SECTION 24G DRAFT REPORT APPLICATION FOR AUTHORISATION Farms IWULA/F320... · RAYAL INDUSTRIAL...

RAYAL INDUSTRIAL (PT Y) LTD

S o u t h A f r i c a n p o r c e l a i n R o o f & F l o o r T i l e s P r o d u c e

SECTION 24G DRAFT REPORT

APPLICATION FOR AUTHORISATION

CONTINUATION OF AN ACTIVITY IN TERMS OF SECTION 24G OF NEMA

ATMOSPHERIC EMISSION LICENSE IN TERMS OF NEM:AQA

MANUFACTURING OF PORCELAIN TILES AT

ERVEN 171-176 GALENA STREET, EKANDUSTRIA, CITY OF TSHWANE, GAUTENG

GDARD Reference Number: S24G/03/14-15/0327

APRIL 2016

FOR COMMENT BY INTERESTED AND AFFECTED PARTIES

Comment period: Friday, 15 April 2016 to Friday, 20 May 2016

Report compiled by the appointed EAP:

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PURPOSE OF THIS DOCUMENT

Rayal Industrial (Pty) Ltd operates a porcelain tile manufacturing facility, at Erven 171-176, Galena Street, Ekandustria, in the City of Tshwane Metropolitan Municipality, Gauteng. The facility produces roof tiles and floor tiles, which are sold in bulk to commercial clients such as CTM, Builders Warehouse, and others.

Porcelain tile production is a listed activity in terms of the National Environmental Management: Air Quality Act (NEM:AQA) (Act No. 39 of 2004). As a result the facility must have an atmospheric emission license (AEL) in terms of this Act. In addition, prior to commencing with a listed activity, the company was supposed to obtain an environmental authorisation (EA) in terms of the National Environmental Management Act (NEMA) (Act 107 of 1998). Since the company has commenced with operations without the necessary EA and AEL, it needs to apply for a Section 24G rectification in terms of NEMA from the Gauteng Department of Agriculture and Rural Development (GDARD) and an AEL from the local municipality.

The GDARD issued a Directive to Rayal Industrial on 20 August 2016, instructing the company to apply for the NEMA Section 24G rectification. This draft report provides the information requested by GDARD in its Directive, and documents the public consultation undertaken as per GDARD’s requirements to obtain an environmental authorisation for the facility. According to GDARD, interested and affected parties must be given the opportunity to comment and raise objections regarding the project. I&APs have an opportunity to comment on this report from Friday, 15 April 2016 to Friday, 20 May 2016. All comments and objections received during this period will be included in the final Section 24G report before it is submitted for decision-making.

Parties wishing to formally object to and/or comment on the Section 24G rectification and AEL applications are requested to forward their objections and comments no later than 20 May 2016 by contacting the Public Participation Office. This report is available during the comment period at the following public places and on the following web site: www.jaws.co.za.

Printed Copies

Ms Grace Kotlolo Bronkhorstspruit / Kungwini Public Library, cnr

Generaal Louis Botha / Mark Street, Bronkhorstspruit

012 358 6483 / 071 671 8626

Mr Haroon Khan Rayal Trading, 14 Galena Street, Ekandustria 013 933 3846 Electronic Copies

Website download www.jaws.co.za CD copy Please call Anelle Lötter / Sibongile Bambisa 012 667 4860

Public Participation Office Jones & Wagener Engineering & Environmental Consultants (Pty) Ltd,

Anelle Lötter/Sibongile Bambisa, P O Box 1434, Rivonia, 2128,

Tel: (012) 667-4860; Fax: 012 667 6128; Email: [email protected] /[email protected]

Please note that all objections and comments must also be copied to:

The Head of Department: Gauteng Department of Agriculture and Rural Development For Attention: Ms. Maryjane Ramahlodi: Section 24G Unit Manager P.O. Box 8769, Johannesburg, 2000 E-mail: [email protected], [email protected]

http://www.jaws.co.za/

http://www.jaws.co.za/

mailto:/[email protected]

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TABLE OF CONTENTS

1 INTRODUCTION ............................................................................................................. 1 1.1 Purpose of this report .................................................................................... 1 1.2 Content of this report .................................................................................... 1 1.3 Details of the Environmental Assessment Practitioner ................................. 1 1.4 Applicable Environmental Legislation ........................................................... 2

2 BACKGROUND TO THE PROJECT ............................................................................... 5 2.1 Property and location .................................................................................... 5 2.2 Background to Rayal Industrial ..................................................................... 5 2.3 Capacity of the facility ................................................................................... 5 2.4 Existing operations at the site ....................................................................... 5 2.5 Water supply ............................................................................................... 13 2.6 Waste management .................................................................................... 13 2.7 Motivation for this project ............................................................................ 14

3 PUBLIC PARTICIPATION ............................................................................................. 15 3.1 Objectives of Public Participation ................................................................ 15 3.2 Identification of stakeholders and an I&AP register .................................... 15 3.3 Site Notice ................................................................................................... 15 3.4 Written notice and involving disadvantaged stakeholders .......................... 15 3.5 Advertisement ............................................................................................. 16 3.6 Availability of the Section 24G and AEL Report for public review ............... 16 3.7 Notification of GDARD Decision ................................................................. 16

4 RECEIVING ENVIRONMENT ....................................................................................... 17 4.1 Topography ................................................................................................. 17 4.2 Climate ........................................................................................................ 17 4.3 Surface water .............................................................................................. 18 4.4 Ground water .............................................................................................. 18 4.5 Soils and geology ........................................................................................ 19 4.6 Air quality .................................................................................................... 19 4.7 Social .......................................................................................................... 22 4.8 Sense of place ............................................................................................ 22 4.9 Cultural and heritage ................................................................................... 22

5 IMPACT ASSESSMENT ................................................................................................ 23 5.1 Methodology for Impact Assessment .......................................................... 23 5.2 Assessment of potential impacts ................................................................ 24 5.3 Description of identified impacts and recommended mitigation measures . 25

6 ENVIRONMENTAL MANAGEMENT PROGRAMME .................................................... 35 7 INFORMATION REQUESTED BY GDARD .................................................................. 36 8 CONCLUSION AND EAP ENVIRONMENTAL STATEMENT ....................................... 44 9 REFERENCES .............................................................................................................. 45 FIGURES Figure 1: Locality of the Rayal Industrial facility in the City of Tshwane Metropolitan Municipality 6 Figure 2: Site location of the Rayal Industrial facility within Ekandustria, showing surrounding areas 7 Figure 3: Process flow diagram for the Rayal Industrial facility 10 Figure 4: Site Layout Plan 11 Figure 5: Climatic data for the Wonderboom Airport, closest weather station to the site (courtesy of Meteoblue website) 17 Figure 6: Wind Rose for the Ekandustria area (2010 to 2013) 18 Figure 7: Vegetation types in the Metsweding District Municipality (copied from the Metsweding District Municipality EMF, 2011) 20

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Figure 8: Historic aerial photography for the site from 2004 21 Figure 9: Dispersion modelling results for PM10, which indicates compliance with the daily NAAQS outside the factory fence-line 28 Figure 10: Dispersion modelling results for PM2.5, which indicates compliance with the daily NAAQS outside the factory fenceline 28 Figure 11: Dispersion modelling results for TSP, which indicates compliance with the dust control regulations outside the factory fenceline 29 Figure 12: Dispersion modelling results for SO2, which indicates compliance with the NAAQS hourly limit 29 Figure 13: Dispersion modelling results for SO2, which indicates compliance with the NAAQS daily limit 30 Figure 14: Dispersion modelling results for SO2, which indicates compliance with the NAAQS annual limit 30 Figure 15: Dispersion modelling results for NOx, which indicates compliance with the NAAQS hourly limit 31 Figure 16: Dispersion modelling results for NOx, which indicates compliance with the NAAQS annual limit 31 Figure 17: Dispersion modelling results for HF, which indicates non-compliance with the hourly CALEPA limit off-site. 32 Figure 18: Dispersion modelling results for HF, which indicates non-compliance with the annual CALEPA limit off-site. 32 TABLES Table 1: Summary of Activities Requiring Authorisation under R543, 544 and 545 of 2010 3 Table 2: Summary of Activities Requiring an Atmospheric Emission License in terms of GN 893 4 Table 3: Raw materials stored on site 8 Table 4: Waste streams generated at Rayal Industrial 13 Table 5: Sampling Data at DWS Sampling point (B31_189521) from 1 Jan 1972 to 31 Dec 2010 18 Table 6: Scoring of impacts 23 Table 7: Impact Assessment Summary 24 Table 8: Emissions from the facility compared to the minimum emission standards 26 Table 9: GDARD Requirements for this Application 36 APPENDICES Appendix 1: GDARD Compliance Notice and Directive, Requests for extension of the deadline Appendix 2: Professional Profiles and EAP Declaration Appendix 3: Borehole Analyses and Geotechnical Report Appendix 4: Adverts and Site notice Appendix 5: Register of I&APs and Correspondence to I&APs Appendix 6: Comments and Response Report Appendix 7: Copies Of I&AP’s Comments Appendix 8: Photographs Appendix 9: AIR IMPACT REPORT Appendix 10: EMPr Appendix 11: Impact Evaluation Form

S24G Report: MANUFACTURING OF TILES IN EKANDUSTRIA Rayal Industrial GDARD Reference Number: S24G/03/14-15/0327

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1 INTRODUCTION Rayal Industrial (Pty) Ltd operates a porcelain tile manufacturing facility, at Erven 171-176, Galena Street, Ekandustria, in the City of Tshwane Metropolitan Municipality, Gauteng from September 2013. The facility produces roof tiles and floor tiles, which are sold in bulk to commercial clients.

Tile production is a listed activity in terms of the National Environmental Management: Air Quality Act (NEM:AQA) (Act No. 39 of 2004). As a result the facility must have an atmospheric emission license (AEL) in terms of this Act. In addition, prior to commencing with a listed activity, the company was supposed to obtain an environmental authorisation (EA) in terms of the National Environmental Management Act (NEMA) (Act 107 of 1998). Since the company has commenced with operations without the necessary EA and AEL, it needs to apply for a Section 24G rectification in terms of NEMA from the Gauteng Department of Agriculture and Rural Development (GDARD) and an AEL from the local municipality.

