
occasion of load shedding or power outages. This is offset by solar panels to minimise the total output
requirements of the generator.
The factory is fitted with extractor fans which assist with cooling the building. The factory has the following
number of reactors: 4x10 ton, 1x6 ton, 2X5 ton, 1x4 ton and 1X3 ton, which gives a total of 9 different
reactor units of varying sizes. All of these reactor units are heated by the boiler present on site through
the metal jacket system.
1.3 Scoping and Environmental Impact Assessment
1.3.1 Applications Relevant to the S&EIA Process
Kongiwe has been appointed by Gondwana Environmental Solutions (hereafter Gondwana) to undertake
a Scoping and Environmental Impact Assessment (S&EIA) process as part of the Atmospheric Emissions
Licensing (AEL) of the existing Makeean Polymers (Makeean) factory. The S&EIA and specialist studies to
be undertaken will support the applications for the required approvals. The following applications will be
made to the relevant CA for the Project:
1. Application for EA for listed activities triggered in Listing Notices GN R983, GN R984 and GN R9851
published pursuant to the EIA Regulations 2014 (as amended), promulgated in terms of the
National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA), in particular,
Activity 6 of Listing Notice 2; and
2. Application for an Atmospheric Emission Licence (AEL) authorising activities listed in GN R893 of
22 November 2013 published in terms of the National Environmental Management: Air Quality
Act, 2004 (Act No. 39 of 2003) (as amended) (NEM:AQA).
11
These Listing Notices have been amended by GN R327, GN R325 and GN R324 of 7 April 2017
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The period of EA being applied for is undetermined and remains relevant until the polymer factory ceases
to be operational.
The EIA findings, including specialist findings, are used by the applicant and authorities to obtain an
objective view of the potential environmental, social and cultural impacts that could arise during the
operation of the currently active activity. Measures for the avoidance or mitigation of negative impacts
will be proposed and positive impacts will be enhanced.
1.3.2 Methodology applied to conducting the Scoping Process
The outcome of the first phase of the S&EIA is the Scoping Report, which provides the terms of reference
for undertaking the EIA Phase of the project. The figure below indicates the methodology that is applied
in conducting the S&EIA process.
Decision-Making Phase:
EIA Phase:
EIA and EMPr Reports: Authority makes a
Scoping Phase: Studies done on the
Consolidate the findings decision, based on the
Identify potential potential positive and
of the impact findings of the EIA and
positive and negative negative impacts
assessment studies done EMPr Reports, if the
issues to focus the EIA identified during the
during the EIA Phase project is to proceed or
Scoping Phase
not.
Figure 1-1: Different phases of S&EIA
1.3.3 S&EIA Timeframes
The Draft Scoping Report (DSR) will be submitted and made available for a 30-day public review period.
The comments received during this period will be captured in a Comments and Responses Report (CRR)
that will be submitted with this Final Scoping Report.
Once the Final Scoping Report (FSR) has been submitted to the Gauteng Department of Agriculture and
Rural Development (GDARD), which is the Competent Authority (CA), the CA must either accept or reject
the Scoping Report within 43 days. Once confirmation of acceptance has been received from the CA, the
EIA Phase commences and will run for a period of 106 days, in which time stakeholders will be afforded a
30-day period in which to review and comment on the S&EIR documentation.
Upon submission of the Environmental Impact Assessment/Environmental Management Programme
(EIA/EMPr) document the CA will have 107 days to reach a decision on the project Record of Decision
(RoD). The RoD is otherwise referred to as the EA which authorises the activities to proceed (or in this case,
continue). The decision to grant the EA may be appealed (within 20 days) by any party, including the
Applicant, following the process outlined in the National Appeal Regulations (GNR 993 of 8 December
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2014) published in terms of the NEMA.
