PROJECT COMPILED FOR: Rubble Tech (Pty) Ltd. Rubble Tech S24G_Final EA... · PROJECT COMPILED FOR:...

GDARD Reference No. Gaut: S24G/03/12-13/0246

In terms of Section 24G of the National Environmental Management Amendment Act, Act No. 8 of 2004;

and in terms of Section 5(1) of the National Environmental Management: Waste Act, Act No. 59 of 2008.

PROJECT COMPILED FOR: Rubble Tech (Pty) Ltd

PROPERTY DESCRIPTION: A Portion of the Remaining Extent of Portion 16 of the Farm Lombardy 36-IR, Modderfontein

REPORT NUMBER: RUB-LON_002-13

DATE: November 2013

COMPILED BY: Umhlaba Environmental Consulting CC Candis Lubbe

ACKNOWLEDGEMENTS

Umhlaba Environmental Consulting CC would like to acknowledge the following staff from Rubble Tech Pty (Ltd) for providing the required information that assisted in the compilation of this report:

- Gerardus Gomes-Sebastiao (Director)

COPYRIGHT WARNING Unless otherwise stated, the copyright in all text and other matter (including the manner of presentation) is the exclusive property of Umhlaba Environmental Consulting CC. It is a criminal offence to reproduce and / or use any matter, technical procedure and / or technique contained in this document, without written consent, unless it is being reproduced for the purpose in which it was intended.

AUTHOR’S CONTACT DETAILS Umhlaba Environmental Consulting CC Tell: (011) 791 3389 P.O. Box 731504 Fax: (011) 791 3384 Fairland, 2030 E-mail: [email protected]

Environmental Assessment Report Rubble Tech (Pty) Ltd November 2013 Page ii

TABLE OF CONTENTS

1 INTRODUCTION ............................................................................................................. 5

1.1 REPORT OUTLINE ...............................................................................................................................5

2 LEGAL FRAMEWORK ..................................................................................................... 8

2.1 SECTION 24G APPLICATION ................................................................................................................8

2.2 OTHER RELEVANT LEGISLATION AND /OR GUIDELINES ..........................................................................8

2.2.1 National legislation............................... .............................................................................8 2.2.2 By-laws for City of Johannesburg .................. .................................................................9 2.2.3 Other Documentation ............................... .........................................................................9

2.3 OTHER PERMITS .................................................................................................................................9

3 MOTIVATION FOR SECTION 24G APPLICATION .............................................................. 10

4 SITE ASSESSMENT ...................................................................................................... 11

4.1 LOCATION ....................................................................................................................................... 11

4.2 SIZE OF THE PROPERTY ................................................................................................................... 11

4.3 SITES SURROUNDING THE PROPERTY ............................................................................................... 11

4.4 STATUS QUO OF THE SITE ................................................................................................................ 11

5 PROJECT DESCRIPTION ............................................................................................... 20

5.1.1 Background to the Site ............................ ...................................................................... 20 5.1.2 Process Activities................................. .......................................................................... 20 5.1.3 Throughput of Facility (Processing)................ ............................................................. 21 5.1.4 Capacity of the facility (storage) ................ ................................................................... 23 5.1.5 Supporting Services................................ ....................................................................... 23

5.2 INFRASTRUCTURE AND STRUCTURES IN RELATION TO COMMENCEMENT OF THE ACTIVITIES ................ 24

5.3 REHABILITATION UPON CLOSURE ..................................................................................................... 28

5.4 SITE VISIT PHOTOS .......................................................................................................................... 28

5.4.1 Waste Storage Areas ............................... ...................................................................... 29 5.4.2 Process Activities................................. .......................................................................... 32 5.4.3 Supporting Services................................ ....................................................................... 35 5.4.4 Other Aspects of the Site. ........................ ..................................................................... 36

6 PUBLIC PARTICPATION PROCESS ................................................................................ 39

6.1 DESCRIPTION OF THE PROCESS UNDERTAKEN .................................................................................. 39

6.2 IDENTIFIED INTERESTED AND AFFECTED PARTIES (I&APS) ................................................................ 39

6.3 NOTIFICATIONS ................................................................................................................................ 39

6.3.1 Written Notification .............................. .......................................................................... 40 6.3.2 Newspaper Advertisement ........................... ................................................................. 45 6.3.3 Site Notice ....................................... ................................................................................ 48

6.4 SUMMARY OF ISSUES RAISED BY I&APS .......................................................................................... 49

7 ENVIRONMENTAL IMPACT ASSESMENT .......................................................................... 56

7.1 CRITERIA AND METHODOLOGY OF IMPACT ASSESSMENT ................................................................... 56

7.2 IMPACT ASSESSMENT ...................................................................................................................... 56

7.2.1 Process Activities................................. .......................................................................... 57 7.2.2 Storage of Waste .................................. .......................................................................... 59 7.2.3 Supporting Services................................ ....................................................................... 59 7.2.4 Summary of Impact Assessment ...................... ............................................................ 61

8 ENVIRONMENTAL MANAGEMENT PLAN ......................................................................... 62

8.1 ENVIRONMENTAL MANAGEMENT PLAN ............................................................................................. 62

8.2 WASTE MANAGEMENT PLAN ............................................................................................................ 69

8.3 STORM WATER MANAGEMENT PLAN ................................................................................................ 70

8.4 AIR QUALITY MANAGEMENT PLAN ................................................................................................... 71

Environmental Assessment Report Rubble Tech (Pty) Ltd November 2013 Page iii

8.4.1 Management Measures ............................... ................................................................... 71 8.4.2 Monitoring: Dust Fallout .......................... ...................................................................... 71

9 EMERGENCY RESPONSE PLAN .................................................................................... 73

10 DECLARATION ............................................................................................................ 74

10.1 RESPONSIBLE PERSON / ENVIRONMENTAL CONTROL OFFICER ....................................................... 74

10.2 SIGNED SUBMISSION ..................................................................................................................... 74

11 APPENDICES .............................................................................................................. 75

11.1 LANDOWNER CONTRACT AGREEMENT ........................................................................................... 76

11.2 INTERESTED AND AFFECTED PARTIES REGISTER ............................................................................ 77

11.3 BACKGROUND INFORMATION DOCUMENT ....................................................................................... 78

11.4 COMMENTS RECEIVED FROM I&APS .............................................................................................. 79

11.5 FORMAL COMMUNICATION ............................................................................................................. 80

LIST OF FIGURES Figure 4.1: Status and aesthetics of the Rubble Tech site and its surroundings. ..................................... 12 Figure 4.2: Road network surrounding the Rubble Tech site. ................................................................... 14 Figure 4.3: Locality map indicating Rubble Tech in relation to major towns and roads. ........................... 17 Figure 4.4: Locality map of the Rubble Tech site indicating the surrounding land uses (zoning information). ................................................................................................................................................ 18 Figure 4.5: Google Earth Image illustrating prominent features and absence of surface water and other environmental features within 500m proximity of the rubble site. .............................................................. 19 Figure 5.1: Examples of (A) new waste and (B) historical waste. ............................................................. 20 Figure 5.2: Process Flow diagram of the Rubble Tech Operation. ........................................................... 21 Figure 5.3: Overview of Rubble Tech processing operation (photo taken, 2012). .................................... 23 Figure 5.4: Google Earth images illustrating the various physical footprints of all development structures on the site PRIOR to June 2011. ................................................................................................................ 25 Figure 5.5: Google Earth images illustrating the various physical footprints of all development structures on site POST June 2011. ........................................................................................................................... 26 Figure 5.6: Google Earth images illustrating the various physical footprints of all development structures on site CURRENTLY. ................................................................................................................................. 27 Figure 7.1: Impacts associated with process (crushing and screening) activities. .................................... 58 Figure 7.2: Impacts associated with waste storage activities and supporting services. ........................... 60 Figure 8.1: Stormwater management plan. ............................................................................................... 70

LIST OF TABLES

Table 1.1: Requirements for public participation. .........................................................................................5 Table 1.2: Additional information required for the compilation of the Environmental Assessment Report. .6 Table 4.1: Immediate land use surrounding the site. ................................................................................ 11 Table 4.2: Climate data for Johannesburg. ............................................................................................... 13 Table 5.1: Estimated quantities of product generated from building waste. ............................................. 23 Table 6.1: A summary of all comments raised by I&APs. ......................................................................... 49 Table 7.1: Summary of impacts associated with the operation without mitigation measures. .................. 61 Table 8.1: Management measures for all the impacts identified (Section 7.2) associated with the operation. .................................................................................................................................................... 62 Table 8.2: Additional management measures not associated with identified impacts. ............................. 66 Table 8.3: Minimum requirements for environmental noise monitoring. ................................................... 68 Table 8.4: Sources waste generated at the Rubble Tech site. ................................................................. 69 Table 8.5: Sources and management measures for dust generation at the Rubble Tech site. ................ 71 Table 8.6: Minimum requirements for dust fallout monitoring. ................................................................... 71

Environmental Assessment Report Rubble Tech (Pty) Ltd November 2013 Page iv

LIST OF PHOTOGRAPHS Photo 4.1: London Road intersection from the M54. ................................................................................. 14 Photo 4.2: Clulee Road intersection from the M54 east. ........................................................................... 15 Photo 4.3: Clulee Road intersection from the M54 west. .......................................................................... 15 Photo 4.4: Entrance to the Pure Magic Compost and Rubble Tech Site. ................................................. 16 Photo 5.1: Storage area for ‘New Waste’ (most new waste has been removed off site). ......................... 29 Photo 5.2: Historical Waste 1 (North West portion of site) viewed from M54 Route................................. 30 Photo 5.3: Historical Waste 1 (North West portion of site) viewed from London Road. ........................... 30 Photo 5.4: Historical Waste 2 (South East portion of site) viewed from M54 Route. ................................ 31 Photo 5.5: Historical Waste 2 (South East portion of site) viewed from Pure Magic Compost. ................ 31 Photo 5.6: Crusher. ................................................................................................................................... 32 Photo 5.7: Process screens. ..................................................................................................................... 33 Photo 5.8: Various stockpiles. ................................................................................................................... 34 Photo 5.9: Mobile offices. .......................................................................................................................... 35 Photo 5.10: Access gate............................................................................................................................ 35 Photo 5.11: PRIMEDIA Bill Board (present on site). ................................................................................. 36 Photo 5.12: N3 Highway (adjacent to site). ............................................................................................... 36 Photo 5.13: Pure Magic Compost (adjacent to site). ................................................................................. 37 Photo 5.14: Pick n Pay (immediately adjacent to site). ............................................................................. 37 Photo 5.15: Reshaping (sloping) of historical waste in terrace design (31 August 2012). ........................ 38 Photo 5.16: Rehabilitated slope (Photo 5.15) of historical waste in terrace design (02 October 2013). .. 38

ABBREVIATIONS

CoJ City of Johannesburg

DWA Department of Water Affairs

EAP Environmental Assessment Practitioner

EAR Environmental Assessment Report

GDARD Gauteng Department of Agriculture and Rural Development

GPS Global Positioning System

I&AP Interested and Affected Parties

NEMA National Environmental Management Act

NEM:WA National Environmental Management: Waste Act

NEM:AQA National Environmental Management: Air Quality Act

PPE Personal Protective Equipment

PPP Public Participation Process

RoD Record of Decision

SWMP Storm Water Management Plan

Environmental Assessment Report Rubble Tech (Pty) Ltd November 2013 Page 5

1 INTRODUCTION

1.1 REPORT OUTLINE In order for the Department (i.e. the Gauteng Department of Agriculture and Rural Development (GDARD), the designated competent authority) to make an informed decision regarding the above mentioned application, the process as set out in Table 1.1 and Table 1.2 has been followed.

Table 1.1: Requirements for public participation.

A. Public Participation Reference in Report a. The unlawful development must be advertised in the local

newspaper and on site in accordance with the attached advertising guideline.

Section 6.3.2 Section 6.3.3

b. The adjacent landowners as well as occupiers of neighbouring properties and ‘tenants and residents’ associations, must be informed directly, in writing, of the application for rectification and they must be invited to register as I&APs.

Section 6.3.1

c. I&APs must be given a thirty (30) day period within which to lodge any objections and/or comments to the application for rectification.