1.1 Purpose of this report The GDARD issued a Notice of Intention to Issue a Compliance Notice on 27 November 2014 and a Directive on 20 August 2016, instructing Rayal Industrial (Pty) Ltd to apply for the NEMA Section 24G rectification (the notice and directive are provided in Appendix 1).

This draft report provides the information requested by GDARD, and documents the public consultation undertaken to obtain an environmental authorisation for the facility. According to GDARD, interested and affected parties must be given the opportunity to comment on the Section 24G Report before it is submitted to the department. I&APs have an opportunity to comment on this draft report from Friday, 15 April 2016 to Friday, 20 May 2016. All comments and objections received during this period will be included in the final Section 24G report which will be submitted for decision-making.

1.2 Content of this report This provides the following information:

• Background information to the project (Section 2). • Public participation undertaken to comply with GDARD requirements (Section 3). • Receiving environment (Section 4). • Impact Assessment (Section 5). • Environmental Management Plan (Section 6). • Information requested by GDARD (Section 7).

1.3 Details of the Environmental Assessment Practitioner Rayal Industrial appointed Prav Sewmohan, an environmental assessment practitioner (EAP), to conduct this Section 24G application. Prav Sewmohan has no business, financial or personal interest in the facility and is therefore able to provide an independent, objective assessment. She is a qualified chemical engineer with over 20 years’ experience in leading and conducting environmental impact assessments in the manufacturing sector. She is certified as an environmental assessment practitioner by the Interim Certification Board of South Africa. Her experience includes the integration of various specialist assessments in the compilation of environmental impact reports and environmental management plans. Such reports include the integration of water, ground water, air quality, biodiversity, wetland, social, socio-economic, macro-economic, noise, traffic, visual, heritage and paleontological studies. She has also undertaken a number of Section 24G applications previously. Her profile is given in Appendix 2. The declaration of independence is also given in Appendix 2.


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1.3.1 Public participation practitioner The public participation for the EIA is being carried out by Jones & Wagener (Pty) Ltd, an engineering and environmental consulting company, led by Ms Anelle Lötter. Ms Lötter is an experienced public participation practitioner with more than 20 years’ experience in leading and conducting public participation processes.

1.3.2 Air quality specialist An air impact assessment was conducted by Airshed Planning Professionals, a specialist consulting company undertaking air impact assessments for over 20 years.

1.4 Applicable Environmental Legislation The following environmental legislation is applicable to the project.

1.4.1 The Constitution of the Republic of South Africa (Act 108 of 1996) Section 24 of the Constitution states that: Everyone has the right:

a) to an environment that is not harmful to their health or well-being; and b) to have the environment protected, for the benefit of present and future generations,

through reasonable legislative and other measures that- i. prevent pollution and ecological degradation; ii. promote conservation; and iii. secure ecologically sustainable development and use of natural resources, while

promoting justifiable economic and social development

The current environmental laws in South Africa concentrate on protecting, promoting, and fulfilling the Nation’s social, economic and environmental rights; while encouraging public participation, implementing cultural and traditional knowledge and benefiting previously disadvantaged communities.

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

The National Environmental Management Act, 107 of 1998, as amended, (NEMA), specifies that it is necessary for an applicant to undertake an EIA, which meets the minimum requirements of section 24(7) of NEMA, where an activity requires permission by law. The minimum requirements of section 24(7) of NEMA are regulated by the EIA Regulations, of which the latest Regulations were promulgated in December 2014 (Government Notices R983 and R984). Since this facility commenced in September 2013, the previous EIA Regulations, viz. Government Notices R543, R544 and R545 of June 2010, as amended, is also applicable. The identified listed activities applicable to the facility are listed in Table 1 below.

1.4.3 National Environmental Management: Air Quality Act (Act 39 of 2004) (NEM:AQA)

Government Notice GN893 of 22 November 2013 identifies activities which have emissions that have or may have significant detrimental effects. An atmospheric emissions license (AEL) is required for the undertaking of such activities. Table 2 lists the activities that apply to the facility in terms of GN893.


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Table 1: Summary of Activities Requiring Authorisation under R543, 544 and 545 of 20101

2010 EIA Regulations 2014 EIA Regulations Explanation of Applicability R544, 18 June 2010: Listing Notice 1 R983, 4 December 2014: Listing Notice 1 Activity 23: The transformation of undeveloped, vacant or derelict land to –

(i) residential, retail, commercial, recreational, industrial or institutional use, inside an urban area, and where the total area to be transformed is 5 hectares or more, but less than 20 hectares, or (ii) residential, retail, commercial, recreational, industrial or institutional use, outside an urban area and where the total area to be transformed is bigger than 1 hectare but less than 20 hectares;

except where such transformation takes place – (i) for linear activities; or (ii) for purposes of agriculture or afforestation, in which case Activity 16 of Notice No.R. 545 applies.

Activity 28: Residential, mixed, retail, commercial, industrial or institutional developments where such land was used for agriculture or afforestation on or after 01 April 1998 and where such development:

(i) will occur inside an urban area, where the total land to be developed is bigger than 5 hectares; or (ii) will occur outside an urban area, where the total land to be developed is bigger than 1 hectare;

excluding where such land has already been developed for residential, mixed, retail, commercial, industrial or institutional purposes

The property is already zoned for Industrial 1 and therefore is considered to be inside an urban area. The property is 21.767 hectares in extent. However, the facility covers 4.81 hectares only (48 062 m2), i.e., the facility covers less than 5 hectares. This activity was identified in the Section 24G application, and was identified in the GDARD Directive. However, due to the limited extent of the development, this listed activity does not apply to this facility.

R545, 18 June 2010: Listing Notice 2 R984, 4 December 2014, Listing Notice 2 Activity 5: The construction of facilities or infrastructure for any process or activity which requires a permit or license in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case that Act will apply.

The development of facilities or infrastructure for any process or activity which requires a permit or licence in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent, excluding (i) activities which are identified and included in Listing Notice 1 of 2014; (ii) activities which are included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case the National Environmental Management: Waste Act, 2008 applies; or (iii) the development of facilities or infrastructure for the treatment of effluent, wastewater or sewage where such facilities have a daily throughput capacity of 2000 cubic

The facility requires an AEL in terms of the NEM:AQA and therefore this Activity applies.

1 As corrected by “Correction Notice 1” of 30 July 2010, GN No. R. 660 and “Correction Notice 2” (GN No. R. 1159 of 10 December 2010)


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2010 EIA Regulations 2014 EIA Regulations Explanation of Applicability metres or less.

Activity 26: Commencing of an activity, which requires an atmospheric emission license in terms of section 21 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004), except where such commencement requires basic assessment in terms of Notice of No. R544 of 2010.

Activity 28: Commencing of an activity, which requires an atmospheric emission license in terms of section 21 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004), excluding - (i) activities which are identified and included in Listing Notice 1 of 2014; (ii) activities which are included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case the National Environmental Management: Waste Act, 2008 applies; or (iii) the development of facilities or infrastructure for the treatment of effluent, wastewater or sewage where such facilities have a daily throughput capacity of 2000 cubic metres or less.

The facility requires an AEL in terms of the NEM:AQA and therefore this Activity applies.

Table 2: Summary of Activities Requiring an Atmospheric Emission License in terms of GN 893

Process Number: Listed Process Description: Explanation of Applicability

3.6

Synthetic gas production and clean-up: The production and clean-up of a gaseous stream derived from coal gasification and includes gasification, separation and clean up of a raw gas stream through a process that involves sulphur removal and Rectisol as well as the stripping of a liquid tar stream derived from the gasification process. Application: All facilities.

The synthetic gas plant includes clean-up of tar and therefore this activity applies.

5.2

Drying: The drying of mineral solids including ore, using dedicated combustion installations. Application: Facilities with a capacity of more than 100 tons/month product.

The raw materials spray tower dryer utilises a dedicated coal water slurry furnace, which is a combustion installation. The spray tower produces a maximum of 9 000 tons/ month and therefore this activity applies.

5.9 Ceramic production: The production of tiles, bricks, refractory bricks, stoneware or porcelain ware by firing, excluding clamp kilns. Application: All installations producing 100 ton per annum or more.

The facility produces porcelain tiles which are fired in an open kiln. The facility produces 104 million tons per annum and therefore this activity applies.


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2 BACKGROUND TO THE PROJECT

2.1 Property and location The Rayal Industrial facility is situated at Erven 171-176, Galena Street, in Ekandustria, within the City of Tshwane Metropolitan Municipality as shown in Figure 1 and Figure 2. This part of Ekandustria is zoned for industrial use and comprises a number of industrial stands. The site is therefore surrounded by industries such as Marley Tiles, Bronco Tarps, Plast Africa, Taai Brick and Tile, and undeveloped industrial stands.

The area is serviced by the R513 and R460 roads, which both link to the N4 national highway. Rail services are provided in the industrial area as indicated by black lines in Figure 2. The site is about 2km north-west of the nearest residential area of Rethabiseng. Other residential areas include Ekangala and its extensions to the north east of the site.

2.2 Background to Rayal Industrial Rayal Industrial is the first porcelain roof and floor tile manufacturer in South Africa and the whole of Africa. Brought to South Africa at the invitation of the Department of Trade & Industry, Rayal has made inroads into the local market and has created permanent jobs in its niche market. The technology and some of the equipment is brought from China.

2.3 Capacity of the facility The existing facility has one production line. Rayal Industrial wishes to bring another production line into operation in the near future. The main building has been sized to accommodate two production lines. The spare space is currently used for storage of finished product. The design capacity of the current production line is 15 000 m2 of tiles per day, whilst current production is around 11 000 m2 per day. This translates to 104 million tons of tiles per annum.

2.4 Existing operations at the site The Rayal Industrial facility consists of raw material storage, access roads, synthetic gas plant, ball mills for crushing of raw materials, dryer for crushed material, crushed material (powder) storage, tile press, tile dryer, tile glazing and printing, tile kiln, automated packaging. These units are shown in the process flow diagram given in Figure 3, the site layout is shown in Figure 4, and the process is described below.

