South African Nuclear Energy Corporation (Necsa)projects.gibb.co.za/Portals/3/projects/201111...

Arcus GIBB (Pty) Ltd Reg. 1992/007139/07

Head Office: Johannesburg, South Africa

14 Eglin Road, Sunninghill, 2191

Tel: +27 11 519 4600 Fax: +27 11 807 5670

South African Nuclear Energy Corporation (Necsa)

ENVIRONMENTAL IMPACT ASSESSMENT FOR THE PROPOSED DEVELOPMENT OF A DEDICATED ISOTOPE PRODUCTION

REACTOR (DIPR) AND ASSOCIATED INFRASTRUCTURE ON CHURCH STREET WEST EXTENSION, BRITS DISTRICT, NORTH

WEST PROVINCE

27 October 2011 Reference No: J 31126

Necsa DIPR EIA – Draft Scoping Report i Rev 1 / October 2011

PROJECT INFORMATION

Title: Draft Scoping Report for the Proposed Development of the Dedicated Isotope Production Reactor

Environmental Authority: Department of Environmental Affairs DEA Reference Number: 12/12/20/2453 Applicant: South African Nuclear Energy Corporation (Necsa) Environmental Consultant: Arcus GIBB Pty Ltd Date: October 2011

Necsa DIPR EIA – Draft Scoping Report ii Rev 1 / October 2011

EXECUTIVE SUMMARY

Introduction

The South African Nuclear Energy Corporation (Necsa) proposes to develop a small nuclear reactor with associated infrastructure at the Necsa Pelindaba site, which is located on Church Street, West Extension, Brits District in the North West Province. The nuclear reactor is to be known as the Dedicated Isotope Production Reactor (DIPR). This DIPR is to be solely utilized for the purpose of producing radio isotopes and not for energy production. The thermal power generated by the DIPR would be less than 15 Mega Watts (MW). This process waste heat is ultimately shed to the environment through cooling towers. The radio isotopes produced are used in over 100 000 different medical procedures such as X-rays, Magnetic Resonance Imaging (MRI) scans and Computerised Tomography (CT) scans.. The proposed development will consist of:

The installation a Dedicated Isotope Production Reactor (DIPR);

The construction of a building to house the DIPR;

The construction of a service building;

The construction of cooling towers; and

The renovation of an existing building, which will be used for the administration of the DIPR.

In order for the proposed development to proceed, authorisation is required from the Department of Environmental Affairs (DEA). Necsa, as the project proponent, has appointed Arcus GIBB (Pty) Ltd (GIBB) as the independent Environmental Assessment Practitioner (EAP) to undertake the EIA for the proposed development of the DIPR and associated infrastructure. Motivation for the Proposed Development (Why is the DIPR needed?) Currently there is a nuclear reactor on the Necsa Pelindaba site which has been in operation since 1965. This reactor is referred to as the South African Fundamental Atomic Reactor Installation (Commonly known as SAFARI -1). The reactor was originally intended as a research tool to undertake basic research in nuclear science. In 1993 there was an identified local need for radio-isotopes for medical purposes. SAFARI-1 was then commissioned to produce these medical isotopes. As the field of nuclear medicine grew so did the international market for these radio-isotopes. South Africa began exporting these isotopes and now produces 20 % of the world supply of medical isotopes. There are only four other countries in the world that produce these isotopes commercially, owing to the high costs of acquiring reactors, processing facilities and supporting infrastructure. In the last 17 years no new reactor based radio-isotopes producers have entered the market. South Africa currently produces 20% of the world supply of the Molybdenum 99 and Iodine 131 isotopes required for over 100 000 different medical procedures. The demand for the applications in nuclear medicine is growing, because of its ability to accurately diagnose cancer, heart disease and other illnesses.