Section 6.1

d. The Environmental Component of the relevant District or Metropolitan Municipality as well as all other relevant Organs of State must be formally invited to register as I&APs and be provided a thirty (30) day period within which to comment. A copy of their comments and/or objections must be submitted along with the information requested above.

Section 6.1 Section 6.3.1 Appendix 11.4

e. Proof of the public participation of the notice, placement of the notice on site as well as notification to the adjacent landowners, tenants and residents’ associations must be submitted to the Department.

Section 6.1 Section 6.3

f. Details in respect of the following must be submitted to the Department: − A list of all persons, organisations and organs of state that were

registered as interested and affected parties in terms of section 57 of Government Notice R 543, in Government Gazette No. 33306 of 18 June 2010.

− A summary accurately reflecting issues raised by I&APs, the date of receipt of and any response of the EAP to those issues.

− Any objections and/or comments raised by I&APs together with an indication as to how the objections and comments were/will be addressed. Copies of all correspondence in this regard are required.

Section 6.2 Section 6.4 Appendix 11.2


In addition to the above, the appointed EAP has compiled an Environmental Assessment Report (this report) and includes the following additional information (as requested) listed in Table 1.2.

Table 1.2: Additional information required for the compilation of the Environmental Assessment Report.

B. Additional Information Reference in Report 1. A signed affidavit stating that the landowner knows and understands

the activities on site and has given permission to utilise the site, must be submitted as part of the report.

Appendix 11.1

2. A motivation of why your application in terms of Section 24G of the NEMA should be considered favourably, with specific reference to the sites environmental sensitivity.

Section 3

3. A locality map clearly indicating the location of the site. Section 4 4. A site layout plan clearly indicating the following:

− The location and physical footprint of all infrastructure and structures that occurred on the site prior to 03 July 2006 01 June 2011 (see note below).

− The location and physical footprint of all development and structures on site that occurred after 03 July 2006 01 June 2011 (see note below).

NB NOTE: As stipulated in the application form acti vities commenced from 01 June 2011, therefore the informat ion provided in this section shows location and physica l footprint of all infrastructure and structures that occurred on the site prior to 1 June 2011 (and not 03 July 2006).

Figure 5.4 Figure 5.5 Figure 5.6

5. A map clearly indicating the proximity of the site to the closest surface water bodies and other sensitive environmental features within 500m radius from the site. All environmental features must be clearly indicated and defined.

Figure 4.5 Section 4.4

6. A clear description of the activity applied for, including but not limited to: − A detailed description of the activities that are undertaken on site

in terms of this project, it is advisable to include all aspects in order to avoid the need for amendments and thus at a later stage delays in S24G process;

− The size of the property (in square meters). − Discussion on the management of stockpiles on site before

processing. − The method used for processing (i.e process flow). − A detailed discussion on all current possible environmental

impacts associated with the operation and decommissioning of the activity, taking into consideration the environmental , physical, social, economic, geographical and cultural aspects of the environment.

− Discussion on any other permit(s) obtained regarding the activities. Copies of such permit(s) must be attached to the report.

Section 5 Section 5.1.1 Section 5.1.2 Section 4.2 Section 5.1.2 Section 5.1.3 Figure 5.2 Section 7.2 Section 5.3 Section 2.3

7. Discussion on impact of the activity on the ambient air quality of the site and the surrounding area, including any form of air quality management system currently in pace; if there is none, an air quality management plan must be complied and submitted as part of the report.

Section 8.4

8. A Waste Management Plan (“WMP”) during the operational phase of the development must be compiled and submitted as part of the requested report in order to comply with the requirements of the department. The WMP must include but not be limited to: − The quantity of waste processed per day. − The storage areas if any. − Duration fop storage if any.

Section 8.2

9. A description of the storm water management system currently operational on site. A storm water management plan for the site must

Section 8.3


be submitted should there be none currently existing. 10. An Environmental Management Plan (“EMP”) must be compiled and

submitted to this Department for approval. The EMP must highlight all possible environmental impacts associated with the operation and decommissioning phases of the activity as well as mitigation and/or rehabilitation measures for each of eth identified impacts and all sensitive environment within the vicinity of the site (if any).

Section 8.1

11. The name and contact details of the person or Environmental Control officer responsible for monitoring compliance of EMP in (9) above.

Section 10.1

12. An emergency response plan for the operation of the activity, including an indication of training of personnel in the management of the site.

Section 9

13. An identification of all legislation and guidelines that have been considered in preparation of all conclusions and recommendations made.

Section 2

14. A signed submission by Rubble Tech (Pty) Ltd that: a. He understands the content of the Environmental

Management Plan and will be ultimately held responsible for compliance with the requirements and procedure thereof.

b. No similar activities would be undertaken in future with the Gauteng province without prior approval from GDARD as well as Rubble Tech (Pty) Ltd commitment to comply with South African environmental legislations.

c. No other unlawful activities [(listed under R 718 promulgated in terms of section 19 and 69 of the NEM: WA (Act No. 59 of 2008) and (listed under the sub-regulations of Government Notice R544, R545, and R546 promulgated in terms of Section 24 and 24D of the NEMA)], have commenced or are continued with on the property in question.

Section 10.2

15. A4 (210mm x 297mm) colour photographs of the following: − Area taken 10m and 50 m away from North, Eastern, Southern

and Western direction; − All structures associated with the activity(s). − Fire fighting equipment on site (if any).

Section 5.4


2 LEGAL FRAMEWORK

2.1 SECTION 24G APPLICATION This section describes the legal framework of the Section 24G Application and explains the background as to how this activity commenced in contravention of the legislation. In terms of Section 19(1), the National Environmental Management: Waste Act (NEM:WA), Act No. 59 of 2008, the Minister has published a List of Waste Management Activities which have, or are likely to have a detrimental effect on the environment (GN R 718 of 3 July 2009 ). Regulation 3 of the GN R 718 of 3 July 2009 states that: A person who wishes to commence, undertake or conduct an activity listed under Category A, must conduct a basic assessment process, as stipulated in the environmental impact assessment regulations made under Section 24(5) of the National Environmental Management Act (NEMA), (Act No. 107 of 1998) as part of a waste management licence application. In addition to the above, Section 20(b) of the NEM:WA, states that: no person may commence, undertake or conduct a waste management activity except in accordance with a waste management licence issued in respect of that activity. The following waste management activities in terms of Category A of GN R 718 of 3 July 2009 under NEM:WA are applicable to this application: • Activity 1: The storage, including the temporary storage, of general waste at a facility that has the

capacity to store in excess of 100m3 of general waste at any one time, excluding the storage of waste in lagoons.

• Activity 5: The sorting, shredding, grinding or bailing of general waste at a facility that has the capacity to process in excess of one tone of general waste.

• Activity 7: The recycling or re-use of general waste of more than 10 tons per month. • Activity 14: The disposal of inert waste in excess of 25 tons and with a total capacity of 25 000 tons. • Activity 15: The disposal of general waste to land covering an area of more than 50m2 but no less

than 200m2 and with a total capacity not exceeding 25 000 tons. Section 24F of NEMA refers, whereby it is an offence to commence or to continue with a listed activity unless the competent authority has granted an environmental authorisation for the activity. However, Section 24G makes provision to rectify the unlawful commencement or continuation of the activity. Rubble Tech commenced with the above listed activities from 1 July 2011 , without prior authorisation and is in the process of undertaking the Section 24G application procedure to rectify the unlawful commencement. Currently, processing and operation activities have ceased on site since February 2013, pending the outcome of the aforementioned application. 2.2 OTHER RELEVANT LEGISLATION AND /OR GUIDELINES The following is a broad list of environmental legislation compiled for guidance to assess how environmental laws are applicable to the Rubble Tech :

2.2.1 National legislation

• The Constitution of the Republic of South Africa Ac t, Act No.108 of 1996. - Section 24 explains the constitutional right to an environment that is not harmful to our health and

wellbeing and to have the environment protected. • National Environmental Management Act, Act No 107 o f 1998.

- Principles of NEMA. - Listed activities. - Commencement and rectification.

• National Environmental Management: Air Quality Act, Act No. 39 of 2004.

- National Ambient Air Quality Standards. - Listed activities for Air Emissions Licence (AEL).


• National Environmental Management: Waste Act, Act N o. 59 of 2008. - General duties. - Declaration of priority wastes. - Industry waste management plans. - Licensing of listed waste management activities.

• National Water Act, Act No. 36 of 1998.

- Objects and purposes. - Prevention and remedying effects of pollution.

• Spatial Planning and Land Use Management Act, Act N o. 16 of 2013

- Municipal Land use planning.

2.2.2 By-laws for City of Johannesburg

• Emergency Services - Fire prevention; Burning of refuse; Fire protection including building construction; Sprinkler

systems; Emergency exits; Fire-fighting equipment; Evacuation plans; Water supply; Use, handling and storage of flammable substances; Transport, supply and delivery of dangerous goods; Fire brigade services; Offences and penalties.

• Encroachment on Property

- Encroachment which means any physical object which intrudes on or over municipal property, or property which the Council has control over or other property in respect of which a servitude or other property right has been registered in favour of the Council.

• Public Health

- Hazards and nuisances; Hazardous uses of premises; Storage of waste; Offences and penalties;

• Public Roads and Miscellaneous - Cleaning and repairing on public roads; Excavations; Stormwater and watercourses;

Obstructions; Control of traffic; Throwing stones; Offences and penalties.

• Waste Management - Information system; Municipal service; Provision and usage; Commercial services including

building waste; Licence applications; Prohibition of littering and dumping; Offences and penalties.

2.2.3 Other Documentation

• National Waste Management Strategy (2013). • Draft Integrated Development Plan (IDP) for the City of Joburg (2013/16): Implementing the Joburg

2040 Strategy. • Consolidated Johannesburg Town Planning Scheme (2011), City of Joburg Municipality. • Integrated Waste Management Plan (2011), City of Joburg Municipality • Integrated waste Management Policy (2011), City of Joburg Municipality. • Linbro Park Urban Design Framework Plan (June, 2010).

2.3 OTHER PERMITS Rubble Tech is not in possession of any other environmentally related permits, licences or authorisations pertaining to their business activities.


3 MOTIVATION FOR SECTION 24G APPLICATION

Motivation regarding the legal interpretation The main motivation for this Section 24G application was due to lack of understanding of the legal definitions and capacity in terms of the Waste Act (NEM:WA). Rubble Tech was unaware that the processing of material in this manner was constituted as “recycling waste”. In addition, the activities regarding storage and disposal capacities were misunderstood as the acceptance of new waste (disposal) is not stored in large quantities before it is processed. Through this application process it has come to Rubble Tech’s attention that all the waste on the site must be included and therefore all potential activities have been included. It must also be considered that the Waste Act is still considered a new act that has only come into effect during 2010, and attaining the understanding of the Act is still in process by many operators. Rubble Tech is not an obvious role player to the waste management industry and it was not thought of as an applicable Act until evaluation and interpretation of the definitions. Motivation regarding the historical waste It must be considered that prior to Rubble Tech operating on the site; the property already contained large quantities of illegally tipped building waste. Rubble Tech cannot be liable for waste present prior to June 2011 when Rubble Tech initiated their operations. Motivation based on responsible environmental manag ement The Rubble Tech operation is a small operation with little/small environmental impacts and offers an effective solution to waste management of construction waste: • The operation is located on a disturbed footprint. No vegetation or soil structure was affected from the

commencement of the activities. • The operation supports waste minimisation by recycling waste. • The operation does not accept any hazardous waste or waste that cannot be processed. Only useful

recyclable building and construction waste is processed into useable products that are marketable. • The entire crushing and screening process is clean whereby there are no additives or hazardous

products of any kind used in the process. • The processing plant operation does not require the use of water during processing. • The products that are generated from processing are “re-used” in the construction industry. • Adequate storm water control measures are in place. • Dust suppression measures are in place i.e conveyors are closed to prevent dust from emanating. • A commitment has been made (within this document) to carry out dust monitoring. • Reshaping (sloping) of historical waste in terrace design has been undertaken to prevent rock falls

and erosion and to encourage rehabilitation. • The provision of saleable products avoids utilisation of virgin materials. Motivation with reasoning as a solution to construc tion waste in the area The illegal tipping of waste in the area is currently a problem due to the limited landfill space available for its disposal. This causes illegal dumping and tipping on several properties that are vacant. Therefore the Rubble Tech site offers a solution whereby construction waste generated by developers may be disposed of in a legally acceptable manner (post legalisation). Motivation based on City of Joburg IDP The Draft Integrated Development Plan (IDP) for the City of Joburg (2013/16) has made provision for a “Builders Crushers Plant” as part of a programme for waste management and minimisation. It should be considered that Rubble Tech is in line with this IDP. Motivation based on socio-economic benefits Cost of Materials: Since the products have been subjected to processing and are not virgin materials, the products available for sale are cheaper than raw construction materials. This allows smaller developers the opportunity to afford materials for construction. Employment: Although the operation is small, jobs are will be provided (post legalisation) to twelve employees that are employable with mining (aggregate) related experience.