2.4.1 Raw material storage Raw material is stored in walled, covered concrete bunkers at the northern end of the site. Trucks are allowed access at the northern end via a secure access gate and material is weighed on a weigh bridge. From the bunkers, material is taken to the ball mill using trucks and bulldozers, as required. Table 3 lists the raw materials that are stored on the site, the type of storage and the area occupied for raw materials storage.


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Figure 1: Locality of the Rayal Industrial facility in the City of Tshwane Metropolitan Municipality


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Figure 2: Site location of the Rayal Industrial facility within Ekandustria, showing surrounding areas


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Table 3: Raw materials stored on site

Raw material Maximum amount used per annum

Area and type of storage

Coal nuts 15,000 ton 1 175 m2, covered storage

Duff coal 7,000 ton Feldspar 3,300 ton

4 427 m2 covered storage 1 600 m2 uncovered storage

Clay 16 6,000 ton Clay 19 6,000 ton Clay 21 6,000 ton Cyclone fine 7,000 ton Mixed stone 6,000 ton White clay 1,100 ton Kulu 40 300 ton Screen sand 11,000 ton

2.4.2 Synthetic gas plant Synthetic gas is a fuel made up of methane, carbon monoxide, hydrogen, carbon dioxide and water vapour that is produced from coal, biomass or natural gas, by reacting it with water and air/oxygen. At Rayal Industrial, coal is used to produce synthetic gas, which is then used as the fuel for the tile dryer and kiln. Large nut coal burns in the gasifier, where the right amount of air and water vapour is sent through the induced draft fan (combustion fan) into the gas furnace.

The raw synthetic gas contains some dust and tar. It is sent through a dust-extraction unit, electrostatic tar catcher, and electrostatic light oil catcher to produce a clean synthetic gas, which is used in the kiln and tile dryer. In order to prevent waste, tar and light oil from the gas cleaning system is used in the coal water slurry furnace, which provides heat to the dryer for crushed materials. The coal dust is sent to the coal water ball mill, from where it is used in the coal water slurry furnace.

Ash from the gasifier is collected in drums at the bottom of the gasifier, and is temporarily stored on site. The ash is taken off site by a brick making facility.

2.4.3 Ball mills for crushing of raw materials The facility has a Coal Water Ball Mill and a Raw Material Ball Mill. These are significant electricity users and are often operated at night to minimise the impact on the local electricity grid. As a result, both mills are operated on a batch basis.

Coal Water Ball Mill Coal duff and coal dust are milled in this ball mill for a certain period of time to create a liquid that will be sprayed into the Coal Water Slurry Furnace.

The ball mill is operated for 8 hours of the day and produces 10 tons of slurry per day. This is sufficient for a day’s production requirements. The slurry is stored in a concrete reservoir from where it is pumped to the coal water slurry furnace.

Raw Material Ball Mill Raw materials from the storage areas are moved by truck and bulldozer to this ball mill. Different raw materials are mixed in the correct proportions required for the specific tile to be manufactured. The materials are crushed in the ball mills into a liquid slurry, where the particles are reduced to a fine powder consistency. The slurry is stored in an underground


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concrete storage bunker. When required, the slurry is pumped from the storage bunker to the dryer for crushed materials.

The ball mill is operated for 13 to 15 hours per day, and produces up to 100 tons of slurry per day, depending on the production rate of the rest of the facility.

2.4.4 Coal water slurry furnace There are two sources of fuel to this furnace: coal water slurry from the coal water ball mill and oil and tar from the gas cleaning plant. These two streams are mixed together in a given ratio (to meet the temperature required in the furnace) and the mixture is jet sprayed into the furnace and ignited. The fuel burns at temperatures of approximately 1200 degrees. The hot gas stream in the furnace is sent to the spray tower dryer. The furnace uses approximately 12 tons of coal dust and coal duff per day to meet the spray tower production requirements.

Ash is collected in drums at the bottom of the furnace and is temporarily stored on site. The ash is taken off site by a brick making facility.

2.4.5 Dryer for crushed material The raw material slurry stored in the underground bunker is pumped to a spray tower dryer and is forced through high pressure jets. The hot gas stream generated in the Coal Water Slurry Furnace is pushed into the spray tower and causes the raw material slurry to dry out, becoming a powder as the moisture is extracted from it. The powder drops to the bottom of the spray tower. The moisture laden air from the spray tower passes through a cooling system to re-capture the water. The re-captured water is sent to the recycling pond on site. The dried powder (10% moisture content) is stored in metal silo-type storage bins and is used as required for manufacturing the tiles. Some moisture is lost through the spray tower vent in the form of steam.

The spray tower and silos for storage of the powder are housed within the main building of the facility. The spray tower has a design capacity of 9 000 tons/month of dried powder.

2.4.6 Tile press Powder from the storage bins drops into a press machine. The press uses different moulds for the specific tile that needs to be made. The powder is pressed by the mould to create the flat floor tile or wavy roof tile shape, and is released on a solid base, on a conveyor track. The conveyor moves the pressed powder to the dryer. In this form, the powder has not become bound and crumbles easily if touched. Therefore, the conveyor system moves each tile along from this point forward until the tile has been baked and can be packaged.


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Figure 3: Process flow diagram for the Rayal Industrial facility


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Figure 4: Site Layout Plan


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2.4.7 Tile dryer The pressed tiles move through the tile dryer on the conveyor track. Waste hot air from the kiln is passed through the dryer to remove the remaining moisture and bind the powder. Additional heat can be added by burning synthetic gas in the dryer if required. The dryer allows the powder to become completely dry, ensuring no weak spots in the tile, and to allow the powder to bind to a limited extent, so that the tile does not crumble if touched. The dryer is essentially a long drum through which the conveyor track enters one side and exits the other side, moving the tiles along from one end to the other.

Any broken or damaged tiles exiting the dryer are collected and sent to the raw material ball mill, to be re-used.

From the dryer, the conveyor moves the tiles to the glazing and printing sections.

2.4.8 Tile glazing and printing Once the drying process is complete, the roof tiles are colour glazed and the floor tiles are first glazed and then screen-printed or digitally printed to give the tiles the desired colour and pattern. The tiles move along the conveyor and the glazing and printing is automated to minimise touching and handling of the tiles. Staff observe the entire process to ensure quality control. The tiles are now ready for the kiln where they can be baked to form a tough but beautiful porcelain tile.

Any damaged product from the tile glazing and printing sections are collected and sent to the raw material ball mill, to be re-used.

2.4.9 Kiln Tiles move through the kiln, where they are fired at temperatures of up to 1200 °C and thereafter gradually cooled as it exits the kiln. Like the dryer, the kiln is a much longer drum and the tiles stay on the conveyor as they enter the kiln on one end and exit the other end. The kiln utilises the synthetic gas, which is burned through a series of gas burners inside the kiln to heat up the tiles. Towards the exit, the tiles are air cooled.

Baked tiles cannot be re-used as raw material. Substandard tiles are sold to the public and/or small retailers. Broken or unusable tiles are temporarily stored on site. Local builders collect the broken, unusable tiles which they use as an inert fill for excavations.

2.4.10 Packaging The roof tiles are immediately packed after the kiln whereas the floor tiles are edged around the 4 sides (bevelled) before being automatically boxed, packed and palletised. Packaging depends on the type of tile produced and on the branding requirements for that batch of tiles. Packaged tiles are stored within the main building, and are removed from the facility by truck directly to customers.

Waste packaging is stored temporarily on site and is collected by plastic and paper recyclers.

2.4.11 Water management There are two water management systems on site, as described below.

Storm water management All storm water is diverted from storage areas and the roofs of buildings via drains and channels to the municipal storm water drain that runs along the property boundary. This water is considered clean and uncontaminated and is allowed to leave the site.


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Process water management All recovered water within the process is sent to the recycle pond. At the recycle pond, calcium carbonate is added to the water to remove any sulphates in the water. The resulting calcium sulphate sludge drops to the bottom of the recycle pond. The pond is dredged regularly to remove the sludge. The sludge is temporarily stored on site to dry it out, and then included in the raw material sent to the raw material ball mill (i.e., it is incorporated into the tile making process). The ball mills use up all the water sent to the recycle pond.

The site has a borehole to supplement its process water stream. The borehole has a yield of 19.7 m3/hour. Water from the borehole is pumped directly into the recycle pond

All water holding systems are impervious, either plastic, metal or concrete. The recycle pond has a capacity of 2 280m3

2.5 Water supply The site obtains municipal water for drinking purposes and for ablutions. The site uses borehole water as make-up water for its tile making processes. The quantities of water used on site needs to be verified.

2.6 Waste management The following Table provides a description of the waste streams generated on the site. A waste management plan needs to be developed for the site and is included as a management measure in the EMPr since quantities and classification of waste streams were not known at the time this report was compiled. (Appendix 10).

Table 4: Waste streams generated at Rayal Industrial

Source of Waste Waste stream description How this stream is managed

Synthetic gas plant

Ash Temporarily stored on site. Facility plans to give this to brick makers.

Tar and oil Used as a fuel in the coal water slurry furnace

Coal dust Used as a fuel in the coal water slurry furnace

Coal water ball mill No waste

Coal water slurry furnace Ash Temporarily stored on site.

Facility plans to give this to brick makers.

Raw material storage and handling

Spills of material Material is picked up and returned to storage for use

Raw material ball mill and spray tower dryer

No waste

Tile press, tile dryer, tile glazing and printing

Damaged or broken tiles Sent to the raw material ball and re-used

Kiln

Substandard tiles Sold to the public/small retailers Broken/unusable tiles Temporarily stored on site, taken

by builders as an inert fill for excavations

Powder from edgings of floor tiles

Collected and sent to the raw material ball mill for re-use

Packaging Waste packaging Taken by plastic and paper recyclers

Entire facility Storm-water Considered clean and released to the municipal storm water


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Source of Waste Waste stream description How this stream is managed drain

Process water Treated and re-used via the recycle pond

Office and general waste Taken to the municipal landfill

2.7 Motivation for this project

2.7.1 Why did Rayal Industrial establish a facility in South Africa? Rayal Industrial is a foreign investment company that was brought to South Africa by the Department of Trade and Industry. Rayal indicates that, prior to establishing the facility, it met with various stakeholders, including the then Kungwini Local Municipality and the Department of Town Planning and Rural Development. The Department of Town Planning and Rural Development assisted the company in complying with the necessary requirements, such as acquisition of land, site plans, geotechnical reports, etc.