Necsa DIPR EIA – Draft Scoping Report iii Rev 1 / October 2011

There is a critical global shortage of Molybdenum 99 and Iodine 131, due to the recent unscheduled closure of two reactors in Canada and Europe. In response Necsa increased production by 20% to maintain the global supply. SAFARI -1 has maintained an excellent safety record to date and today ranks as the world’s most reliable reactor for the production of medicines. In line with Government policy, SAFARI -1 has ensured that the South African public is reliably provided with affordable nuclear medicine for the diagnosis and treatment of cancer. However, international experience has shown that reactors of a similar age must be considered for replacement in the near term. Since it can take up to ten years to construct a replacement medicine-producing reactor and to ensure continuity of supply Necsa, is considering the construction of a small new medicine-producing reactor to achieve the following goals:

To permit Necsa to remain a reliable supplier of medical isotopes to the growing local and international markets and to ensure a secure supply of affordable medicines for the detection and treatment of cancer for South African patients.

To allow for more protracted life-extension programmes for the SAFARI-1 reactor, without disrupting the production of isotopes.

The Proposed Site for the DIPR (Location and Property Description)

Table 1: Property Description for the Proposed DIPR Site

Refer to the locality map of the proposed site provided below in Figure 3.

Property Description Portion 82, Farm 567–JQ Weldaba

Street Address Church Street, West Extension, Brits District, North West Province, South Africa

Approximates Coordinates from centre point of the proposed site

Latitude: 25°47'44.78"S Longitude: 27°55'11.52"E

Project Footprint 19000 Square Metres

Local Municipality Madibeng – Ward 29

District Municipality Brits District Municipality

Ownership The site is owned and operated by the South African Nuclear Energy Corporation

Zoning Industrial 1

Necsa DIPR EIA – Draft Scoping Report iv Rev 1 / October 2011

Figure 2: Locality map for the proposed development of the Dedicated Isotope

Production Reactor and Associated Infrastructure

Why is an Environmental Impact Assessment Required?

In terms of the National Environmental Management Act, 1998 (Act No.107 of 1998) [NEMA] and associated EIA Regulations published on 18 June 2010, an environmental authorisation must be obtained from the National Department of Environmental Affairs (DEA) prior to the commencement of certain listed activities that may result in potential negative impacts on the environment. The proposed construction of the DIPR and associated infrastructure involves a number of listed activities (Refer to Table 2 below). An EIA must therefore be undertaken.

Table 2: Listed activities in terms of section 24 and 24(d) of the NEMA as per GN

R544, R545 and R546, published on the 18 June 2010

GN Activity No (s):

Description of each listed activity as per project description:

544

1 The reactor will be powered with Low Enrichment Uranium (LEU) standard plate-type fuel and the DIPR will have a maximum thermal power of 15 MW.

544 13 The construction of facilities or infrastructure for the storage, or for the storage and handling, of a dangerous good, where such storage occurs in containers with a combined capacity of 80 but not exceeding 500 cubic metres.

544 22 A proposed access road will be built on the site upon which building material and component will be delivered to the proposed DIPR site.

545 2 The construction of a proposed nuclear installation, which will be a small nuclear reactor that is dedicated for the production of radioisotopes, commonly referred to as a Dedicated Isotope Production Reactor (DIPR).

Necsa DIPR EIA – Draft Scoping Report v Rev 1 / October 2011

545 3 The construction of facilities or infrastructure for the storage, or for the storage and handling, of a dangerous good, where such storage occurs in containers with a combined capacity of more than 500 cubic metres.

545 5 The reactor building will house a stack, approximately 65 m in height, which will release emissions into the air which may require necessary air quality licenses. The outputs of the stack will be subjected to an Air Quality Impact Assessment.

546 19 Widening of a road by more than 4 metres, or the lengthening of a road by more than 1 kilometre. (c) In North West :

i. Outside urban areas, in: (aa) A protected area identified in terms of NEMPAA, excluding conservancies; (bb) National Protected Area Expansion Strategy Focus areas; (cc) Sensitive areas as identified in an environmental management framework as contemplated in

chapter 5 of the Act and as adopted by the competent authority; (dd) Sites or areas identified in terms of an International Convention; (ee) Critical biodiversity areas (Terrestrial Type 1 and 2 and Aquatic Type 1) as identified in

systematic biodiversity plans adopted by the competent authority or in bioregional plans; (ff) Core areas in biosphere reserves; (gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any

other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve.

The EIA Process The EIA process is controlled through Regulations published under the Government Notice No. R. 543 and associated guidelines promulgated in terms of Chapter 5 of the National Environmental Management Act (Act 107 of 1998). The EIA Process is summarised in the flow diagram below.