4 SITE ASSESSMENT

4.1 LOCATION Rubble Tech (Pty) Ltd is located within the administrative “Region E” of the City of Joburg (CoJ) metropolitan municipality within the Gauteng province. The site is situated on the Corner of London Road and the N3 (refer to Figure 4.3), on a portion of the remaining extent of portion 16 of the farm Lombardy 36-IR, Modderfontein (refer to Figure 4.4). This is approximately 7km south of the Buccleuch interchange and 3km north of Edenvale when travelling in the N3 highway. 4.2 SIZE OF THE PROPERTY According to the title deed [T0IR00000000003600016], the entire size of the property [Remaining Extent of Portion 16 of the farm Lombardy 36-IR] is 101 hectares, which is a vast piece of land. However, only a portion of the remaining extent of portion 16 of the farm Lombardy 36-IR is being utilised for by Rubble Tech , as indicated in Figure 4.5 and is approximately 2.5 hectares in size. 4.3 SITES SURROUNDING THE PROPERTY The immediate surrounding land utilisation surrounding the property of the Rubble Tech site is indicated in Table 4.1. See Figure 4.5 for a visual indication.

Table 4.1: Immediate land use surrounding the sit e.

Direction from the Site Land utilisation North London Road and N3 intersection. North East M54 route and vacant. East M54 frontage roads. South East Pure Magic Compost (plant nursery) and Pick n Pay. South Pure Magic Compost (composting area). South West N3 highway immediately. Adjacent to the N3 highway includes a

construction site yard for road maintenance. West N3 highway immediately. Adjacent to the N3 highway includes another

construction site yard for road maintenance North West Vacant land located between the N3 highway and London Road off ramp.

4.4 STATUS QUO OF THE SITE The site was historically utilised for the dumping of large/bulky construction waste by unknown contractors. Since June 2011, Rubble Tech erected a small scale processing plant and commenced activities such as processing the inert waste (described further below in Section 5). The current site consists of various quantities of building rubble with processing equipment located on top of the waste piles. No other infrastructure or natural features occur on this site. Currently no activities are taking place as processing activities were suspended in February 2013 as a result of the undertaking of the Section 24G process (refer to Appendix 11.5 for all formal communication regarding the process). Regional Socio-economic Structure: The following demographics were referenced from the draft IDP (2013/2016) and are based on the 2011 Census: • Population: The total population in the City of Johannesburg is 4,434,827 individuals (total population

increase from 2001 to 2011 is 37%) and is the leading gateway for migrants from other provinces or countries. Region E has a population density of 11.8%, ranked 5th of the seven administrative Regions (A-G).

• Housing: Households increased by 37% comparable with the population growth. There was a reduction in the number of households living in informal dwellings by 3.9%.

• Inequality: In 2011, whites earn on average 5.3 times more than black Africans, 2.5 times for than Coloureds and 1.4 times more than Indians / Asians.

• Unemployment: The city’s official unemployment rate is 25% and is 29.8% in South Africa. • Skills Development: Literacy rate is expected to rise, due to a huge increase in those with a matric

exemption; a reduction in residents with only Gr10/Std8/Form3; and the number of Masters and PhDs increased by 02.%.

• Service Delivery: - Water: 96.7% of the population has access to piped water less than 200m away. - Sanitation: Access to sanitation is 94.6%. - Electricity: 90.8% have access to electricity for lighting.


- Waste: Refuse collection is currently 95.3%. • Local Economy: The city has the largest economy in the country, contributing 17% of national GDP

and approximately 47% of Gauteng’s economy. • Economic Sectors: Current primary economic sectors include:

- Finance and business services. - Community services. - Manufacturing. - Trade.

Status / Aesthetics of the site: Rubble Tech is located in an urban area within the City of Joburg. The surrounding properties include residential, business and national road infrastructure. Other land uses surrounding the site comprise special land use, industrial, residential and includes a rehabilitated landfill site north to north-west of the site. Located immediately adjacent to Rubble Tech site is a plant nursery with composting activities (refer to Figure 4.1). Ecology and Biodiversity: The site is completely disturbed with no natural vegetation or any biodiversity concern.

Figure 4.1: Status and aesthetics of the Rubble Te ch site and its surroundings. Topography and Soil: Based on a site assessment the natural topography and soil composition is completely altered due to the placement of material onto the site. Sites of Archaeological or Cultural Interest: There is no indication of any archaeological or cultural aspects (including graves) and none of these aspects were identified on the site during the various site inspections which have taken place during 2012 to 2013. Surface water: There are no surface water bodies located within close proximity (500m radius) to the site, refer to Figure 4.5. Climatology: The city of Joburg has a sunny climate, with the summer months (October to April) characterized by hot days followed by afternoon thundershowers. In the winter months (May to September) the days are sunny with cold nights. Temperatures are usually fair to mild with an average maximum daytime temperature in January of 25.6 °C, dropping to an average maximum of around 16 °C in June. Occasional frost may be experienced in winter when temperatures drop below freezing at night. Table 4.2 illustrates the record of temperatures and average rainfall for the Johannesburg.

Surrounding urban area

Plant Nursery and Composting

Rubble Tech Operation Billboard located on N3

Waste Waste


Table 4.2: Climate data for Johannesburg 1.

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Year

Record high

°C 35.4 33.5 31.9 29.3 26.4 23.1 24.4 26.2 30.0 32.2 32.9 32.4 35.4

Avg. high °C 25.6 25.1 24.0 21.1 18.9 16.0 16.7 19.4 22.8 23.8 24.2 25.2 21.9

Daily mean °C 19.5 19.0 18.0 15.3 12.6 9.6 10.0 12.5 15.9 17.1 17.9 19.0 15.5

Average low

°C 14.7 14.1 13.1 10.3 7.2 4.1 4.1 6.2 9.3 11.2 12.7 13.9 10.1

Record low °C 7.2 6.0 2.1 0.5 −2.5 −8.2 −5.1 −5.0 −3.3 0.2 1.5 3.5 −8.2

Precipitation

mm 12 9 91 54 13 9 4 6 27 72 11 10 713

Avg.

precipitation

days (≥ 0.1

mm)

15.9 11.2 11.9 8.6 2.9 2.0 1.0 2.1 3.8 9.8 15.2 14.9 99.3

Mean

monthly

sunshine

hours

250.1 224.8 238.8 236.9 276.0 266.9 283.9 284.1 280.8 269.5 248.7 263.9 3,124.4

Air quality: According to the State of the Air Quality Report (October 2007), the City of Johannesburg has six air quality monitoring stations (namely Alexandra, Buccleuch, Delta Park, Jabavu, Newton, and Orange Farm) that measure air quality (PM10, NO2, SO2, O3 & CO). Buccleuch is the closest to the Rubble Tech site (See Figure 4.2). PM10 is the greatest concern in the CoJ and frequently exceed the air quality guidelines as measured at all the stations. The highest concentrations emanate from areas such as Alexandra, Jabavu and Orange Farm. Although there are no standards for comparison of the CO concentrations, these are especially elevated at Buccleuch. Air quality is worse in winter months due to temperature inversions and calm winds that promote stagnation of the air. Roads and Traffic: The entrance to the Rubble Tech site (refer to Photo 4.4) is shared with Pure Magic Compost and is located 350m from the London Road intersection (Photo 4.1) and 330m from the Clulee Road intersections (Photo 4.2 and Photo 4.3). The M54 route is a dual carriageway and has a speed limit of 80 km per hour and are one way routes east and west as indicated in Figure 4.2. London Road is indicated north and the N3 high way runs south west of the site.

1 Data obtained from http://en.wikipedia.org/wiki/Johannesburg which was sourced from the South African Weather Service (SAWS), retrieved on 6 March 2010.


Figure 4.2: Road network surrounding the Rubble Te ch site.

Photo 4.1: London Road intersection from the M54.

Entrance

N3

M54 Route

Clulee Rd

350 m 330 m

London Rd


Photo 4.2: Clulee Road intersection from the M54 e ast.

Photo 4.3: Clulee Road intersection from the M54 w est.


Photo 4.4: Entrance to the Pure Magic Compost and Rubble Tech Site.


Figure 4.3: Locality map indicating Rubble Tech in relation to major towns and roads.

Edenvale

Randburg Rubble Tech (Pty) Ltd

Kempton Park

Rivonia N1

Buccleuch Interchange

N3


Figure 4.4: Locality map of the Rubble Tech site i ndicating the surrounding land uses (zoning informa tion).

RRRRRRRRRRRRUUUUUUUUUUUUBBBBBBBBBBBBBBBBBBBBBBBBLLLLLLLLLLLLEEEEEEEEEEEE TTTTTTTTTTTTEEEEEEEEEEEECCCCCCCCCCCCHHHHHHHHHHHH ((((((((((((PPPPPPPPPPPPTTTTTTTTTTTTYYYYYYYYYYYY)))))))))))) LLLLLLLLLLLLTTTTTTTTTTTTDDDDDDDDDDDD


Figure 4.5: Google Earth Image illustrating promin ent features and absence of surface water and other environmental features within 500m proximity of the rubble site.

500m

500m

500m

500m

Residential Areas

Business & Commercial Use

Rehabilitated landfill site


5 PROJECT DESCRIPTION

5.1.1 Background to the Site The Rubble Tech operation began in June 2011 on a portion of the remaining extent of portion 16 of the farm Lombardy 36-IR. Occupation by Rubble Tech onto this property came into being through an agreement between Pure Magic Compost cc owned by Jon Roberts (currently occupying the adjacent property being used as a nursery but unbeknown at the time) and Rubble Tech owned by Gerardus Gomes-Sebastiao. Rubble Tech was led to believe that Pure Magic cc was leasing the property in question from the City of Johannesburg. Rubble Tech therefore assumed that the City of Johannesburg was in agreement with Pure Magic to process and remove the building waste material on the site. However through the Section 24G Application process it materialised that Pure Magic is unrelated to the property in question and an agreement between the property owner, City of Johannesburg and Rubble Tech is required (refer to Section 11.1). In the past building rubble has been illegally tipped onto the property in question (immediately adjacent to Pure Magic Compost cc) from unknown contractors during development projects (Figure 5.1 (B)). Based on the size and type of the bulky material on site, it has been speculated that it originates from deep substrates that was generated through blasting methods. Over time additional unwanted building waste material accumulated on the site. There has been a vested interest in this waste building material and previous attempts by others (prior to Rubble Tech ) have been made to process this waste. Rubble Tech took occupation of the site and set up equipment required for processing operations in June 2011.

5.1.2 Process Activities Rubble Tech processes waste building rubble and inert waste historically accumulated on the site, into resalable products to the construction industry. Rubble Tech further accepts construction waste in addition to the historical accumulation present on the site (Figure 5.1), depending on its quality for use in mixing and processing with the existing inert material.

Figure 5.1: Examples of (A) new waste and (B) hist orical waste. Refer to Figure 5.2 for the process flow of the Rubble Tech operation which must be read in conjunction with the following activities: Acceptance of waste New construction waste is accepted from sub-contractors in the construction industry which enter the site through a controlled access entrance. If the material is of a quality that can be accepted and has a processing value, the new waste is permitted to be tipped at the Rubble Tech site and the waste transporters leave the site. Rubble Tech does not accept any waste that cannot be utilised for processing and resale. Storage and stockpiles New waste material is stored in appropriate stockpiles until processing is required. Existing waste on the site is excavated or sorted according to the quality of the potential grade material.