2.7.2 Why did Rayal Industrial fail to undertake the EIA and AEL applications prior to establishment?

The Directors of the company, who are Chinese nationals, were unaware that an environmental authorisation and an atmospheric emission licence were also required for the facility prior to establishment. It would seem that the Kungwini Local Municipality was under the incorrect assumption that an environmental authorisation and an atmospheric emission licence were not required because the land was already zoned for industrial use. Hence, the company was not made aware of these requirements when it was assisted by the Municipality to establish its facility.

2.7.3 How has the facility benefited the local community? More than R250 million has been invested in the facility by Rayal Industrial, for which various incentives were provided by our Department of Trade and Industry.

Currently, the facility employs 270 local people from the surrounding areas. All staff receive on-site training.

In addition, downstream business and job opportunities have been realised with regards to the manufacture and supply of boxes, pallets, packaging film, and for the supply of raw materials, as well as transportation of raw materials and finished goods.


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3 PUBLIC PARTICIPATION This section provides information about the public participation process that is being followed as per the requirements stipulated by GDARD in its letter dated 20 August 2015.

3.1 Objectives of Public Participation The objective of the public participation process in this application process is to provide sufficient and accessible information to interested and affected parties (I&APs) in an objective manner so as to:

• Assist the I&APs to identify issues of concern, and providing suggestions for enhanced benefits and alternatives.

• Contribute their local knowledge and experience. • Verify that their issues have been considered by the EAP and the specialist investigation. • Comment on the findings of the Section 24G and AEL Report, including the measures

that have been proposed to enhance positive impacts and reduce or avoid negative ones.

The key objective of public participation is to ensure transparency throughout the process and to promote informed decision making.

3.2 Identification of stakeholders and an I&AP register Stakeholders, representing the following sectors have been identified and a contact list has been compiled which served as the initial I&AP database and register of I&APs:

• The owner and occupiers of the Rayal Industrial premises in Ekandustria • Landowners and occupiers adjacent to the Rayal Industrial premises • Relevant organs of state including national, provincial and local government (including

the municipal councillor) • Organised groups such as the rate payers’ association, water and environmental forums • Media

The identification of stakeholders is on-going and is refined throughout the process. The initial I&AP database and all I&APs responding to the announcement of the application process will be included in the I&AP register and will be informed of progress and the opportunity to comment on the assessment. The initial I&AP database is appended as Appendix 5.

3.3 Site Notice A number of copies of the site notice were placed on Wednesday, 13 April 2016 at and around the Rayal Industrial premises in Ekandustria. Proof of placement will be provided in the final version of the Section 24G and AEL Report. Please refer to Appendix 4 for a copy of the site notice. The site notice provides information as per the GDARD advertising guideline which was provided with the Directive on 20 August 2016.

3.4 Written notice and involving disadvantaged stakeholders Written notice of the application was provided to the initial I&APs database. A Background Information Document (BID) and a comment sheet was emailed to those listed and copies of the BID were hand delivered to I&APs adjacent to the facility on 13 April 2016. The hand delivery of BIDs was used as an opportunity to involve the immediate surrounding disadvantaged communities. With the handing out of the BIDs the contents of the document were discussed and explained. Individuals were invited to contact the public participation office telephonically should they required any further verbal explanations of the information.


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The BID provided background to the application, a clear description of the activities applied for, the process to be followed for the application and how and when stakeholders can participate. Information about the availability of the draft Section 24G and AEL Report, its review period and where stakeholders can obtain a copy of the report was also provided. Please refer to Appendix 5 for a copy of the BID and comment sheet.

3.5 Advertisement An advertisement was published in the Streeknuus newspaper on Friday, 15 April 2016. The content of the advertisement complies with the GDARD advertising guideline which was provided with the Directive on 20 August 2016. Please refer to Appendix 4 for a copy of the advertisement.

3.6 Availability of the Section 24G and AEL Report for public review This Draft Section 24G and AEL Report was made available for public review from 15 April to 20 May 2016. Notice about the availability of the report for review and how stakeholders may access the report was provided in the advertisement published, the site notices, the BID and I&APs were again reminded of the opportunity to comment via emails personally sent to them.

The draft report was made available as follows:

Printed Copies

Ms Grace Kotlolo Bronkhorstspruit / Kungwini Public Library, cnr

Generaal Louis Botha / Mark Street, Bronkhorstspruit

012 358 6483 / 071 671 8626

Mr Haroon Khan Rayal Trading, 14 Galena Street, Ekandustria 013 933 3846 Electronic Copies

Website download www.jaws.co.za CD copy Please call Anelle Lötter / Sibongile Bambisa 012 667 4860

I&APs will be notified of the availability of the Final Section 24G and AEL Report via an email/fax/letter notification. I&APs will be requested to send their final comments to the GDARD and the City of Tshwane and to copy the public participation practitioner.

3.6.1 Comments and Responses Register The comments received from I&APs will be recorded and documented in a Comments and Responses Register (CRR). The register allow for each comments from an I&AP to be listed and a response from the EAP and/or Rayal Industrial will be provided. The comments received will be considered for the finalisation of the Section 24G and AEL Report. A copy of the CRR will be appended to the Final Section 24G and AEL Report to be submitted to the GDARD and City of Tshwane.

3.7 Notification of GDARD Decision The GDARD decision regarding the application and the opportunity to appeal the decision will be announced to the I&AP register when the decision is issued by the GDARD. The announcement will be made by email/fax or mailed letter.


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4 RECEIVING ENVIRONMENT This section outlines the receiving environment within which the site exists. Without the detail provided in specialist studies, this section draws from public information for the region.

4.1 Topography The topography around the Ekandustria site is generally flat with an average slope of 8.1%. The site has an elevation of between 1505 m and 1510 m, draining towards the north-west.

4.2 Climate Mean daily temperatures in the area arrange between 17°C and 34°C in January to between 2°C and 20°C in July. Rainfall occurs in the summer months, with dry winter months as indicated in the Figure below. The average precipitation for the area is in the region of 600mm to 700mm per annum, with most of the rain occurring in the months of January and December. Almost no rain is experienced in July.

Figure 5: Climatic data for the Wonderboom Airport, closest weather station to the site (courtesy of Meteoblue website)

The predominant wind direction at Ekandustria for the period 2010-2013 is from the northeast. Day-time winds are usually from the northern sector (north-west and north-east); however, and night-time wind fields show a stronger predominance from the easterly sector (north-easterly and south-easterly). It should be noted that relatively low wind speeds and very little wind from the south western sector occurs. The wind rose is given below.


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Figure 6: Wind Rose for the Ekandustria area (2010 to 2013)

4.3 Surface water The site drains to the north-west towards an unnamed tributary of the Masokolo River, which drains further north-west into the Elands River, which is part of the B31A quaternary catchment. The Department of Water and Sanitation monitoring programme includes a sampling point on a neighbouring tributary of the Masokolo River, just upstream of the Ekandustria sewage treatment plant. Limited data for the sampling point is available and is given in the table below.

Table 5: Sampling Data at DWS Sampling point (B31_189521) from 1 Jan 1972 to 31 Dec 2010

Parameter Minimum Mean 95%ile Maximum Electrical conductivity (mS/m)

9.7 16.4 19.75 20.6

pH 6.17 6.44 6.97 7.43 Phosphate (mg/ℓ) 0.05 0.3 0.35 0.4

4.4 Ground water The site has a borehole for supply of water. Borehole samples were taken in January 2016 and analysed at Regen Waters, an independent SANAS accredited laboratory. The results indicate that the water quality complies with the SANS Standards -241-2:2015 Ed 2


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Domestic Water (drinking water standard), but that the water contains bacteria of non-pathogenic nature. The borehole water analyses are given in Appendix 3.

Borehole yield testing was undertaken by Waterman, and indicated that the borehole can yield 19 755 ℓ per hour over a 6-hour pump test. The static water level is 10m deep and the dynamic water level went to 1m deep. The borehole is 80m deep. The test certificate is given in Appendix 3.

4.5 Soils and geology A geotechnical investigation was undertaken for the site in July 2011 by Lamola & Raphekwane Engineers & Project Managers, prior to establishment (see Appendix 3). The report indicates that the site is underlain by igneous rock of the Rooiberg and Pretoria Group, Bushveld complex of the Lebowa granite suite, which comprises the locally weathered clay material.

The site’s typical soil profile consists of a variable but thick layer of topsoil and hillwash, with underlain clay. The soil profile consists of a topsoil horizon of typically 300mm covering the reddish brown, silty clay hillwash layer up to 1.2m deep and a firm reddish brown silty clay layer with ferrigunisation and concretion of 20mm, with depth varying up to 3m.

Ground water was not encountered during the investigation.

4.6 Air quality The City of Tshwane Metropolitan Municipality conducts ambient air quality monitoring as part of the Tshwane Air Quality Network. Data obtained at the Ekandustria monitoring station which is the closest to the site are summarised below. Carbon monoxide (CO), nitrous oxide (NO2), sulphur dioxide (SO2) and particulates derived from observations at this station were obtained from DEA’s SAAQIS webpage (http://www.saaqis.org.za/).

CO The hourly average and diurnal CO concentrations observed at the Ekandustria station are well below the DEA NAAQS limit (30 000 µg/m³ / 26 ppm). The expected CO hourly average concentration at the proposed development is expected to be within the same range as that of the Ekandustria station, with a maximum of about 3 490 µg/m³ (3 ppm).

NO2 The hourly NAAQS of 200 µg/m³ (106 ppb) was exceeded on numerous occasions during the period July 2012 to December 2012, but not thereafter in 2013 or 2014. It is therefore anticipated that the highest hourly average NO2 concentration at the proposed development would be similar at the levels measured for 2013/2014, i.e. between 57 µg/m³ and 115 µg/m³ (30 ppb and 60 ppb). The data also shows an increase in NO2 concentrations between 4am and 8am in the morning, and between 4pm and 8pm in the evening.