Necsa DIPR EIA – Draft Scoping Report vi Rev 1 / October 2011

Figure 3: EIA Process Flowchart Chapter 5 details the methodology undertaken for the EIA for the proposed development for the DIPR and associated infrastructure.

THE EIA PROCESS

PUBLIC EAP DEA

Authority Meetings

Notice Boards

Advertisements

40 Day Comment period

Conduct PPP

Notify Stakeholders Distribute BID

Prepare Draft Scoping Report

Submit Application to

DEA

Solicit Comments on DSR

Submit Final Scoping

Report to DEA

Acknowledge Receipt of the Application

within 14 Days

Reply in 40 Days to Accept DSR

Or Reject DSR

Or Request Amendment

Prepare Draft Environmental Impact Report (EIR) and Draft

Environmental Management Plan

(EMP)

Solicit Comment on

the Draft EIA & EMP

Submit Final reports to the Authority

Environmental

Authorisation

Decided within 60 days:

Accept EIR Or

Refer for reviews Or request

Amendments Or

Reject EIR

Grant or Refuse

Environmental Authorisation within 45

Days of Acceptance


on Draft Scoping Report

40 Day Comment Period

Advise I&APs on the Environmental

Authorisation

SCOPING PHASE

ASSESSMENT PHASE

Necsa DIPR EIA – Draft Scoping Report vii Rev 1 / October 2011

The Roleplayers of the EIA Process

The Proponent: The South African Nuclear Energy Corporation (Necsa) The South African Nuclear Energy Corporation Limited (Necsa) is a state-owned public company, registered in terms of the Companies Act, (Act No. 61 of 1973), registration number 2000/003735/06. Necsa derives its mandate from three regulatory frameworks: The Nuclear Energy Act of 1999, the Nuclear Energy Policy of 2008 as well as directives conferred on it by the Minister of Energy. The Environmental Assessment Practitioner: Arcus GIBB (Pty) Ltd (GIBB) GIBB is a multi-disciplinary engineering and environmental consultancy organisation whose environmental division comprises 25 professionals. Arcus GIBB’s Environmental Division has a proven track record in the planning, co-ordination, management and execution of a wide range of environmental projects. The Arcus GIBB team consists of a number of highly qualified and experienced environmental professionals. The Competent Authority: The National Department of Environmental Affairs (DEA) The DEA is the competent authority or decision making authority for this proposed application. This is a result of Necsa being a parastatal and as such any application made by a parastatal must be submitted to National Department for assessment. The Provincial Department of Economic Development, Environment Conservation and Tourism (DEDECT) is the key commenting authority for the application.

Detailed Project Description: Technical Details

The Dedicated Isotope Production Reactor (DIPR) What is the Purpose of the DIPR? The purpose of the DIPR is to produce radioisotopes to meet the growing local and international demand for isotopes, in particular Molybdenum 99 (99Mo). Radioisotopes are used in nuclear medical procedures as detailed below. What are Radioisotopes? Radioisotopes are atoms with a different number of neutrons than those that occur in elements in their naturally occurring stable form. This causes these isotopes to have an unstable nucleus that decays, and in the process emits alpha, beta and gamma rays, until the isotope reaches stability. The isotope is transformed entirely into another element after stability is reached. The DIPR will produce the following radioisotopes:

Molybdenum 99: is a parent isotope of Technetium (Tc) 99m the most widely used isotope in nuclear medical diagnostic procedures and is used in 40-50 million diagnostic procedures annually.

Iodine 131: is a widely used isotope for medical therapeutic and diagnostic procedures.

Necsa DIPR EIA – Draft Scoping Report viii Rev 1 / October 2011

Radioisotopes and Nuclear Medicine Nuclear medicine utilises very small amounts of radioactive materials (radiopharmaceuticals made from radioisotopes) to diagnose and treat disease. In diagnosis, the radiopharmaceuticals are detected by special types of cameras that work with computers to provide very precise pictures about the area of the body being imaged. Some of the devices used for imaging include X-rays, MRI scanners, CT scans and ultrasound. The most important benefit of nuclear imaging procedures is that it is non-invasive and, with the exception of intravenous injections, are usually painless medical tests that help physicians diagnose medical conditions. In treatment, radiopharmaceuticals such as iodine (I-131) go directly to the organ being treated. The amount of radiation in a typical nuclear imaging procedure is comparable with that received during a diagnostic x-ray, and the amount received in a typical treatment procedure is kept within safe limits.