A B


Excavation and/or breaking The historical inert construction waste must be excavated from the existing substrate in order to be sorted and stockpiled for processing when required. Large rocks or boulders may require breaking (using a mechanical hammer) which will generate noise. Crushing and screening The waste material (either new or existing or both) is loaded by excavators into dump trucks and tipped into the jawcrusher feed. The size of the material is reduced by the jawcrusher and then by the cone crusher. Conveyors are used to transfer the material from the crushers to stockpiles or for further processing and screening. The crushed rock is then screened and sold as various products (size particles) which generally include sand and course material. The output (products) may vary according to the quality of the material, customer requirements ad market needs. Equipment Mobile equipment used in this operation include: excavators, dump trucks, mobile crusher and mobile screens and conveyors.

New Waste

Historical Waste Excavate & Sorting

Stockpiles

Crushing

ScreeningSaleable

Products

Figure 5.2: Process Flow diagram of the Rubble Tec h Operation.

5.1.3 Throughput of Facility (Processing) The size of the site that Rubble Tech occupies is approximately 2.5 hectares. Refer to Figure 5.3 for an overview of the operation which indicates the general occupational size of Rubble Tech , and is divided in to following operational areas: • Stockpile areas. • Processing plant. • Mobile offices. • Access entrance. The remainder of the site is comprised of the historical waste, which is material that Rubble Tech uses to process along with smaller quantities of new building waste (such as excavated uncontaminated earth). The estimated quantities that are generated as final saleable product are indicated in


Table 5.1.


Table 5.1: Estimated quantities of product generat ed from building waste.

Saleable Products Estimated Quantities (cubes / month)

13mm 200 19mm 300 Builders mix 100 G5 Subbase 2000 G6 Filling 700 Pit sand 1500 River Sand 300 Total 5100

Figure 5.3: Overview of Rubble Tech processing ope ration (photo taken, 2012).

5.1.4 Capacity of the facility (storage) The storage of waste occurs in two main forms on site: • Contained within stockpiles before processing. • As a historical substrate. The size of the stockpiles varies according to the amount of new waste accepted and generated within a specified period, although it is generally controlled according to the quantities that can be processed. At no time will Rubble Tech accept (for processing and disposal) more than 25 000 tons of new waste at any point in time. The historical waste has not been quantified; although if it is disposed of via processing activities then the amount of waste on site at any one time will adhere to the limit set by new waste.

5.1.5 Supporting Services Rubble Tech makes use of the following supporting services for the operation and for use by their employees. • Mobile Offices: Temporary mobile containers are used as office space for the conducting of all

administrative functions. • Access Gates: A lockable access gate is utilised on site to ensure that no further illegal tipping may

occur after operational hours. The entrance is used for access to the office and for receiving of raw material (new waste).

• Potable water: A tap is located on site for drinking purposes.

Historical waste material substrate

Product

Pure Magic Compost Processing operation

Excavated material

Mobile offices Waste material

Entrance


• Chemical Toilets: Portable chemical toilet(s) are hired for use by the employees (currently not observed on site).

• Equipment: Mobile equipment used in this operation include: excavators, dump trucks, loader and crusher and mobile screens and conveyors. Some or all of this equipment may be hired and/or owned.

• Transport: Rubble Tech is not involved in any transportation activities associated with accepting or

selling the waste materials/products.

5.2 INFRASTRUCTURE AND STRUCTURES IN RELATION TO COMMENCEMENT OF THE ACTIVITIES The Rubble Tech operation began in June 2011 on the property. No construction activities took place prior to operation as the operation is completely mobile. Previous Structures/Infrastructure (Prior to June 2 011) Figure 5.4 shows the first available image (December 2010) recorded on Google Earth prior to June 2011. From the image it is evident that no infrastructure or structures pertaining to Rubble Tech was present on the site. The following is evident on site prior to the commencement of Rubble Tech operation: • Historical waste. • Bill board. These facilities were not used for any activities associated with Rubble Tech . Structures/Infrastructure (Post June 2011) Since Rubble Tech’s commenced operations from June 2011, the existing structures mentioned above remained on site with the addition of the following development: • New (additional) construction waste material. • Mobile processing equipment:

- Crusher. - Screens. - Conveyors. - Excavator and loading trucks.

• Mobile offices. • Access gate. Refer to Figure 5.5 for a visual representation of the structures/development that has occurred from June 2011. Current Footprint of the Site (2013) No additional structures or development have occurred on the site since 2011. However, at the beginning of 2013, a compliance notice (dated 12th February 2013) was issued in terms of Section 31L of NEMA, Act 107 of 1998 and Rubble Tech was directed that to cease in operating this area as storage, processing facility and waste disposal site. Therefore the following activities were undertaken: • Most of the moveable product(s) and/or waste was removed off site. • The mobile processing equipment was moved to a central location for security reasons and fenced

off. • The mobile offices and toilets were removed. Refer to Figure 5.6 for a visual overview of the existing structures/infrastructure. Structures/Infrastructure and Activities that Trigg ered Authorisation Despite the development described above, the following activities triggered the need for environmental authorisation: • The storage, including the temporary storage, of general waste at a facility that has the capacity to

store in excess of 100m3 of general waste at any one time. • The sorting, shredding, grinding or bailing of general waste at a facility that has the capacity to

process in excess of one tone of general waste. • The recycling or re-use of general waste of more than 10 tons per month. • The disposal of inert waste in excess of 25 tons and with a total capacity of 25 000 tons. • The disposal of general waste to land covering an area of more than 50m2 but no less than 200m2

and with a total capacity not exceeding 25 000 tons.


Figure 5.4: Google Earth images illustrating the v arious physical footprints of all development struc tures on the site PRIOR to June 2011.

25 December 2010

Billboard

Site Boundary Historical Waste


Figure 5.5: Google Earth images illustrating the v arious physical footprints of all development struc tures on site POST June 2011.

13 June 2011

05 June 2012

Billboard

Historical Waste Site Boundary

New Waste

Historical Waste

New Waste

Historical Waste Site Boundary

Historical Waste

Product

Product

Processing Plant

Processing Plant

Billboard


Figure 5.6: Google Earth images illustrating the v arious physical footprints of all development struc tures on site CURRENTLY.

14 July 2013

Historical Waste 2

Site Boundary

Historical Waste 1

Processing Plant

Billboard

Cleared Area


5.3 REHABILITATION UPON CLOSURE In the event that the Rubble Tech operation is instructed to permanently cease activities and close, the following must occur as a minimum: • All newly accepted building rubble accepted within the last 3 months prior to ceasing activities must

be removed entirely from the property. • Any other material or building rubble that can be re-used may also be removed from the property. • Material remaining on site must be shaped and sloped to alleviate visual impacts and to minimise the

potential for future erosion occurring. • All processing equipment and its associated parts that formed part of the operation are to be

dismantled and removed from the site. • The temporary office (containers) must be removed off site, including any platform or foundations

associated with the office. • Any other waste, such as domestic waste from employees that may have accumulated either

intentionally or as a result of windblown litter management areas must be removed and disposed of at a general waste landfill site. This excluded the waste intended for processing/recycling associated with the activity described in this report.

5.4 SITE VISIT PHOTOS The images contained herein were taken during a site visit carried out on the 2nd October 2013 . The photos are grouped according to the following areas: • Waste Storage Areas. • Process Activities. • Supporting Services. • Other Aspects of the Site. These images can viewed in conjunction with the process flow in Figure 5.2.


5.4.1 Waste Storage Areas

Photo 5.1: Storage area for ‘New Waste’ (most new waste has been removed off site).

Historical Waste 1

‘New Waste’ Storage Area (None currently stored)

Environmental Assessment Report November 2013

Photo 5.2: Historical Waste 1 (North West portion of site) viewed from M54 Route.

Photo 5.3: Historical Waste 1 (North West portion of site) viewed from London Road.

Environmental Assessment Report November 2013

Photo 5.4: Historical Waste 2 (South East portion of site) viewed from M54 Route.

Photo 5.5: Historical Waste 2 (South East portion of site) viewed from Pure Magic Compost.

Pure Magic Compost (RE of portion 2 Erf 332 of farm Lombardy East)

Historical Waste 2


5.4.2 Process Activities

Photo 5.6: Crusher.


Photo 5.7: Process screens.


Photo 5.8: Various stockpiles.

Historical Waste (Excavated Earth)

Processed Waste to be sold


5.4.3 Supporting Services

Photo 5.9: Mobile offices.

Photo 5.10: Access gate.


5.4.4 Other Aspects of the Site.

Photo 5.11: PRIMEDIA Bill Board (present on site).

Photo 5.12: N3 Highway (adjacent to site).


Photo 5.13: Pure Magic Compost (adjacent to site).

Photo 5.14: Pick n Pay (immediately adjacent to si te).


Photo 5.15: Reshaping (sloping) of historical wast e in terrace design (31 August 2012).

Photo 5.16: Rehabilitated slope (Photo 5.15) of hi storical waste in terrace design (02 October 2013).

Reference point: Gauteng Freeway Sign

Reference point: Gauteng Freeway Sign


6 PUBLIC PARTICPATION PROCESS

6.1 DESCRIPTION OF THE PROCESS UNDERTAKEN In undertaking an Environmental Impact Assessment (EIA) or Basic Assessment (BA), that is carried out in terms of the National Environmental Management Act (NEMA), Act No. 107 of 1998, as amended, a formal public participation process is undertaken as detailed in Regulation 54-57 of the EIA Regulations, 2010. However in undertaking a Section 24G Process – which is a rectification process for commencing an activity without undertaking an EIA / obtaining Environmental Authorisation – the public participation process as mentioned above is not required in the same way. Instead, the public participation process required is prescribed by the relevant competent authority, in this case by the GDARD, and is detailed in Table 1.1 of Section 1.1 of this report. Therefore, Interested and Affected Parties (I&APs) were identified (refer to Section 6.2) and then notified of the project (refer to Section 6.3). I&APs were provided with an opportunity to object and/or comment on the application for rectification. The official comment period of thirty (30) days was provided to the I&APs from: • 30 August to 30 September 2013 (although comments received in October were also accepted) where I&APs were able to raise and submit any objections and/or comments on the application to our offices for consideration and inclusion in this report. After the public participation process was undertaken as stipulated above, the Environmental Assessment Report (this report) was compiled containing proof of the public participation process as well as other requested information for submission to the GDARD. 6.2 IDENTIFIED INTERESTED AND AFFECTED PARTIES (I&APS) I&APs were identified according to the requirements as set out by the GDARD (refer to Section 1.1). The following I&APs were identified: • The adjacent landowners as well as occupiers of neighbouring properties:

- Remainder of Portion 67 of the Modderfontein 35 IR (Heartland Properties (Pty) Ltd. - Holding 131 Linbro Park Agricultural Holdings (Chamber Lane Properties 3 (Pty) Ltd. - Remainder of Portion 16 of the farms Lombardy 36 IR (City of Joburg Property Company). - Portion 29 of the farm Lombardy 36 IR (South African National Roads Agency Limited). - Longmeadow Business estate Ext 10 Township (Pick n Pay Retailers Ltd.) - Portion 2 of Erf 322 Lombardy East Township (South African National Roads Agency Limited

and Pure Magic Compost cc). • District or metropolitan municipality and all other organs of state :

- City of Johannesburg local municipality. - Ward Councillor of Section 32 (Long Meadow Business Estate, Far East Bank,

Modderfontein, Linbro Park). - Ward Councillor of Section 81 (Lombardy East).

• Any other potential I&AP groups : - Linbro Park Community Association. - Greater Lombardy East Residents Association (GLERA). - Long Meadow Business Estate. - Primedia Advertising

A complete list of all the registered I&APs is attached in Appendix 11.2. 6.3 NOTIFICATIONS I&APs were notified in writing by means of the following: • Written notifications (Section 6.3.1). • Advertisement in the newspapers (Section 6.3.2). • Site notice (Section 6.3.3) placed up at the site. The notifications were compiled in accordance with the guidelines provided by the GDARD. In addition a Background Information Document (BID) was provided along with the notification (Appendix 11.3).


6.3.1 Written Notification A copy of the following written notice was sent via registered post to the surrounding landowners and occupiers, relevant organs of state; residents asso ciations; and other potential I&APs :


Proof of written notifications sent via registered letter :


A copy of the following written notice was sent via email to the surrounding landowners and occupiers, relevant organs of state; residents associations; a nd other potential I&APs :


6.3.2 Newspaper Advertisement The following notice was published in the Bedfordview and Edenvale News, 28 August 2013 :


The following notice was published in the North Eastern Tribune, 30 August 2013 :


The following notice was published in the Alex News, 30 August 2013 :


6.3.3 Site Notice Two site notices were placed up 1) on the boundary of the site and at the 2) entrance access gate and were displayed for the thirty (30) day period from 30 August to 30 September 2013 .