SO2 The highest hourly concentrations were observed to be below the NAAQS limit value of 350 µg/m³ (134 ppb) throughout the monitoring period. It is therefore probable that the levels at the study site does not exceed the air quality standard for SO2.

Particulate Air Concentrations The daily average NAAQS limit value for PM10 (75 µg/m³) were shown to be exceeded 4 days in 2013 and about 20 days between March and August in 2014. The particulate air concentrations were higher during the night. Two very distinct peaks are also observed at about 6h00 and 18h00, which coincides with increased household fires and the development of a night-time stable layer. An annual average concentration was determined as 46.7 µg/m³ (from measured monthly average concentrations), which exceeds the annual average NAAQS limit value for PM10 (40 µg/m³).


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The particulate air concentrations at the study site (background) are expected to be high and could also exceed the NAAQS limit value.

4.6.1 Ecology The site sits close to the watershed, but falls entirely on the western side that drains to a tributary of the Masokolo River. According to the Metsweding District Municipality Environmental Management Framework (2011) “biodiversity within the Metsweding area has been highly affected by land transformation activities, notably urban expansion, mining and agriculture. The most sensitive and valuable features within the area include the ridges (notably the Bronberg area), remaining areas of intact natural vegetation, wetlands and river and riperian areas”. The vegetation types in the district are shown in the Figure below. The site lies within the Rand Highveld grassland, however, previous Google Earth images indicate that site was fenced off for development as early as 2004 (see figure below) and that on site, no significant wetlands, pans or sensitive features existed at that time or subsequently.

Figure 7: Vegetation types in the Metsweding District Municipality (copied from the Metsweding District Municipality EMF, 2011)


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Figure 8: Historic aerial photography for the site from 2004


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4.7 Social According to the 2011 Census, Ekangala (which includes Ekandustria) has a population of 48 493 people, consisting of 13 618 households. Females make up 51.5% of the population, whilst males make up 48.5%. Black Africans consist of 99% of the population, with 0.3% Indian/Asian, 0.3% Coloured and 0.4% classified as Other. Only 0.04% of the population are classified as White. isZulu is the first language of 33.4% of the population, and isiNdebele is the first language of 28.6% of the population. Other first languages include Sepedi (15%), Sesotho (6%), Xitsonga (4%), SiSwati (3%), Setswana (3%), isiXhosa (2%). English, Tshivenda, Afrikaans and other languages are also spoken by a few of the population.

Although Ekandustria covers 23% of the total area of Ekangala, it holds only 0.2% of the population due to this area being an Industrial area.

4.8 Sense of place Ekandustria is a zoned industrial node, characterised by light to medium industrial developments to the south, east and north east of the site. The closest residential areas are some 2 km to 5 km away from the site, consisting of Rethabiseng in the south east and various parts of Ekangala to the north east. The area immediately to the south-west, west and north-west of the site is currently undeveloped. Thus, the overall sense of place for the site is industrial, surrounded by townships and rural areas.

4.9 Cultural and heritage There are no known cultural or heritage resources on the site or in the surrounding areas.

The Jabulani Junior Primary Private School is situated some 2 km away in Rethabiseng. A number of primary and high schools are situated in the Ekangala area, between 4 and 5 km east-north-east of the site. A police station and a post-office is present in Ekangala. Health clinics are found 4 to 5 km to the north-north-west of the site. The closest formal towns are Bronkhorstspruit about 11 km south-south-east of the site and Cullinan about 17 km to the west-north-west of the site. The edge of the greater Pretoria area lies 25 km to the west of the site.


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5 IMPACT ASSESSMENT

5.1 Methodology for Impact Assessment Potential impacts are scored according to Table 6.

Table 6: Scoring of impacts

SEVERITY OCCURRENCE

Magnitude (severity) of impact

Duration of impact Extent of impact Probability of occurrence

Magnitude Duration Scale Probability

10 Very high/ don’t know

5 Permanent 5 International 5 Definite/don’t know

8 High 4 Long-term (impact ceases after closure of activity)

4 National 4 Highly probable

6 Moderate 3 Medium-term (5 to 15 years)

3 Regional 3 Medium probability

4 Low 2 Short-term (0 to 5 years)

2 Local 2 Low probability

2 Minor 1 Transient 1 Site only 1 Improbable

1 None/insignificant

After ranking these factors for each impact, the significance of the aspects, occurrence and severity, was assessed using the following formula:

SP (significance points) = (magnitude + duration + scale) x probability

The maximum value is 100 significance points (SP). The environmental effects were then rated on the following basis:

SP >70 Indicates high environmental significance

Where it would influence the decision regardless of any possible mitigation. An impact that could influence the decision about whether or not to proceed with the project.

SP 40 - 70 Indicates moderate environmental significance

Where it could have an influence on the decision unless it is mitigated. An impact or benefit which is sufficiently important to require management. Of moderate significance - could influence the decisions about the project if left unmanaged

SP <40 Indicates low environmental significance

Where it will not have an influence on the decision. Impacts with little real effect and which should not have an influence on or require modification of the project design or alternative mitigation

+ Positive impact An impact that is likely to result in positive consequences / effects.


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5.2 Assessment of potential impacts Table 6 provides a summary of the potential impacts, of which the significant impacts are discussed below.

Table 7: Impact Assessment Summary

Environmental Impact

ENVIRONMENTAL SIGNIFICANCE

Before mitigation After mitigation

M D S P Total SP M D S P Total SP

1. Geology Not applicable-the proposed project has not resulted in any changes to the geology.

- - - - - - - - - - - -

2. Topography Not applicable-the proposed project will not resulted in significant changes to topography.

- - - - - - - - - - - -

3. Soils Topsoils would have been lost during excavations. This impact has already occurred and cannot be mitigated.

2 5 1 5 40 M This impact has already occurred and cannot be mitigated.

4. Land capability and use The area is zoned for industrial development therefore no impact. - - - - - - - - - - - -

5. Ecology The facility was developed on a stand zoned for industrial. Historic photo’s do not indicate the presence of sensitive features.

- - - - - - - - - - - -

6. Surface water Spillages or leaks from piping and storage vessels could impact on storm water. None of the solid materials stored on site are noxious or toxic.

4 1 1 4 24 L 4 1 1 2 12 L

7. Groundwater The project has not resulted in changes to ground water. However, underground slurry storage and other water holding structures could contaminate ground water if these leak.

4 3 1 4 32 L 2 2 1 3 15 L

8. Air quality The air impact assessment indicates significant hydrogen fluoride emissions. All other emissions are within emission compliance limits.

6 4 2 5 60 M 2 4 1 5 35 L

9. Noise Noise measures have been implemented on site. Noise levels were observed to be low on site.

6 2 1 4 36 L 2 1 1 4 16 L

10. Visual aspects Steam emitting from the spray tower dryer has a visual impact on the local area. 4 4 2 5 50 M 4 4 2 5 50 M

11. Cultural heritage


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Environmental Impact

ENVIRONMENTAL SIGNIFICANCE

Before mitigation After mitigation

M D S P Total SP M D S P Total SP

The project has not result in any changes to heritage resources. - - - - - - - - - - - -

12. Socio-economic aspects

Investment of R250 million 6 2 3 5 55 M+ 8 3 3 5 70 H+

270 local permanent jobs created 4 4 2 5 50 M+ 6 4 2 5 60 M+

13. Traffic and transport aspects Trucks access the site for raw material deliveries and for transportation of product. R513 is a dual lane road, easily accommodating heavy traffic for this area.

2 2 2 5 30 L 2 2 2 5 30 L

14. Waste management The site will develop a waste management plan to address temporary storage on site. 4 3 1 5 40 M 2 2 1 5 25 L

15. Health and safety Staff health and safety: investigation of dust levels 6 3 1 5 50 M 2 3 1 5 30 L

5.3 Description of identified impacts and recommended mitigation measures This section describes the impacts identified in the summary above.

5.3.1 Surface water The site’s clean and dirty storm water systems were observed to be in place and adequate for the site. Process water is managed through the recycle pond. Water usage is minimised by recovery of water in the cooling system. Any spillage or leaks from the site, could run off into the open area to the west of the site, which leads to the tributary of the Masokolo River. It is noted that most of the site is contained within storm water canals or within buildings. Nevertheless a major spill could result in contaminated water leaving the site.

It is recommended that pipes, pumps and vessels are regularly inspected and maintained to minimise the likelihood of spills and leaks due to major failure.

5.3.2 Ground water A number of the water-holding structures are below ground level. Leaks from these structures could result in contamination of ground water. Whilst most of the materials are not noxious or toxic, the coal water slurry can result in significant pollution of the ground water due to organics present in this stream. These structures are inspected annually to ensure their integrity

It is recommended that annual monitoring of the on-site borehole is carried out and must include an organics analysis. It is further recommended that a civil/structural engineer inspect the water-holding structures and verify their integrity.


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5.3.3 Air quality A detailed air impact assessment has been carried out by Airshed Planning Professionals and their report is provided in Appendix 9. A brief summary is provided here highlighting the main findings of the assessment.

As indicated in Section 1.4.3 above, synthetic gas production, drying and ceramic production are listed activities in terms of the NEM:AQA and therefore these processes need to comply with the national minimum emission standards (MES). The synthetic gas plant does not have routine emissions since it is a closed system to contain the gas that is formed, which is used as a fuel in the drying process.

Emissions from the facility The stacks on site were sampled by independent analytic company C&M Consulting Engineers in November 2015. The following Table summarises the stack emissions for the pollutants of concern associated with each listed activity, and an indication of compliance with the MES.

Table 8: Emissions from the facility compared to the minimum emission standards

Stack Pollutant Maximum release rate as measured at the stack MES

(Mg/Nm3) (mg/Nm³) g/s Tpa

Dryer PM 19.3 0.12 4 50 SO2 334 2.11 67 1 000 NOx 213 1.35 42 500

Kiln PM 14.3 0.03 1 50 SO2 330 0.72 23 400 HF 695 1.53 48 50

Spray tower

PM ‒ 0.172 5 50 SO2 30.3 0.42 13 1 000 NOx 198 2.76 87 500

Legend Blue Complies with MES Red Does not comply with MES

From the above Table, it is clear that the facility complies with the minimum emission standards for the dryer and spray tower, and the emissions are well below the standard. The kiln emissions also comply with the minimum emission standards for SO2 and particulate matter. However, it is significantly out of compliance in terms of its HF emissions.