If significant changes to the EIA/EMPr are required, which were not consulted on during the initial public
participation process, a notice may be submitted to the GDARD stating that the EIA/EMPr will be submitted
within 156 days from date of acceptance of the Scoping Report. During the aforesaid 156-day period,
stakeholders will be afforded a further 30-day period in which to review the amended EIA/EMPr
documentation.
1.3.4 Public Participation Process
The Public Participation Process (PPP) has been designed to comply with the regulatory requirements set
out in the EIA Regulations of 2014 (as amended). The PPP provides the opportunity for communication
between agencies making decisions and the public. This communication can be an early warning system
for public concerns, a means through which accurate and timely information can be disseminated, and can
contribute to sustainable decision-making (IAP2, 2006).
Kongiwe encourages stakeholders to provide input into the S&EIA. The sharing of information forms the
basis of PPP, with an aim to encourage the public to have meaningful input into the decision-making
process from the onset of the project. Stakeholders can become involved in the project in the following
ways:
During the Scoping Phase:
Contribute relevant local
Identify issues of concern Assist in identifying
Verify that issues have been information and knowledge
and suggestions for reasonable alternatives,
accurately recorded to the environmental
enhanced benefits where required
assessment
During the EIA Phase:
Contribute relevant local information Verify that issues have been
Comment on the findings of the
and knowledge to the environmental considered in the environmental
environmental assessments
assessment investigations as far as possible
During the Decision-Making Phase:
Be advised of the outcome of the Competent Authorities decision, and how and by when the decsion can be appealed
The Draft Scoping Report (DSR) will be made available for public comment from (28 August 2020 - 28
September 2020). It is the intention to proceed in accordance with the Directions published by the
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Minister of Forestry, Fisheries and the Environment on 05 July 2020 (GN R650), even though these
Directions are only applicable to Alert Level 3 and accordingly, only electronic copies of the Scoping Report
and Environmental Impact Assessment Report/Environmental Management Programme will be made
available. All stakeholders will be encouraged to download the reports from Kongiwe Environmental’s
website: http://www.kongiwe.co.za/publications-view/public-documents/. A non-technical summary of
the report will be compiled and distributed to stakeholders, in particular to stakeholders with no access
to the internet. Hard copies of the non-technical summary will be distributed through any relevant
community representatives. If required, an electronic copy (CD) of the reports can be made available upon
a request directed to the stakeholder engagement team. To curb the spread of COVID-19, all hard copies
will be enclosed in a plastic folder and sanitised.
1.4 Details of the Environmental Consultant
Kongiwe is a contemporary, problem-solving consultancy specialising in solving real-world environmental
challenges. We pride ourselves in using the latest technology available to realise pragmatic solutions for
our clients. The company was created with the essential intent: ‘To solve environmental challenges for a
world driven towards a sustainable future.’
With offices in both Johannesburg and Pretoria, South Africa, our team of professional Environmental
Scientists are highly trained in various environmental disciplines and have significant, hands-on experience
in an array of projects across numerous industries. The company has extensive environmental and project
management experience in multiple sectors, with significant experience in South Africa, as well as
internationally. Kongiwe focuses on the integration of environmental studies and processes into larger
engineering and mining projects. Moreover, Kongiwe provides clients with strategic environmental
assessments and compliance advice, the identification of environmental management solutions and
mitigation / risk minimising measures throughout the project lifecycle.
1.4.1 Contact Person and Corresponding Address
Details of the Environmental Consultant:
Table 1-1: Details of Environmental Consultant
Name of Practitioner Foord Ceronio, Kongiwe Environmental (Pty) Ltd
Tel No +27 (10) 140 6508
Cell No 072 984 8574
e-mail address fceronio@kongiwe.co.za
Foord Ceronio has an M.Sc. Environmental Management degree from the University of Johannesburg and
is a candidate South African Council for Natural Science Professional (Environmental Management)
(Registration No: 124117). Qualifications in Appendix A.
Foord has experience in the mining industry. His responsibilities range from Environmental impact
reporting, air quality monitoring, Visual Impact Assessments, Closure costing, environmental auditing,
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