6.4 SUMMARY OF ISSUES RAISED BY I&APS A summary of all the issues and/or concerns that were received from I&APs are presented in Table 6.1 below. A brief response and/or reference where the comment is addressed is also provided. Copies of the full submissions can be viewed in Appendix 11.4.

Table 6.1: A summary of all comments raised by I&A Ps.

Comment / Concern Response / Reference in Report A Greater Lombardy East Residents Association (GLERA)

Joyce Abrahams – Committee Member 1. We the Residents would require the construction

of a secure, suitably high wall around the site, to ensure that rock and other objects do not fall onto the Road, damaging vehicles and pedestrians.

Since Rubble Tech commenced operations (June 2011) at no point has rocks or other objects been placed in a manner that result in them falling off site and damaging adjacent roads. It is not economically feasible to construct a high wall around the premises. In addition, the property does not belong to Rubble Tech and acquiring permission to do this would require landowner consent.

2. That dust is controlled by watering- down operations or by other suitable means.

Dust suppression measures have been suggested as a management measure (Section 8.1).

3. That noise is kept to a minimum. Noise is kept to a minimum by operating during normal business hours (Section 8.1).

4. Processing of building waste and rubble takes place during normal office hours.

Operational hours are suggested to be carried out during normal business hours (Section 8.1).

B W & L Consultants Liselle van Niekerk – Consultant

Heartland Properties (Pty) Ltd requested W & L Consultants Cc to submit comments on their behalf. The following represents issues and concerns that Heartland Properties (Pty) would like the Consultant to address in the Section 24G Application:

1. Noise: the anticipated increase in noise levels due to the processing activities must be monitored by the applicant. Should the noise levels exceed relevant thresholds, it would be the responsibility of the Applicant to implement mitigation measures to mitigate the noise levels.

Noise monitoring has been included in the Environmental Management Plan (Section 8.1).

2. Dust: dust levels must be monitored and adequate dust suppression methods must be in place to mitigate dust fall out.

Dust monitoring and suppression have been included in the Environmental Management Plan (Section 8.1).

3. Potential leaching from materials stored in laydown area: waste must be screened. Any waste coated in harmful substances should not be permitted on site. Such waste should not be processes on site. It must be removed to a licenced waste disposal site.

No potential leaching is anticipated. No hazardous waste will be accepted on site. Only non-hazardous waste that is useful to re-process will be accepted. Refer to the Environmental Management Plan (Section 8.1).

4. Increase in heavy vehicles on London Road: a traffic study should be submitted as part of the rectification application. The traffic study must assess the impact of the increase in heavy vehicles on London Road.

A traffic impact study is not required as the number of trucks/heavy vehicles that dispose of construction waste at the Rubble Tech site is low i.e. 12 of trucks a day.

5. Condition of London Road: Spillages of material, soil etc. on London Road must be monitored. The applicant must ensure that the road is kept free of any debris/material.

Cleaning up of any spills on the road is included as a management measure in the Environmental Management Plan (Section 8.1).

6. Rehabilitation of the area during and after decommissioning of the activity: a rehabilitation plan must be drafted and approved by GDARD.

Rehabilitation has been included (Section 5.3). Although at this stage a rehabilitation plan is not required (due to the liability of the historical waste).


Comment / Concern Response / Reference in Report The above-mentioned comments will be

forwarded to Donald Thobela of the Section 24G Unit at GDARD.

Comment noted.

C Chamber Lane Properties 3 Pty Lt d Matt Jackson

1. Objection to granting of rectification and environmental authorisation (S24G/03/12-13/0246). 1.1 Chamber Lane Properties 3 Pty Ltd (“CLP”)

wishes to object to the granting of rectification in terms of section 24G of the National Environmental Management Act, 1998 (“NEMA”) as amended and the granting.

Objection noted.

1.2 CLP3 further wishes to be registered as an interested and affected party to this application.

Refer to Appendix 11.2.

1.3 CLP3 submits this objection in our capacity as the registered owner of ERVEN 50-55,58 and 63, Linbro Park Ext 86 and holdings 64, 65 1/66 RE 66,68,69,70,71,73,74,75,RE 76 and 1/76,Linbro Park A>H which properties are located to the immediate north east of the unlawful operation. The locality plan enclosed under Annexure “A” refers.

Location of property in relation to the site is noted. Annexures referred to here can be viewed in Appendix 11.4.

1.4 CLP3 is developing the 50ha Meadowview Business Estate, a clean industry commercial precinct upon the above mentioned properties. The photographs in Annexure “A” refer.

Meadowview Business Estate development is acknowledged. Annexures referred to here can be viewed in Appendix 11.4.

1.5 The Meadowview Business Estate has catalysed the redevelopment of Linbro Park as envisioned in the city of Johannesburg approved Linbro Park Urban Development Framework, 2010 and has included the upgrading the public road network, installation of new bulk infrastructure and improvement of the public environment on behalf of the City of Johannesburg.

Linbro Park redevelopment is acknowledged. This framework document is included in Section 2.2.3. The CoJ has also envisaged a “Builders Crushers Plant” as part of the Integrated Development Plan (2013/2016) to be able to accommodate the building rubble and construction waste that is currently being illegally tipped in various places, due to limited landfill space for this waste type.

1.6 Over the 5 to 7 year development period an estimated 4000 to 6000 construction related jobs will be created in close proximity to Alexandra. Once fully developed the Meadowview Business Estate shall support an estimated 5000 permanent jobs.

Comment noted.

1.7 The unlawful building waste and excavated earth processing and storage creates pollution, compromises the general amenity of the Meadowview Business Estate clean industry commercial node and infringes on the environmental rights of the current and future residents of the surrounding Linbro Park medium to high density residential area.

An impact assessment has been undertaken in Section 7.

2 Request to refuse granting rectification and environmental authorisation. 2.1 Use and occupation of RE/PTN 16/Lombardy

36-IR has not been authorised by local authority. The local authority have been informed and comment has on the application has been invited.

2.1.1 The Southern extent of RE/PTN 16/Lombardy 36-IR has been zoned as Agricultural in terms of the Sandton Town Planning Scheme of 1980, which town planning scheme is administered by the city of Johannesburg. This land use zoning does not permit the use of RE/PTN 16/Lombardy 36-IR for the processing, storage,

This point regarding zoning is acknowledged. Again it must be noted that prior to Rubble Tech operation, exiting (historical) waste has been tipped onto the site. Rubble Tech will request the landowner (CoJ) to ensure that the land is appropriately zones.


Comment / Concern Response / Reference in Report disposal and sale of building waste or excavated earth.

2.1.2 The city of Johannesburg, the owner of the southern extent of RE/PTN 16/Lombardy 36-IR, has not granted authorisation to Rubble Tech Pty Ltd (the applicant), or a third party, to occupy the southern extent of RE/PTN 16/Lombardy 36-IR.

A compliance notice has been issued by the competent authority to Rubble Tech to cease all activities and to submit an environmental assessment report (containing requested information) in order for a decision to be made regarding this application. 2.1.3 In light of 2.1.1 and 2.1.3 above, the city of

Johannesburg has initiated legal action against Rubble Tech Pty (the applicant) to terminate the unauthorised use of land unlawful occupation of the city of Johannesburg owned RE/PTN 16/Lombardy 36-IR.

2.1.4 The unauthorised use and illegal occupation of the southern extent of RE/PTN 16/Lombardy by Rubble Tech Pty Ltd contravenes section 26 (1) NEM:WA which states: “no person may dispose of waste, or knowingly or negligently cause or permit waste to be disposed of, in or on any land, waterbody or at any facility unless the disposal of that waste is authorised by law.

All activities on site have ceased, and the Section 24G application has been submitted as a rectification of commencement of activities without prior authorisation.

2.2 Unlawful operation generates pollution. 2.2.1 The unlawful operation generates high level of

dust and noise pollution which have an adverse effect on the human health and wellbeing as defined in section 1 (xxiv) (iii) of NEMA which states: “pollution means any change in the environment caused by noise, odour, dust or heat emitted from any activity, including the storage or treatment of waste or substances, construction and provision of services, whether engaged in by any persons or an organ of state, where that change has an adverse effect on human health or well-being or on the composition, resilience and productivity of natural or managed ecosystems or on materials useful to people”.

Dust and noise pollution impacts have been considered in the Environmental Management Plan (Section 8.1).

2.2.2 The granting of environmental authorisation in terms of NEM:WA, and the associated waste management license in terms of Section 49 of NEM: WA would be contrary to section 2 (a) (v) of NEM:WA which states: “the objects of this Act are to protect health, well-being and the environment by providing reasonable measures for preventing pollution and ecological degradation”.

Without Rubble Tech or any other processing company on site to crush the waste, the existing (historical) waste would remain on site.

2.3 Negative impacts on high levels of dust pollution. 2.3.1 The continued release of dust pollution will have

the following negative social, economic and environmental impacts on the operation of the food distribution and high tech pharmaceutical distribution business in operation on adjoining properties.

Dust pollution impacts have been considered in the Environmental Management Plan (Section 8.1), which specifically includes monitoring requirements and dust suppression measures. It must be noted that the PM10 levels are already high in the absence of Rubble Tech’s operation.

2.3.1.1 Reduce the usable lifecycle of the air filtration system that the food and pharmaceutical distribution businesses are required to install to meet the air quality control standards set by the


Comment / Concern Response / Reference in Report authorities which regulate the operation of such businesses.

2.3.1.2 Dust pollution adversely effects the health and wellbeing of the employees of the neighbouring clean industry businesses and pedestrians who walk past the unlawful operation; and

2.3.1.3 Degrades and compromises the quality of the food and pharmaceutical products, which material are useful to people, stored within the neighbouring distribution facilities.

2.4 Unlawful operation may be processing hazardous waste. 2.4.1 The building waste processed, stored and sold

from the unlawfully occupied RE/PTN 16/Lombardy 36-IR includes materials sourced from demolished buildings which may contain traces of Asbestos Waste.

No hazardous waste (inclusive of asbestos waste) is to be accepted onto site. Only waste that is considered useful for reprocessing will be accepted. Waste that is brought to site must be accompanied by a waste manifest document that appropriately classifies the waste.

2.4.2 Asbestos waste is classified as a hazardous waste in terms of section (2) (b) of Annexure (1) of the waste classified and management Regulations ( Government Notice 35572 of 2012) gazetted in terms of section 69 of NEM:WA.

2.4.3 The processing of hazardous waste will adversely impact on the environmental rights of:

2.4.3.1 the current and future occupants, and their employees, of the Meadowview Business Estate clean industry commercial node: and

2.4.3.2 The current and future residents of the broader Linbro Park area which has been planned as a medium to high density residential area in terms of the city of Johannesburg approved Linbro Park Urban Development Framework 2010.

2.5 Storage of building waste and excavated earth contravenes Section 21 of NEM:WA. 2.5.1 The open air manner in which building waste

and excavated earth has been stored on the southern extent of RE/PTN 16/Lombardy 36 IR contravenes section 21(c)and (e) of NEM:WA which sates: S21 “any person who stores waste must at least take steps, unless otherwise provided by this Act, to: S21 (c) ensure that the waste cannot be blown away. S21 (e) ensure that pollution of the environment and harm to health are prevented.

Dust suppression measures have been included as part of the Environmental Management Plan in Section 8.1. No hazardous waste (inclusive of asbestos waste) is to be accepted onto site. Only waste that is considered useful for reprocessing will be accepted.

2.5.2 The open air storage of building waste, which may contain hazardous asbestos waste, and excavated has the following negative impacts:

2.5.2.1 Reduces the operational lifecycle of the air filtration system which have been installed by the neighbouring clean industry businesses.

2.5.2.2 Compromises human health and wellbeing: and 2.5.2.3 The negative visual impact compromises the

general amenity of the clean industry commercial node and surrounding medium to high density residential area.

2.6 Risk to safety and wellbeing of motorists travelling on the N3 highway. 2.6.1 The unlawful operation in occupation on the

southern extent of RE/PTN 16/Lombardy 36-IR is situated to the south east of the N3 Highway/London Road interchange.