Dust on site was estimated based on the length of road travelled within the site, the number of trucks, type of trucks, type of materials transported and stored, type of storage, hours of operation, etc. Dust was assessed in terms of total suspended particles (TSP), respirable particles smaller than 10µm (PM10) and respirable particles smaller than 2.5µm (PM2.5). There are no emission standards for dust from an area source. However, dust estimated to be generated on site was included in the dispersion model for the project in order to assess the impact on the local surrounding area.

2 Calculated emission rate for PM10 using emission factor from AP 42, Fifth Edition Compilation of Air Pollutant Emission Factors – Chapter 11.7 Ceramics Products Manufacturing. Assumed granulation through natural gas-fired spray dryer, with venturi scrubber. Tons of dry material produced given as 55,000 ton/annum of powder.


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Predicting impacts of the facility on the local environment The ground level ambient concentrations were predicted at the facility fence line as well as at the closest receptors using the above stack emissions and dust emissions. Two scenario’s were developed: a) using the minimum emission standards for the stacks, and b) using the measured emissions for the stacks. The air impact report provides the background, methodology, assumptions and outcomes for both scenario’s. The scenario using the measures emissions is presented in this report since this is deemed to be a more accurate representation of the facility.

The predicted ground level concentrations were compared to the national ambient air quality standards (NAAQS) for particulate matter, SO2 and NOx. The ground level ambient concentration for HF was compared to international standards since South Africa does not have a national ambient air quality standard for HF. The following sections indicate the outcome of the dispersion modelling.

Impact of Particulates Predicted ground level concentrations for PM10, PM2.5 and TSP are all within compliance of the NAAQS as indicated in the Figures below. However, in light of elevated particulate air concentrations measured at the nearby Ekandustria ambient monitoring station cumulative PM10. PM2.5 and TSP ground level impacts may result in exceedances of the respective daily average and annual NAAQS. The stack emissions are well within the emission standard, therefore dust management measures are proposed to address area source emissions. Detailed measures are spelt out in the EMPr (Appendix 10).

Impact of SO2 Predicted ground level concentrations for SO2 are within compliance of the NAAQS as indicated in the Figures below. No mitigation is required.

Impact of NOx Predicted ground level concentrations for NOx are within compliance of the NAAQS as indicated in the Figures below. No mitigation is required.

Impact of HF As noted above, the HF emissions from the site significantly exceed the minimum emission standard. Predicted ground level concentrations for HF do not comply with international ambient air standards. as indicated in the Figures below. It is noted that the extent of the non-compliance is outside the site boundary but does not impact on any of the identified receptors in close proximity to the site.

Measures to reduce HF emissions are proposed. Detailed measures are spelt out in the EMPr (Appendix 10).


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Figure 9: Dispersion modelling results for PM10, which indicates compliance with the daily NAAQS outside the factory fence-line

Figure 10: Dispersion modelling results for PM2.5, which indicates compliance with the daily NAAQS outside the factory fenceline


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Figure 11: Dispersion modelling results for TSP, which indicates compliance with the dust control regulations outside the factory fenceline

Figure 12: Dispersion modelling results for SO2, which indicates compliance with the NAAQS hourly limit


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Figure 13: Dispersion modelling results for SO2, which indicates compliance with the NAAQS daily limit

Figure 14: Dispersion modelling results for SO2, which indicates compliance with the NAAQS annual limit


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Figure 15: Dispersion modelling results for NOx, which indicates compliance with the NAAQS hourly limit

Figure 16: Dispersion modelling results for NOx, which indicates compliance with the NAAQS annual limit


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Figure 17: Dispersion modelling results for HF, which indicates non-compliance with the hourly CALEPA limit off-site.

Figure 18: Dispersion modelling results for HF, which indicates non-compliance with the annual CALEPA limit off-site.


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5.3.4 Noise An occupational noise survey was carried out by Mr E Steenkamp in 2014. His findings were that employees working at the synthetic gas plant during the loading of coal and sludge removing actions, all milling operations, tile press area, tile packing, cooling fans, edging operations and palletising operations at the end of the line are exposed to noise exceeding the statutory limit of 85 dB (A), and recommended the following measures:

• General maintenance such as replacement of worn parts, lubrication etc. to reduce noise emitted.

• After reduction of noise through engineering control has proven to be impracticable use of personal protective devices such as ear plugs and ear muffs with a noise reduction rating of at least 30dB (A).

• Identification of noise sources by placing signs complying with SANS Code of Practice 1186 in conspicuous places on the machines/sources.

• Where the noise rating levels cannot be reduced to below 85 dB (A), the area must be demarcated as a noise zone by placing signs complying with SANS Code of Practice 1186 in conspicuous places along the boundaries of the zone.

• Undertake occupational noise monitoring as per the Occupational Health and Safety Act requirements to ensure compliance with noise regulations.

• Medical surveillance of personnel on placement, periodically during their employment and on termination of employment.

• Active supervision and implementation of the use of hearing PPE by monitoring the use of PPE and disciplining staff that do not comply.

Noise measures were observed to be implemented on site, however, subsequent noise monitoring and medical surveillance has not been confirmed.

It is recommended that annual monitoring of noise at the noise zones and at the fence boundary is carried out. It is also recommended that the medical surveillance is implemented to protect the company and its staff.

5.3.5 Visual Most of the activities undertaken on site are within buildings. Trucks transporting raw materials and product will create localised dust. The site has a large stack for the release of steam from the dryer. This stack has a visual impact locally. However, since the stack is fairly low, the visual impact is mitigated to some extent. There is no further mitigation for this impact and since the site is present in an industrial area, the impact thereof is not considered to be significant.

5.3.6 Social There are two aspects to the social benefits of this project.

Investment and local development The site required an investment of R250 million which benefited the local, regional and national community. In addition, the company provides staff training and has initiated training for local suppliers and contractors with regards to raw materials and product. The site is also the first porcelain roof and tile manufacturer in South Africa, and these products were previously imported to South Africa.

It is recommended that the company structure its training and development initiatives to maximise the benefit to the local and regional communities and businesses.

Local job creation The facility has provided 270 permanent jobs to local people.


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It is recommended that the company continue to train and develop staff in order to increase the amount of local labour it uses on site.

5.3.7 Traffic The site receives its raw materials by truck and product is transported from the site by trucks. On several site visits, traffic was not observed. The site access leads onto the R513 within a few 100 m. The R513 is dual carriageway road, designed to service the Ekandustria industrial area. The R513 links to the N4 within a few kilometres to the south of the site. The N4 is designed to provide easy access up to Maputo to the east and to Rustenberg and eventually Botswana to the west. This well – structured access system results in insignificant traffic from the site.

It is recommended that incoming and outbound loads are well managed and scheduled to minimise potential disruptions on the R513 or at the site access.

5.3.8 Waste Whilst most wastes are recycled and re-used on site, management of temporary storage of waste needs to be addressed.

It is recommended that a site waste management plan is developed.

5.3.9 Health and safety Some staff were observed to wear dust masks. Occupational health and safety data for the site was however not available to assess potential impacts. The site indicates that it is in the process of developing its ISO 9001 EMS, to manage and control quality, health and safety and environmental aspects on the site.

It is recommended that an occupational health and safety review is carried out by the site. Such a review should make recommendations for the following aspects at the site:

• Dust within the main building and whether additional personal protective equipment and/or dust abatement measures are required.

• Noise as per the above Section 5.3.4.

• Use of hard-hats, safety shoes, goggles, protective clothing and other personal protective equipment that would be relevant for each area of the operation.

• Visitors safety induction and personal protective equipment for visitors.

• Monitoring of workers health.


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6 ENVIRONMENTAL MANAGEMENT PROGRAMME A stand-alone EMPRr is provided in Appendix 10. The EMPr includes the following information:

1. Mitigation measures

2. Management measures

3. Monitoring programme

4. Emergency preparedness plan

5. Environmental awareness plan

6. Inspections and audits

7. Reporting

A stand-alone document was developed that will allow for the document to be updated as the operation obtains more information in terms of environment, health and safety and as it implements the EMPr.


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7 INFORMATION REQUESTED BY GDARD The table below indicates the requirements of the GDARD Directive and how these are met/ will be met in the submission to GDARD.

Table 9: GDARD Requirements for this Application

GDARD Directive Requirement Where/How this is addressed in this Report Item No. Requirement

5.3 Not expand the activity/ies applied for pending the finalisation of the S24G process, as expansion of the activity/ies may change the nature and extent of the activity/ies as applied for in the submitted section 24G application, and consequently impact on the final decision to be made by the Department.

The company will not expand its facility until a new EIA has been conducted.

5.4 Immediately (within 24 hours) cease with any activity/ies that may, as a result of operation of your facility, cause significant harm to the environment and the human health.

No such risks were identified when the Directive was issued.

5.5 Immediately (within 24 hours) put in place environmental management measures to manage any pollution that may occur as a result of the operation of the activity/ies, especially with regards to the (i) air quality management (this may include installation of air emissions control systems and air quality monitoring systems}, (ii) water pollution as a result of runoff of contaminated storm water, (iii) storm water management (separation of clean and dirty water), (iv) Waste Management (general and hazardous waste management).

No such risks were identified when the Directive was issued.

5.6 Immediately (within 24 hours) comply with all the instructions made in this Directive. Please be advised that this directive should not be construed to be an environmental authorisation from the Department. Should there be any non- compliance discovered on site during the S24G process, then the Department will instruct you to cease with the operation of all the activity/ies and the MEC or the delegated authority may decide whether to refer the matter for criminal proceedings.

The company has endeavoured to comply with the requirements of the Directive.

5.7 Within thirty (30) days contain and prevent any pollution observed on site that may occur on site as a result of the operation of the activity/ies indicated in paragraph 1 above.

As indicated under 5.4 and 5.5 above, no such risks were identified when the Directive was issued.

5.8 Within four (4) months from the date of receipt of this Directive, investigate, evaluate and assess the impact of the activity on the environment, compile and submit a report containing the information requested below.

The Company has applied for extensions of the time frame. Please see Appendix 1.