Management measures regarding the management of rocks and vegetation establishment have been included in the Environmental Management Plan (Section


Comment / Concern Response / Reference in Report 2.6.2 Large mounds of excavated earth and large

rocks have been created to the immediate east of the N3 Highway. These waste materials are positioned approximately 5m to 10m above the roadway of the south bound lane of the N3 Highway. Photograph 1 below refers.

8.1). References to photos mentioned here can be viewed in Appendix 11.4.

2.6.3 The placement of excavated earth and large rocks and the operation of heavy machinery in close proximity to the southbound lane of the N3 Highway pose a significant risk to the safety and wellbeing of motorists travelling along the N3 Highway.

2.7 Increase of traffic congestion and risk to safety of motorists on M54 Frontage Roads. 2.7.1 The unlawful operation has taken direct access

from the M54 Frontage Roads, which roads fall under the jurisdiction of the City of Johannesburg.

The existing entrance to Pure Compost Magic is being utilised as an access point which comes out on the M54.

2.7.2 This access does not comply with the road safety standards which govern the use of the roads in the city of Johannesburg or the legislation governing the safety standards of south Africans roads.

2.7.3 The delivery and collection of building waste and excavated earth from the unlawful operation results in heavy vehicles making dangerous turning movements into oncoming traffic which poses a risk to the safety of pedestrians and the motorist travelling along the M54 Frontage Roads. Photograph 2 below refers.

From June 2011 through to February 2013 (when Rubble Tech ceased operations) there was no records of any traffic incidents associated with the operation. Management measures are indicated in Section 8.1 to minimise the likelihood of traffic incidents occurring.

2.7.4 The use of this noncompliant access generates traffic congestion on the M54 Frontage Roads and the N3 Highway/ London Road interchange.

SANRAL have been notified (See Section 6.2 and Appendix 11.2) although no comments have been received.

3 Request to issue instruction in terms of Section 24G(2)(a) of NEMA.

Rubble Tech has the right to make such application for rectification and for a decision to be made based on the information submitted.

3.1 In light of the above, Chamber Lane Properties 3 Pty Ltd wishes to request that the Gauteng Department of Agriculture and Rural Development:

3.1.1 Refuse the granting of a waste management license in terms of section 49 (1) (b) of the National Environmental Waste Act of 2008; and

3.1.2 Issue an instruction in terms of section 24G (2) (a) of the National Environmental Act, 1998 to Rubble Tech Pty Ltd to terminate the unlawful building waste and excavated earth processing, storage and disposal operation and rehabilitate the southern extent of RE/PTN 16/Lombardy 36-IR.

D Linbro Park Community Association Spencer Tarr – Chairman

Kindly be advised that we hereby confirm that we are an Interested and Affected Party in terms of the relevant legislation applicable and would appreciate your confirming that we are so recognized, failing which we will be obliged to take the appropriate action to be so recognized in terms of the Act. We note the Application for Rectification lodged by Rubble Tech (Pty) Ltd in terms of Section 24G of the NEM Act and formally place on record that we object to such rectification on, inter alia, the following grounds:

Objection noted.


Comment / Concern Response / Reference in Report 1. The site is not conducive to an operation of this

nature which involves the storage of earth, rock, general waste and other materials which before, during and post processing causes excessive dust, pollution and other harmful materials to invade nearby properties which include Alexandra, Linbro Park and Long Meadow.

Prior to Rubble Tech operating the site, it was used for disposal of construction waste. Rubble Tech will implement measures to monitor and reduce dust generation from the site (Section 8.1).

2. We are aware that the current road infrastructure adjoining this operation is totally inadequate and the continued use of this land for present purposes which involves large trucks and other vehicles constitute a further burden and danger to current road users of the R54.

SANRAL have been notified (See Section 6.2 and Appendix 11.2) although no comments have been received.

3. The entire operation is unsightly and a hideous blot in the vicinity of up-market business premises in Long Meadow and on the Southern Boundary of Linbro Park.

Prior to Rubble Tech operating the site, it was used as an illegal dumping site. Rubble Tech is controlling the dumping of waste. Should Rubble Tech not be allowed to operate the site in future then it is anticipated that illegal dumping will resume which will result in a visual impact.

The authorities can’t seriously consider allowing this abomination to continue unchecked within the above-mentioned communities. Any Environmental Study which supports this Application should be seriously questioned. The LPCA reserves its rights to take any administrative decision which condones this continued operation on review to the appropriate High Court. Kindly acknowledge and we look forward to your earliest response.

Comment noted.

E The Linbro Association Nico Nel - Chairman

My thoughts are a bit conflicting and ambivalent: 1. Rubble disposal is a heck of a problem. If their

site were to accept building rubble for processing and resale would be preferable to it being dumped in Linbro.

The Rubble Tech site is envisaged to be a solution and an opportunity to the dumping of waste in the area.

2. Soil is needed for the rehabilitation of the Linbro Park dump. This not permitted to have any rocks or stones. It has to be friable so hat plants will grow in it. PIKITUP are having a look at the types of soil being removed currently from the construction sites with a view to it being diverted to the Linbro Dump for rehabilitation purposes. Michelle Nel and I took PIKITUP on a site-meeting trip to explore my idea of converting the site into a Private Nature Reserve with maybe a hotel on its Southern Portion as an amendment to the 2007 END use plan. There was considerable buy-in from the PIKITUP officials present. This has also been raised at the last Monitoring Committee Meeting and good initial support will help reduce the toxicity of the groundwater) and the DWAF official saw merit. If the project does take off, it would mean the Linbro Dump would be very well secured and become an asset rather than a liability for the area – and Johannesburg at large. Maybe we can leverage Rubble Tech to support the project by diverting suitable soil types to the Linbro

This is potential to discuss the needs of Linbro Dump with Rubble Tech .


Comment / Concern Response / Reference in Report Dump for rehabilitation.

3. There is going to be a lot of construction some day when the PWV3 is constructed. Rubble Tech is a bit of an eyesore at present but does serve a useful function.

It is anticipated that with permission from the CoJ, the site may be potentially utilised for further construction projects in the area. The visual aspects of this operation are recognised and may be alleviated to a lesser degree by implementation of the management measures in the Environmental Management Plan (Section 8.1).

On balance, we are not objectors so much as interested parties.

Comment noted.

F City of Johannesburg Metropolitan Municipality Environment, Infrastructure and Services Department Impact Management and Compliance Unit Tshilidzi Tshimange – Senior Specialist: Environmen tal Impact Management

The following comment was received 25th November 2013: I understand the frustrations, unfortunately we had an administrative challenge this side and due to that you application is still under review. Please note that you will be getting your comments very soon.

Adequate time has been provided for comment: • Initial public participation period: 30

August – 30 September 2013. • Review of Environmental Assessment

Report: 24 October to 24 November 2013.

Due to the deadline stipulated by GDARD for the submission of this report on the 26 November 2013 , no additional time can be provided, however any comments received will be forwarded to GDARD as soon as they are received. In addition it must be noted that a time extension has not been requested as due process has been followed and the applicants standing cost of the site must also be considered.


7 ENVIRONMENTAL IMPACT ASSESMENT

The potential social and environmental impacts associated with the unlawful activities have been identified and assessed. Management and mitigation measures to address the identified impacts are discussed in the Environmental Management Plan in Section 8. 7.1 CRITERIA AND METHODOLOGY OF IMPACT ASSESSMENT In order to identify activities which may require management measures to mitigate any potentially negative impact on the baseline environment of the site, a screening level environmental impact assessment is required. This impact assessment will consider all possible environmental impacts for each of the activities described in Section 5 . When determining the significance of an impact and whether management measures are required, the following criteria were considered: • Intensity. • Spatial extent. • Duration. • Nature. • Probability. • Frequency. For each of the activities the following environmental aspects have been considered where applicable : • Socio-economic structure. • Status / aesthetics of the site. • Archaeological and cultural heritage. • Topography, Soil and Geology. • Ecology & Biodiversity. • Surface water. • Groundwater. • Air quality. • Noise disturbance. • Interested and affected parties. Only those aspects that may be impacted by Rubble Tech’s activities have been detailed. Where it has been deemed to have an insignificant impact, the environmental aspect has not been elaborated on. The definitions used to rank the different categories of significance are as follows: Insignificant impacts are defined when there is no environmental, heritage or socio-economic impacts expected during non-invasive activities.

Positive impact is an impact which has only a positive influence on either environmental or social and cultural receptors, and usually has no negative impacts associated with activities that have a positive impact.

Low significance is one that neither environmental nor social and cultural receptors will be adversely affected by the impact. Management measures may be proposed for low significant impacts in order to ensure that the significance of the impact remains low.

Medium significance is the impact resulting from any activity that will require additional measures to ensure that the impact does not result in adverse environmental / cultural damage.

High significance is an impact that either environmental or social and cultural receptors could potentially be adversely affected by the activities. The precautionary approach will be adopted for all high significant impacts and all possible measures will be taken to avoid the impact.

7.2 IMPACT ASSESSMENT The negative and positive impacts assessed in this section has already occurred and will therefore be assigned two assessment ratings, namely the impact rating assigned to the current status (without mitigation) and the impact significance after the management measures have been implemented (with mitigation). The re-evaluation of the significance rating is provided in Section 8.


7.2.1 Process Activities Development of Infrastructure No impact was identified for the development of any of the infrastructure because the structures are mobile and able to be dismantled. Also it must be noted that the impact assessment will only consider current impacts not impacts that may have occurred in the construction phase, as this has already been completed. Accepting New Construction Waste The acceptance of new construction waste means that additional waste will be permitted to enter the site. Acceptance of such waste at a process facility such as Rubble Tech is considered a positive impact because the alternative method of disposal or illegal dumping is considered an adverse impact on the environment. In addition, Rubble Tech requires new waste of varying material to be able to mix it with existing (or historical construction waste). Excavation and/or Breaking The historical inert construction waste must be excavated from the existing substrate in order to be sorted and stockpiled for processing when required, this generates dust and will contribute to a decreased air quality. Large rocks or boulders may require breaking which will generate noise. Loading and Stockpiling The new and historical construction waste is loaded into trucks and transported to the relevant stockpiles until processing is required. These activities generate dust from handling of the waste material. Refer to Section 1.1.1 for the impacts associated with storage. Crushing and Screening The waste material (either new or existing or both) is loaded from the stockpiles (or is taken directly from excavation) by the excavators into dump trucks and tipped into the jawcrusher feed. The size of the material is reduced by the jawcrusher and then by the cone crusher. Dust may be generated during tipping and crushing, and noise is associated with crushing and screening. The conveyors are used to transfer the material from the crushers to the product stockpiles or for further processing and screening. The conveyors are enclosed to act as dust suppression measures. Resale of Saleable Products The various products (size particles) are sold to the construction industry and the type of products may vary according to the quality of the material, customer requirements ad market needs. Due to the material having been recycled the products are cheaper than virgin construction raw materials. Employment of Local Labourers The process activities utilise approximately 12 employees to run the operation.


Waste Minimisation (+)

E&B: Air Quality (-)

L&S: Air Quality (-)S&E: Resaleable Product (+)

S&E: Employment (+)

E&B: Noise Disturbance (-)

C&S: Air Quality (-)

C&S: Noise Disturbance (-)

C&S: Visual Disturbance (-)

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Figure 7.1: Impacts associated with process (crush ing and screening) activities.

KEY: S&E: Social & Economic C&S: Crushing & Screening E&B: Excavation & Breaking L&S: Loading & Stockpiling.


7.2.2 Storage of Waste Storage of New Waste The new waste material is stored in stockpiles in a designated area according to the kinds of material it is comprised of, until processing is required. The material is not hazardous and does not pose any leachate potential. The stockpiled waste may generate windblown dust which becomes airborne and impacts the air quality. The stockpiles have a negative visual impact on the surrounding areas as the site is visible from the N3 highway and some business buildings. Storage of Existing/Historical Waste The larger existing historical waste occurs in two main areas: • North West area of the site and comprises of fine sandy material. • South East area of the site comprised of rocky type rubble generated from underground substrates. The main impact resulting from the historical waste is its visual impact as they are large volumes that are easily visible from the surrounding areas. In addition, the existence of this material has resulted in the site becoming sterile for other land use in its current state.

7.2.3 Supporting Services Mobile Offices: Temporary mobile containers are used as office space for the conducting of all administrative functions. Access Gates: A lockable access gate is utilised on site to ensure that no further illegal tipping may occur after operational hours. The entrance is used for access to the office and for receiving of raw material (new waste). Potable Water: A tap is located on site for drinking purposes, and has the potential for leaks resulting in wasted water. Chemical Toilets: Portable chemical toilet(s) are hired for use by the employees (currently not observed on site). Soil pollution may occur from leakage or overflow of the chemical toilets.

Equipment and Maintenance: Mobile equipment used in this operation include: excavators, dump trucks, loader and crusher and mobile screens and conveyors. The use of this equipment has the potential for oil or hydrocarbon spillages. No maintenance or refuelling activities will occur on site as these activities will be the responsibility of the suppliers and hiring contractors. The presence of the processing equipment is also a negative visual impact. Transport Rubble Tech is not involved in any transportation activities associated with accepting or selling the waste materials/products, however to support the cradle to grave principle, an indirect impact is associated with spillages of waste material from the trucks on to the roads.


NW: Air Quality (-)

NW: Visual (-)

HW: Air Quality (-)

HW: Visual (-)HW: Land Sterility (-)

SS: Potable Water Leaks (-)SS: Chemical Toilets Leaks (-)

SS: E&M (Visual) (-)

SS: E&M (Hydrocarbon Spills) (-)

SS: T&T (Spillages) (-)

SS: T&T (Traffic Congestion) (-)

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Figure 7.2: Impacts associated with waste storage activities and supporting services.

KEY: SS: Supporting Services. NW: New Waste. HW: Historical Waste. T&T: Traffic & Transportation. E&M: Equipment & Maintenance.


7.2.4 Summary of Impact Assessment

Table 7.1: Summary of impacts associated with the operation without mitigation measures.

ACTIVITIES POTENTIAL IMPACT SIGNIFICANCE RANKING Process Activities

Development of infrastructure No impact identified No impact Waste Minimisation: Acceptance of new construction waste

Re-use, recycling (processing) of waste material

Positive significance

Excavating & Breaking (E&B) Air quality: generation of dust Low significance Noise disturbance Low significance

Loading and Stockpiling (L&S) Air quality: generation of dust Medium significance Crushing & Screening (C&S) Air quality: generation of dust Medium significance

Noise disturbance Medium significance Social & Economic (S&E)

Reduced cost of recycled material


Provision of employment (12 employees)


Storage of Waste New Waste (NW): Storage Air quality: generation of dust Medium significance

Visual disturbance Medium significance Historical Waste (HW): Storage Air quality: generation of dust Mediu m significance

Visual disturbance Medium significance Land sterility Medium -High significance

Supporting Services Potable water supply (tap) Water wastage from leaks Low significance Provision of chemical toilet Chemical leakages Low significance Traffic & Transportation (T&T) Road spillages from trucks Low significance

Traffic congestion Low significance Equipment & Maintenance (E&M) Visual disturbance: processing

infrastructure Low significance

Hydrocarbon spills: vehicles and equipment

Low significance

Management measures for the above described impacts are discussed in Section 8. A re-evaluation of the impacts has been made after consideration of implementing the management measures.


8 ENVIRONMENTAL MANAGEMENT PLAN

8.1 ENVIRONMENTAL MANAGEMENT PLAN

Table 8.1: Management measures for all the impacts identified (Section 7.2) associated with the opera tion.

ACTIVITY POTENTIAL IMPACTS SIGNIFICANCE RANKING MITIGATION MEASURES RE-EVALUATION Process Activities

Development of infrastructure

No impact identified No impact No management measures are required for the infrastructure that has already been assembled on site.

No impact

Waste Minimisation: Acceptance of new construction waste

Re-use, recycling (processing) of waste material

Positive significance Acceptance of waste for re-use and recycling is a positive impact as it encourages the minimisation of waste according to the waste hierarchy) where disposal should be considered as a last resort. • Ensure that only inert construction waste is

accepted, that is conducive to the type of processing (recycling) carried out on site.

• Hazardous waste is strictly prohibited from being accepted at this site.

• No other waste such as garden refuse or domestic waste or animal carcasses will be accepted onto site.

• A designated person must be appointed to inspect the type of waste that can be accepted to ensure that no unwanted waste is delivered onto site. Trucks carrying unwanted waste will be turned away.

• Rubble Tech is to ensure that the appropriate waste manifest documentation is received by the waste transporter.


Excavating & Breaking (E&B)

Air quality: generation of dust

Low significa nce The following management measures will reduce dust generation from the site: • Cease excavation and/or breaking activities if the

dust is very excessive. • Water or spray the surface area of the construction

waste if needed. • All staff must wear appropriate PPE for protection

Low significance


ACTIVITY POTENTIAL IMPACTS SIGNIFICANCE RANKING MITIGATION MEASURES RE-EVALUATION against dust of the eyes and respiratory system.

Noise disturbance Low significance • Operational activities are only required to be conducted during business daylight hours:

- Mon-Fri: 7am – 5pm. - Sat: 7am – 12pm. - Sun: closed.

All staff must wear appropriate PPE for protection against high continuous noise levels. • Noise monitoring should be conducted prior to

operations re-commencing to establish the baseline environmental noise of the area.

•

Low significance

Loading and Stockpiling (L&S)


Medium significance The following management measures will reduce dust generation from the site: • Cease loading and/or stockpiling activities if the dust

is very excessive. • Water or spray the roads/route used by trucks. • Water or spray the surface area of the construction

waste if needed. • Keep tarpaulins on site for use on stockpiles that are

of high fines consistency. • All staff must wear appropriate PPE for protection

against dust of the eyes and respiratory system.

Medium significance

Crushing & Screening (C&S)


Medium significance The following management measures will reduce dust generation from the site: • Cease loading and/or stockpiling activities if the dust

is very excessive. • Water or spray the surface area of the construction


against dust of the eyes and respiratory system. • Apply the following dust suppression measures:

- Ensure that the conveyors are enclosed. - Ensure that water sprays are used at the

crusher. - Screens must be cladded to reduce

excessive dust emanation.

Medium significance


ACTIVITY POTENTIAL IMPACTS SIGNIFICANCE RANKING MITIGATION MEASURES RE-EVALUATION Noise disturbance Medium significance Operational activities are only required to be conducted

during business daylight hours: - Mon-Fri: 7am – 5pm. - Sat: 7am – 12pm. - Sun: closed.

All staff must wear appropriate PPE for protection against high continuous noise levels.

Social & Economic (S&E)

Reduced cost of recycled material

Positive significance Recycled material is cheaper than raw construction material and therefore due to its affordability creates a stronger market for sale of recycled construction waste.


Provision of employment (12 employees)

Positive significance Although only a small number of jobs are provided, without this project the current employees would be expected to find new employment opportunities.


Storage of Waste New Waste (NW): Storage


Medium significance The following management measures will reduce dust generation from the site: • Water or spray the surface area of the construction

waste if needed. • Ensure that the quantities of new waste being

accepted is controlled: - Total combined quantity of new waste accepted

on site must not exceed 25 000 tons. - Once waste has been processed it ceases to

considered as waste and is product. • All staff must wear appropriate PPE for protection

against dust of the eyes and respiratory system.

Low significance

Visual disturbance Medium significa nce • If possible, relocate the stockpiles to areas that are less visible from off site.

• Ensure that the height of the height of the stockpiles do not exceed 3m.

• Plant indigenous trees along the boundary of the site.

Medium significance

Historical Waste (HW): Storage


Medium significance The following management measures will reduce dust generation from the site: • Water or spray the surface area of the construction


Low significance


ACTIVITY POTENTIAL IMPACTS SIGNIFICANCE RANKING MITIGATION MEASURES RE-EVALUATION against dust of the eyes and respiratory system.

Visual disturbance Medium significance • Ensure that the slopes of the historical waste are sloped and rehabilitated in a manner that is visually acceptable and that rock waste is not visible from the N3 highway.

Low significance

Land sterility Medium -High significance

• Ensure that the quantity of historical waste is decreased.

• Compile a processing plan for the management of historical waste with a vision to clean up the site.

• Waste that is accepted on site may not be stored for more than 18 months.

Medium significance

Supporting Services Potable water supply (tap)

Water wastage from leaks Low significance • Inspect the water supply area at least once weekly. • If any signs of leaks are reported, they must be fixed

within a week of the initial leak detected.

Low significance

Provision of chemical toilet

Chemical leakages Low significance • Ensure that the contracted company responsible for hiring of the chemical toilets collect the toilets frequently according to a contractual agreement.

• If any spills or leaks are detected, the contracted company must be contacted immediately for collection and replacement of the toilet.

• The spillage must be cleaned up and disposed of in a closed container or drum for collection by the contractor or for disposal at an appropriate landfill site.

Low significance

Traffic & Transportation (T&T)

Road spillages from trucks

Low significance • The roads up until the first intersection in each direction should be inspected to observe any spillages that could have emanated from transporters of construction waste at least once a week.

• The entrance must be inspected for any spillages from the trucks transporting construction waste on a daily basis.

• If any spills are identified within this road network, clean up the waste and return it back to site.

• Request the trucks to use tarpaulins to cover their loads during transportation.

Low significance


ACTIVITY POTENTIAL IMPACTS SIGNIFICANCE RANKING MITIGATION MEASURES RE-EVALUATION • Loading must be checked and logged according to

the capacity of the vehicles and amount sold. • If regular overloading is observed, a weighbridge

must be implemented. Traffic congestion Low significance • It is not anticipated that any traffic congestion will be

experienced as a result of the Rubble Tech site, approximately twelve of trucks may enter the site per day.

• All truck drivers are to hold valid driver’s licences. • Each new driver of a truck that enters the site must

present a copy of their drivers licence to staff personnel checking the trucks.

• Illegal turning over the traffic island is prohibited. This must be monitored daily and if needed permission to obstruct access must be requested from SANRAL.

Low significance

Equipment & Maintenance (E&M)

Visual disturbance: processing infrastructure

Low significance • If possible, relocate the infrastructure to an area on site that cannot be visible from the N3 highway.

• Consider the possibility (if practical) of constructing a berm/barrier to mitigate the appearance of the processing infrastructure.

Low significance

Hydrocarbon spills: vehicles and equipment

Low significance • Inspect the site for signs of spills at least once weekly.

• If any spills/leaks are detected, ensure that they are cleaned up immediately and disposed of as hydrocarbon waste.

Low significance

Table 8.2: Additional management measures not asso ciated with identified impacts.

ACTIVITY MITIGATION MEASURES Document control A copy of the following documentation must be kept at the site:

- Environmental management programme. - Waste manifest documents. - Monitoring results and reports. - Environmental authorisation. - Complaints register.

Waste management - Ensure that any waste generated is separated at the source.


- Provide two bins for the storage of waste: - Hazardous waste: chemical/hydrocarbon spills. - General waste: domestic waste.

- Bins must be clearly labelled or colour coded according to waste type. - Ensure that the bins are collected/emptied weekly. - Proof of appropriate disposal records must be kept on site.

Monitoring The following environmental monitoring is required for the Rubble Tech operation: - Dust fallout monitoring: minimum requirements as indicated in Table 8.6 . - Environmental (boundary) noise monitoring: minimum requirements as indicated in Table 8.3 .

Access control The site must be controlled and accessed in the following manner: - A security guard must control access to the premises. - Each vehicle that enters the premises must be logged. - Ensure that waste accepted is weighed using a weighbridge. - After hours the site must be locked to prohibit access to the site. - A sign must be placed at the entrance indicating:

- Hours of operation. - Contact details in case of emergency.

Complaints All complaints must be recorded in a register on site and be available for inspection by the competent authority upon request. Meetings with the adjacent landowners and affected parties should be held at least twice a year.

Landowner consent In the event that permission is granted to continue with this activity, the consenting agreement (referred to in Appendix 11.1) must be signed prior to re-commencement of the activity. It is recommended that this agreement is included as a condition of the authorisation (if it is decided to be granted). The CoJ must be requested to obtain the relevant zoning for the type of land use.