5.9 Appoint an Environmental Assessment Practitioner and compile an Environmental Impact Report (EIR) containing the following:

See below.

5.9.1 Appointed Environmental Assessment Practitioner (EAP) 5.9.1.1 Jn the introductory section of the report, the details of the Environmental Assessment Practitioner (EAP) who compiled the report must be clearly indicated. The expertise of the EAP with specific reference to undertaking public participation processes, the translation of scientific into an environmental impact report; understanding and interpretation of financial information must be included

5.9.1.1 – The details of the EAP is provided in Section 1.3. 5.9.1.2 – The EAP’s declaration is included in Appendix 2.


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upfront within this section of the report. 5.9.1.2 A sworn affidavit by the EAP that the information provided to the Department was at no stage influenced by the applicant and that the EAP has explained the potential consequences of submitting this application.

5.9.2 Public Participation Process A description of the public participation process followed during the course of compiling the report, including all comments received from l&AP's and an indication of the manner in which these were addressed must be submitted to the Department by the EAP. The public participation process will be considered sufficient in the event that the following requirements are met and the EAP has submitted proof thereof. 5.9.2.1 Notice must be given to all potential interested and affected parties by fixing a notice board at a place conspicuous to the public at the boundary or on the fence of where the activity occurred (refer to the attached advertising guideline). 5.9.2.2 Written notice must be given to- • the owner or person in control of that land if the applicant is not the owner or person in control of the

land; • the occupiers of the site where the activity is being undertaken, was undertaken, or is to be

undertaken; • owners and occupiers of land adjacent to the site where the activity is being undertaken, was

undertaken, or is to be undertaken; • any organisation of ratepayers that represent the community in the area; • the municipal councillor of the ward in which the site is situated and/or the municipality which has

jurisdiction in the area. The Environmental Component of the relevant Municipality must be formally invited to register as !&AP and be provided a thirty (30) day period within which to comment on the application for rectification. A copy of their comments and/or objections must be submitted along with the information requested above; and

• any organ of state having jurisdiction in respect of any aspect of an activity triggered; 5.9.2.3 The notice and notice board must include colour photographs of the site, each illegal activity and

5.9.2.1 – A copy of the site notice is provided in Appendix 4. Proof of placement will be included in the Final S24G Report. 5.9.2.2 – Written notices are provided in Appendix 5. 5.9.2.3 Photo of the site notice will be included in the Final S24G Report. 5.9.2.4 – A copy of the advertisement is provided in Appendix 4. Proof of placement will be included in the Final S24G Report. 5.9.2.5 See Appendix 4 and Appendix 5 which includes copies of the notices. 5.9.2.6 – Please see Appendix 5 and Appendix 7 for a copy of the BID and all correspondence to I&APs. 5.9.2.7 Please see Section 3 where the


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transgression point. 5.9.2.4 An advertisement must be placed in at least one local and one provincial newspaper3 (refer to the attached advertising guideline).Proof of the publication of the notice, placement of the notice on site and notifications must be submitted). 5.9.2.5 The notice, notice board and newspaper advertisement referred to above must include the following- • details of the application which is subjected to public participation; • details of the competent authority to whom the application has been submitted to; • a statement that the activities have commenced illegally and that the application is for ex post facto

authorisation in respect of the illegal activities; • a list of illegal activities commenced and/or undertaken without approval; • the nature and location of the activity to which the application relates; • where further information on the·application or unlawful activity can be obtained; and • the manner in which, and the person to whom, representations in respect of the application may be

made by interested and affected persons. 5.9.2.6 Interested and affected persons must be afforded the opportunity to comment on the application made. To this effect, the EAP must provide the interested and affected parties with the Background Information Document (BID) which provides, but not limited, a clear brief description of the activity/ies applied for, the impacts that arise as a result of operation of such activity/ies and the mitigation measures that will be implemented to manage such impacts. 5.9.2.7 A description of the manner in which disadvantaged persons (e.g. instances of illiteracy, disability, etc.) were accommodated in the public participation process. 5.9.2.8 Interested and affected persons must be afforded a thirty (30) day comment period from the date of advertisement/notice. The EAP must ensure that the comments of interested and affected parties are recorded in reports and the written comments, including records of meetings, are attached to the EIR referred to above. 5.9.2.9 A register of interested and affected parties must be opened and maintained, which contains the names, contact details and addresses of- • all persons who, as a consequence of the public participation process • ·conducted in respect of the application, have submitted written comments or attended meetings

with the applicant or EAP;

PP process is described. 5.9.2.8 – Please see Section 3, Appendix 5 and Appendix 7. Comments from I&APs will be included in the Final S24G Report. 5.9.2.9 – Please see Appendix 5 for the initial I&AP database. The register will be included in the Final S24G Report. 5.9.2.10 –Any requests during the comment period will be attended to and will be included in the Final Report.

3 The Directive indicates one local and one provincial newspaper, whilst the GDARD advertising guideline attached to the Directive indicates that one local or one provincial newspaper. This discrepancy was clarified with the GDARD and since The Streeknuus is distributed to the surrounding communities, it was agreed that the advertisement will appear in that newspaper only.


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• all persons who, after completion of the public participation process have requested the applicant or the EAP managing the application, in writing, for their names to be placed on the register; and

• all organs of state which have jurisdiction in respect of the activity to which the application relates. 5.9.2.10 The EAP must give access to the register to any person who submits a request for access in writing.

5.9.3 Scientific Reports and Other Requirements 5.9.3.1 A detailed description of all the activities that are undertaken at the site in terms of this application. It is advisable to include all aspects of the activities on site in order to avoid the need for amendments and thus at a later stage delay the section 24G process, including but not limited to: (a) A site layout plan indicating the location and physical footprint (in square meters) of all developed infrastructure and structure associated with the listed activities applied for; (b) A total size of the area transformed; (c} Details on the capacity of the facility in terms of production; (d) A clear description of the raw material warehouse and the Ball Mills (the size of the area in square metres); (e) A clear description of the coal storage area and also the storage areas for the sand and concrete that is used in the process and the quantity; (f) A detailed description of the process flow which must also include diagrams, the nature and quantity of inputs (raw materials), outputs and by-products associated with the activity; (g) A clear description of storm water management on site, especially with regards to the separation of clean and dirty water and containment of contaminated effluent generated on site; (h) Discussion on the waste water treatment plant and the gasification plant; (i) A discussion on the impacts of the activity on the ambient air quality of the site and the surrounding area; j) Discussion on possible health effects associated with the operation of the facility including measures put in place to protect employees from such impacts; (k) Discussion on any complaints received from the public with regards to the operation of the facility on site; (l) A4 (210mmx297mm) colour photographs taken 10 meters away from the Northern, Eastern, Southern and Western direction of the following: • All structures associated with the activity applied for; and • Other relevant areas to the application. 5.9.3.2 A description of the environment that has been and may further be affected by the activity and the manner in which the physical, biological, social, economic and cultural aspects have been and may

5.9.3.1 – Please refer to Section 2 and Section 5. Photographs are given in Appendix 8. 5.9.3.2 – Please see Section 4. 5.9.3.3 – Please see Section 2.7 5.9.3.4 – Please see Section 5. 5.9.3.5 – Please see Appendix 10: EMPr 5.9.3.6 – Please see Appendix 10: EMPr 5.9.3.7 – Please see Appendix 10: EMPr 5.9.3.8 – Please see Section 4. 5.9.3.9 – No soil pollution has been identified on site. 5.9.3.10 A waste management plan will be developed for the site as committed to in the EMPr. Please see Appendix 10: EMPr


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further be affected by the activity. 5.9.3.3 Information on how the local community has benefited I will benefit further from the development, including any social responsibility programmes that will be undertaken by the company. 5.9.3.4 An assessment of the nature, extent, duration, impact and significance of the consequences for or impacts on the environment of each of the activities unlawfully commenced with, and the cumulative impacts on the environment must also be discussed. An indication of the methodology used in determining the significance of actual and/or potential environmental impacts must be outlined. The effects of the activity on the affected community must be described. 5.9.3.5 An environmental management programme must be submitted as part of the report including- (a) Details of the person who prepared the environmental management programme; (b) The expertise of the person who prepared the environmental management programme; (c) The name and contact details of the person or Environmental Control Officer responsible for the monitoring of compliance to the EMPr; (d) information on all mitigation measures undertaken, or that will be taken to address the environmental impacts that have been identified in the EIR, including environmental impacts or objectives in respect of- • Operation or undertaking of the activity; • Rehabilitation of the environment; and • Closure (e) Proposed mechanisms and frequency for monitoring compliance with and performance assessment against the environmental management programme and reporting thereon; (f) An environmental awareness plan describing the manner in which the applicant intends to inform his or her employees of any environmental risk which may result from their work. The awareness plan must also include details on all environmental issues that were identified during the environmental impact assessment process, an assessment of the significance of each issue and an indication of the extent to which the issue could be addressed by the adoption of mitigation measures. 5.9.3.6 An environmental awareness plan describing the manner in which the applicant intends to inform his or her employees and any third party of environmental risk which may result from their work activities. The awareness plan must also include details on all environmental issues that were identified during the environmental impact assessment process, an assessment of significance of each issue and an indication of the extent to which the issue could be addressed by the adoption of mitigation measures. 5.9.3.7 An emergency response plan for the operation of the activity, including an indication of training

5.9.3.11 A geotechnical assessment is provided in Appendix 3. This report does not conform to the Directive requirements because it was carried out in 2011. An air impact assessment is provided in Appendix 9 and complies as far as possible with the Directive requirements. 5.9.3.12 The signed submission will be included in the Final Report to be submitted to the GDARD. 5.9.3.13 Please refer to Item 5.5 of this table above. 5.9.3.14 Please refer to Section 1.4 of the report. 5.9.3.15 This application covers the NEMA and NEM:AQA requirements. A waste management plan will be developed by the site, and any NEM:WA requirements would need to be addressed as part of that plan. The DWS has been included in the initial I&AP list and will be consulted during the public review period regarding registration/licensing of borehole for supply to the facility in terms of the NWA.