Environmental Awareness & Training

The following types of environmental awareness training must be undertaken: - Truck driver awareness: overloading, dust generation, spillages, drivers licence. - Staff acceptance of waste: acceptance and prohibitions of new waste. - General implantation of good environmental practices including implementation of the EMP.

Emergencies In the event of an emergency, follow the emergency response plan in Section 9.


Table 8.3: Minimum requirements for environmental noise monitoring.

NOISE MONITORING Applicable Legislation :

• Regulation 154 (Regulations regarding Noise Control) of the Environment and Conservation Act, Act No. 73 of 1989 (ECA).

• South African National Standard - SANS 10103 (Previously SABS 0103.). Parameters : Noise must be measured in "dBA".

Monitoring Method : Outdoor monitoring must be undertaken by placing the microphone of an integrating impulse sound level meter • At least 1.2m, but not more than 1.4m, above the ground and • At least 3.5m away from walls, buildings or other sound reflecting

surfaces. • The person taking the measurements must ensure: • The microphone of an integrating impulse sound level meter is at all times

provided with a windshield; • The measuring instruments are operated strictly in accordance with the

manufacturer's instructions; and • Sound measuring instruments are checked annually by the SABS or a

calibration laboratory approved by the Minister in order to ensure accuracy.

Site Selection Parameters :

• On the site boundary in direct line of site of the plant. • Off-site at the following locations:

- In direct line of site of the active mining area. - Any sensitive receptors (such as schools, hospitals, houses, etc.) in

close proximity to the site. - Locations from which noise complaints have been received.

Recommended Sites : It is advised that monitoring is undertaken on the boundary of the Rubble Tech site at least two locations:

- North-west of the site. - South west of the site.

Monitoring Interval : • Once every six months – once during winter and once during summer, thereafter every 2 years , unless there is a complaint. If there is a complaint a survey must be commissioned to qualify the complaint.

Eva

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Performance Indicators :

• SANS 10103. • Previous monitoring results.

Reporting : It is advisable to store all results in a spreadsheet and project the results graphically in order to determine: • Exceedances of the SANS, which should be presented on the graphs. • Trends with previously monitored results.

Environmental Management :

When exceedances of performance indicators are recorded, the following steps must be taken and documented: • Determine the source of elevated noise levels. • If increased noise levels are from the site, determine if this is as a result of

a once off incident or a routine event. • Determine how the incident / event can be prevented, or how it can be

managed in future. Implement appropriate mitigation measures. • The success of mitigation measures must be confirmed through continued

routine monthly sampling.


8.2 WASTE MANAGEMENT PLAN Three main sources of waste are generated at Rubble Tech and are indicated in Table 8.4. These “wastes” require specific management according to the type and source of generation. Table 8.4: Sources waste generated at the Rubble T ech site.

Waste types Sources of generation Management Construction waste (builders rubble)

• New waste: accepted onto site via trucks from various development projects.

• No hazardous waste will be accepted onto site.

• Waste that is accepted onto site may not be stored for more than 18 months.

• Total combined quantity of new waste accepted on site must not exceed 25 000 tons.

• Once waste has been processed it ceases to be considered as waste and is product.

• Management of new waste must adhere to the conditions of a waste licence and/or environmental authorisation issued to Rubble Tech (if granted).

• Historical waste: exists on site prior to Rubble Tech operation (June 2011).

• If, during the unearthing of historical waste stockpiles, other waste (general or hazardous waste) is encountered (e.g. paint tins, wood debris or domestic waste), it must be disposed of as either general or hazardous waste.

• This waste must be managed according to the conditions of a waste licence and/or environmental authorisation issued to Rubble Tech (if granted).

Hazardous waste

• Grease, oil, hydrocarbon spillages and oily rags from lubrication of equipment.

• Ensure that any waste generated at Rubble Tech site is separated at the source.

• Provide two bins for the storage of waste: - Hazardous waste:

chemical/hydrocarbon spills. - General waste: domestic waste.

• Bins must be clearly labelled or colour coded according to waste type.

• Ensure that the bins are collected/emptied weekly.

• Proof of appropriate disposal records must be kept on site.

General waste • Domestic waste (food waste). • Litter blown onto site. • Office waste.


8.3 STORM WATER MANAGEMENT PLAN Process water and reticulation Water is not used for any processing activities, therefore there is no water reticulation on site and no management measures are required. Sewer management There are no sanitation facilities on site and therefore no sewer management is required. Chemical toilets are utilised for sanitary requirements. Surface and groundwater resources There are currently no boreholes on site and no surface water resources, therefore no management regarding these resources are required. Storm water drainage • Natural surface drainage is in a north-west direction. However, due to the storage of waste on site

run-off is also prone to be directed south-west and south-east. • Currently a storm water drain exists at the north east corner of the site and any water that runs off

property will flow into the drain. • The south west boundary is sloped and is prone to run-off.

- Ensure that the slope is reshaped and maintained in a terrace design to prevent fast flow of water and erosion.

- Ensure that the top part of the slope is vegetated to prevent erosion. • Ensure that no waste material runs off the site during storm events by creating berms at the perimeter

where necessary. • Inspections regarding the flow of storm water must be carried out every rainy season and any

problems associated with storm water must be rectified to ensure that storm water is managed effectively.

Figure 8.1: Stormwater management plan.

Slope terraced

Storm water drain Construct berm

Construct berm


8.4 AIR QUALITY MANAGEMENT PLAN 8.4.1 Management Measures The point sources of dust that may be generated on site are indicated in . Management measures have been provided to mitigate the sources of dust that emanate during specific activities and such management is required to be implemented within a specified timeframe.

Table 8.5: Sources and management measures for dus t generation at the Rubble Tech site.

Source / Activity generating dust

Management measures Timeframe 2

Vehicle entrainment (includes all vehicle movement on site)

Implement speed limit (20km per hour) on site/access road. Implement speed humps on access road (dependent on monitoring results, see Section 8.4.2).

1 month 3 months

All activities relating to stockpiling (generation and removal)

Reduce double handling of material if possible. Spray or water the stockpiles.

When needed

Exposed surfaces Plant trees on the north-east boundary. Water or spray the exposed surfaces. Increase the frequency of implementing dust suppression during the drier winter months.

1 year Daily Winter

Crushing and processing

Use water sprayers on the crusher. Covers on the conveyors. Cease activities during extreme windy days.

1 month 1 month Immediate

Dust from trucks during transportation

Use of tarpaulins must be encouraged. Prevent overloading through visual checks.

Daily Daily

8.4.2 Monitoring: Dust Fallout The minimum requirements for air quality (dust fallout) monitoring are provided in Table 8.6 below.

Table 8.6: Minimum requirements for dust fallout mo nitoring.

DUST FALLOUT MONITORING Applicable Legislation :

• National Environmental Management Act, Act No. 107 of 1998 (NEMA), Section 28.

• National Environmental Management: Air Quality Act, Act No. 39 of 2004 (NEM:AQA), Section 12.

• South African National Standard - SANS 1929.

Parameters : • Dust Fallout / Deposition.

Monitoring Method : Single or directional fallout monitors, following the American Society for Testing and Materials standard method for collection and analysis of dustfall (ASTM D1739). An open topped cylinder (bucket) not less than 150mm in diameter with a height not less than twice the diameter and suspended 2m above the ground (fixed point monitoring). The bucket must be exposed for a continuous period of 30 days (±2 days). The dust is dissolved in water which is returned to the laboratory, filtered and the residue dried before the insoluble dust is weighed. Results are expressed as mg/m2/day.

2 Timeframes commence from the date of waste licence and/or environmental authorisation (if granted).


DUST FALLOUT MONITORING Site Selection Parameters :

Monitoring sites must consider: • Wind direction: Monitoring stations should be located downwind of the

Rubble Tech site. (Ensure monitoring point recording dust fallout downwind of all prominent wind directions).

• Receptors: Residential areas, schools, ecologically sensitive habitats within close proximity of the site.

• Other sources of pollution in the vicinity: If the site is located downwind of another dust source, locate a directional unit between Rubble Tech site and the off-site source.

Recommended Sites :

The fallout buckets need to be placed along the boundary of the Rubble Tech site in at least the four main wind directions.

Monitoring Interval : • Monthly (on-going): Sampler should be exposed for a continuous period of 30 days (±2 days), results expressed as mg/m2/day.

Eva

luat

ion

of R

esul

ts:

Performance Indicators :

• SANS 1929. • On-site – target of below Industrial limit. • Site boundary – Industrial limit. • Previous monitoring results (if any).

Reporting : It is advisable to store all results in a spreadsheet and project the results graphically in order to determine: • Exceedances of the SANS, which should be presented on the graphs. • Trends with previously monitored results.

Environmental Management :

When exceedances of performance indicators are recorded, the following steps must be taken and documented: • Determine the source of the pollution and prevailing winds. • If pollution is from the site, determine if it is as a result of a once off incident

or a routine event. • Determine how the incident / event can be prevented, or how it can be

managed in future. Implement appropriate mitigation measures. • The success of mitigation must be confirmed through continued routine

monthly sampling.


9 EMERGENCY RESPONSE PLAN

Potential emergencies The following potential environmental and safety related emergencies have been identified: • Slope instability of historical waste. • Rock falls on western side of property. • Lightning strikes. • Mechanical and machinery injuries. Emergency equipment • First aid kit: office building. • Responsible persons:

- First Aid Attendant. - Manager on Duty.

Training requirements The following raining is required to be able to deal with emergencies: Training Applicability Frequency Awareness talks:

- Movement of earth. - Slope stability. - Working in weather

(storm, rain, lightning). - Safety aspects of

operation of equipment.

All employees Monthly

First Aid Attendant (1 employee) Annually (or upon new appointment)

Evacuation plan • Assembly site: entrance/access area. • Responsible person to issue all clear: manager on duty. • Frequency of drills: four times a year. • Signage: label the safety area with a clearly marked sign. Emergency contact information Emergency Action plan Contact Slope instability of historical waste

1. Evacuate the site. 2. Investigate the extent of

stability. 3. Decide on further actions

needed. 4. Responsible person to

provide all clear.

Manager on duty

Rock falls on western side of property

1. Stop work in specific area. 2. Report incident to manager

on duty. 3. Report to traffic department.

Manager on duty

Lightning strikes 1. Stop work in all areas. 2. Assemble in safety area. 3. Responsible person to

provide all clear.

Manager on duty

Mechanical and machinery injuries

1. Stop work. 2. Alter first aid attendant. 3. For minor injuries: treat injury

on site. 4. For major injuries: contact

relevant emergency contact.

First aid attendant

Other:


10 DECLARATION

10.1 RESPONSIBLE PERSON / ENVIRONMENTAL CONTROL OFFICER There is no designated Environmental Control Office at Rubble Tech (Pty) Ltd, however the Director is responsible for ensuring daily implementation of all compliance on the site. The current Director’s details are as follows: Full Name: Gerardus Gomes-Sebastiao Contact No s.: Tel: 012 669 9931

Cel: 082 455 6641 Fax No.: 012 669 9938 Email add ress: [email protected]

10.2 SIGNED SUBMISSION I, ______________________________________ understand the content of the Environmental Management Plan (EMPlan) and will be ultimately held responsible for compliance with the requirements and procedure thereof. No similar activities will be undertaken in future within the Gauteng province without prior approval from GDARD. No other unlawful activities listed under: • GN R 718 promulgated in terms of section 19 and 69 of the NEM: WA (Act No. 59 of 2008); and • GN R544 and GN R545 promulgated in terms of Section 24 and 24D of the NEMA, have commenced

or continued with on the property in question. Rubble Tech (Pty) Ltd commits to comply with all South African environmental legislation. Gerardus Gomes-Sebastiao (Director)

Signed at:

Date:


11 APPENDICES


11.1 LANDOWNER CONTRACT AGREEMENT Please note that the contract below has not been signed by Rubble Tech as the agreement has been drawn up for a period of one year , which is only valid upon authorisation of this application. Therefore Rubble Tech has made a commitment to sign the initial agreement in the event of approval. Therefore the signing and hence permission from the landowner has been included as a recommended management measure and has been recommended to be included as a condition of the authorisation (if approved). Refer to page 66 of this report.


11.2 INTERESTED AND AFFECTED PARTIES REGISTER


11.3 BACKGROUND INFORMATION DOCUMENT


11.4 COMMENTS RECEIVED FROM I&APS


11.5 FORMAL COMMUNICATION

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