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of personnel on the management of spills and fires. 5.9.3.8 Soil conditions, ground water level and quality, and the existing contamination status of the site must be discussed (samples must be taken from boreholes on site). For sites without boreholes and surface water bodies and in cases where no boreholes or surface water bodies occur within a 50 metre radius from the site. a signed affidavit in this regard must be submitted. 5.9.3.9 In cases where any form of soil pollution is detected, the following must be submitted: ,. Specialist report indicating the status quo of the contaminated areas before rehabilitation. -,. Specialist report indicating the status quo of the areas after the rehabilitation thereof. ;> Receipt from relevant hazardous landfill site serving as proof that the contaminated soils and other material are indeed been disposed off. 5.9.3.10 A Waste Management Plan ("WMP") for all waste received, recycled and generated during the operational phase, including but not limited to: • The type, nature and volume of waste being received, recycled, re- used, recovered or treated on site; • The type and quantity of waste generated on site; • The storage areas (containers) if any; and • Method of waste disposal. 5.9.3.11 All specialist reports must have following details: • the person who prepared the report; and • the expertise of that person to carry out the specialist study or specialised process; • a declaration that the person is independent in a form as specified by the competent authority; • an indication of the scope of and the purpose for which the report was prepared; • a description of the methodology adopted in preparing the report or carrying out the specialised process; • a description of any assumptions made and any uncertainties or gaps in knowledge; • a description of the findings and potential implications of such findings on the activity, including identified alternatives, on the environment; e recommendations in respect of any mitigation measures that should be considered by the applicant and the competent authority; • a description of any consultation process that was undertaken during the course of carrying out the study; • a summary and copies of any comments that were received during any consultation process.


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5.9.3.12 A signed submission by the relevant site manager indicating that he/she understands the content of emergency response plan above and will comply with the requirements and procedures thereof. 5.9.3.13 All environmental management measures introduced and implemented as instructed in paragraph 5.5 above must be reported on and submitted as part of this report. 5.9.3.14 An identification of all the legislations and guidelines that have been considered in preparation of all conclusions and recommendations made. 5.9.3.15 Please be advised that if any section of the Strategic Environmental Management Acts (Air Quality Act, Water Act, Waste Act, etc.) is applicable to your activity/ies; you are requested to furnish this Department with a written comment from the relevant authority. In the event that this is not the case, the EAP managing the project must inform this Department accordingly, in writing.

5.9.4 Financial Considerations As stated above, this application is subject to a fine not exceeding R5 000 000.00 (five million rand) to be determined by the competent authority. In order to provide the competent authority wlth a description of the financial profile of the applicant to assist in this determination, the following is required. 5.9.4.1 A report compiled by a suitably qualified financial expert in which an assessment of the financial advantage gained, including any profits derived, by the applicant as a result of the contravention is detailed. 5.9.4.2 Where the applicant is a juristic person, the annual financial statements over the preceding three year period or, for the period from the date of commencement until the submission of this application, whichever is the longer; compiled by an independent and accredited accountant/auditing firm. 5.9.4.3 Where the person is an individual, bank statements of that person for the preceding three year period or for the period from the date of commencement until the submission of this application, whichever is the longer.

The financial information will be included in the Final Report to be submitted to GDARD due to its confidential nature.

5.9.5 Professional Appraisal 5.9.5.1 After having reviewed all the information outlined above the EAP must compile a detailed motivation why this application in terms of Section 24G of the National Environmental Management Amendment Act should favourably be considered, with specific reference to the following information which will be assessed when determining an appropriate fine. To this effect, you are required to complete the attached Impact Evaluation Form and clearly indicate the reasons for each index selected. • Social benefit that will be accrued to any affected communities in the event that this activity is allowed to continue • Social economic impact in the event that communities were negatively impacted by the activities

Please see Section 5 and Section 8. The Impact Evaluation Form is included in Appendix 11.


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that commenced/ was undertaken and/ or conducted unlawfully • The extent to which the biodiversity of the area was affected by having unlawfully commenced, undertaken, conducted activities • the extent to which the sense of place/ natural heritage was affected by having unlawfully commenced, undertaken, conducted activities • The extent to which pollution may have occurred as a result of having unlawfully commenced, undertaken, conducted activities.

6. The information requested above must be contained in a single report. Please ensure that the report is complete and set out in the format above and reflects the correct Departmental reference number [S24G/03/14-15/0327].

This report provides all the available information requested and where not available, commitments are included in the EMPr (Appendix 10) to address such gaps in information. This table summarises how this report meets the requirements of the Directive. This table will be updated in the Final S24G Report.

8. Kindly note that all information required above, including proof of public participation and copies of objections/comments must be submitted in one electronic copy (CD/DVD) and two hard copies. The information must this Department within four months of receipt of this directive. Should the Department not receive this information within the four months period or at least receive a request for an extension of time within the four month period, your section 24G file will be closed and there will be no further opportunity for you to obtain authorisation for the continuation of the activity that commenced/ was undertaken or conducted unlawfully.

All information, including proof of public participation and copies of all comments will be included in the Final Report to be submitted to GDARD.

9. An affidavit deposed to by the applicant person duly authorised by the applicant to depose thereto, explaining why the applicant did not obtain an environmental authorisation prior to commencing with the activity and a commitment that no activities (listed under the sub-regulations of Government Notice R983, R984 and R985, promulgated in terms of sections 24 and 44 of the NEMA) and activities listed under the R718 and R921 promulgated in terms sections 19 and 69 of the NEM:WA) would be undertaken in future within the Gauteng province without written approval from GDARD. It is acknowledged that this affidavit may not be used in any associated criminal prosecution. The affidavit must be submitted as part of the report.

The affidavit will be included in the Final Report to GDARD.


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8 CONCLUSION AND EAP ENVIRONMENTAL STATEMENT This report has provided a description of the activities undertaken at the facility, the applicable legislation and the impacts associated with the facility. In summary:

• Negative impacts associated with the facility include:

o Loss of topsoils from the site during construction.

o High HF emissions, which can be mitigated and measures are included in the EMPr attached to this report. It is noted that HF emissions does not result in an exceedance of ambient air quality limits at sensitive receptors.

o Visual impact due to steam emitted from the spray tower cooling system. There are no health related impacts associated with steam emissions, and this impact is a nuisance level impact, which is considered to be of low significance since the site is within an industrial area.

o Although dust levels are within the ambient air standards, due to the high background levels in the area, dust management measures are proposed for materials transport and handling on site.

• Benefits of the facility include:

o The facility was established with an investment of R250 million, which is significant for any project.

o The facility has created 270 jobs held by local people and has created business opportunities and jobs with regards to raw material supply and product transport, distribution.

o The facility has introduced new products, viz. porcelain roof tiles and floor tiles, previously imported to South Africa.

• Other considerations include:

o Emissions are well within the national minimum emission standard, except for HF (addressed above).

o Water and waste management are considered adequate on site.

o No impact on ecology is evident from historical aerial photographs of the site.

There are no immediate risks to the public due to the activities at the site. An EMPr has been developed and is included in this report. The facility indicates that it is committed to compliance with South African legislation.

It is therefore recommended that the GDARD consider this rectification application and authorise the facility, with the following minimum conditions included in the authorisation:

• Implementation of the EMPr

• Monitoring as per the monitoring programme included in the EMPr

• Auditing and reporting as per the EMPr

Should Rayal Industrial wish to expand the facility, an Environmental Impact Assessment in terms of the latest EIA regulations should be undertaken and an Environmental Authorisation obtained prior to commencement of such an expansion. The AEL for the site must also be amended prior to such an expansion. A water use license may be required and this should be discussed and pursued with the Department of Water & Sanitation.


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9 REFERENCES

1. Airshed Planning Professionals, April 2016 “Atmospheric Impact Report: Rayal Industrial (Pty) Ltd, Ekandustria, Gauteng”.

2. Lamola & Raphekwane Engineers and Project Managers, July 2011 “Geotechnical Investigation for the proposed new tile factory in Ekandustria”.

3. Metsweding District Municipality (2011). “Metsweding District Environmental Management Framework and Strategic Environmental Management Plan. Final Report of the Metsweding Environmental Management Framework and Environmental Management Plan”.

4. Steenkamp E, October 2014 “Occupational Hygiene Survey, Rayal Trading, 14 Galena Street, Ekandustria, Bronkhorstspruit”.

4. Census information: http://census2011.adrianfrith.com/place/799 http://census2011.adrianfrith.com/place/799054

5. Climate information: https://www.meteoblue.com/en/weather/forecast/modelclimate/wonderboom-airport_south-africa_938159

6. DWS water quality data: https://www.dwaf.gov.za/iwqs/wms/data/b31/b31_189529.pdf

http://census2011.adrianfrith.com/place/799

http://census2011.adrianfrith.com/place/799054

https://www.meteoblue.com/en/weather/forecast/modelclimate/wonderboom-airport_south-africa_938159

https://www.meteoblue.com/en/weather/forecast/modelclimate/wonderboom-airport_south-africa_938159

https://www.dwaf.gov.za/iwqs/wms/data/b31/b31_189529.pdf

Appendix 1: GDARD Compliance Notice and Directive, Requests for extension of the deadline

Appendix 2: Professional Profiles and EAP Declaration

Appendix 3: Borehole Analyses and Geotechnical Report

Appendix 4: Adverts and Site notice

Appendix 5: Register of I&APs and Correspondence to I&APs

Appendix 6: Comments and Response Report

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TO BE INCLUDED IN FINAL S24G REPORT AFTER PUBLIC REVIEW OF THIS REPORT

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Appendix 7: Copies Of I&AP’s Comments

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TO BE INCLUDED IN FINAL S24G REPORT AFTER PUBLIC REVIEW OF THIS REPORT

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Appendix 8: Photographs

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FULL A4 SIZE PHOTOS WILL BE INCLUDED IN THE FINAL S24G REPORT IT IS NOT POSSIBLE TO TAKE PHOTOS FROM THE 4 CARDINAL DIRECTIONS FOR ALL STRUCTURES DUE TO THE CHARACTERISTICS OF THE FACILITY LAYOUT

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Appendix 9: AIR IMPACT REPORT

Appendix 10: EMPr

Appendix 11: Impact Evaluation Form

SECTION 24G DRAFT REPORT APPLICATION FOR AUTHORISATION Farms IWULA/F320... · RAYAL INDUSTRIAL...

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