Figure 1: Medical Scan used in Diagnosis of a Multitude of Diseases How does the DIPR Work? The DIPR is a small nuclear reactor dedicated only to the production of medical radioisotopes and silicon doping. A nuclear reactor is a device within which a nuclear fission chain reaction is carried out in a controlled manner. Nuclear Fission: In the DIPR, the controlled nuclear chain reaction occurs when Uranium (a naturally occurring element) targets are bombarded by intense beams of neutrons which

Necsa DIPR EIA – Draft Scoping Report ix Rev 1 / October 2011

then cause the uranium targets to break and split. This results in energy being released. This process is called nuclear fission. The split particles produced by nuclear fission are called fission fragments. In the DIPR, Molybdenum 99 and Iodine 131 radioisotopes form part of the fission fragments that are produced. The nuclear chain reaction is controlled by using neutron poisons and neutron moderators to change the portion of neutrons that will go on to cause more fission. The DIPR will be a pool type reactor: This kind of nuclear reactor has a core that is immersed in an open pool of water. The water acts as the neutron moderator, cooling agent and radiation shield. Water is a cooling agent because when the nuclear fission reaction in the core generates heat, such heat is removed by circulating water past the reactor core to absorb the heat. The DIPR Fuel and Power Control: The DIPR will be fuelled by Low Enriched Uranium fuel (LEU).The power output of the reactor is adjusted by controlling how many neutrons are able to create more fission. Control rods are used to absorb neutrons. Absorbing more neutrons in a control rod means that there are fewer neutrons available to cause fission, so pushing the control rod deeper into the reactor will reduce its power output, and extracting the control rod will increase it. A maximum of 15 MW of heat will be produced by the DIPR. This heat is removed by circulating water through the pool. The heat is ultimately released into the environment through cooling towers. The layer of water directly above the reactor core, shields the radiation. People may therefore work above the reactor safely. The Control Rods: The design of Control rods vary from one reactor to another, but a typical control rod consists of an upper "poison" section, a fuel element section, a lower support and a piston. The "poison" or neutron absorbing section consists of an aluminium box, containing a neutron absorber (typically Cadmium or Hafnium) insert. The actual Process to Form the Final Product: The reactor is used to irradiate (process by which an object is exposed to neutron radiation) various targets and silicon ingots. The most commonly utilised are Molybdenum targets. This process is the same as what has been established for SAFARI-1 The Molybdenum targets: In the proposed DIPR the Standard Molybdenum (Mo) Fuel Plates (SMFP) which are the targets, will be stored in a vault facility in the reactor building from where the required number of targets will be transferred daily to the reactor hot cell for loading into the target plate holders. The target plate holders are then moved to the reactor pools and loaded into the irradiation positions. Loading into and removing from the core is done by means of a motorised linear actuator to limit and control the rate of change of core reactivity. After a number of hours of irradiation, the target holders are removed from the core manually (whilst keeping adequate shielding) and stored in the storage pool for some hours for cooling. The target plate holders are then transferred manually to the reactor hot cell, from where they are removed from the reactor building in specially designed and constructed casks and transported to a separate processing facility. The processed targets remain in the processing facility and are not returned to the reactor building. At the processing facility the irradiated SMFP undergo chemical processing, separating and purifying the Molybdenum using proprietary and licensed processes, and then ultimately

Necsa DIPR EIA – Draft Scoping Report x Rev 1 / October 2011

packing the Molybdenum, now in a final carrier, into specially designed and constructed casks, for shipment to the client. Silicon Ingots: Silicon (Si) ingots consist of cylindrical 99.99999% pure Silicon crystals, either 5" (128 mm) in diameter, or 6" (152 mm) in diameter. In some cases 3" (76 mm) and 4" (101 mm) ingots are also irradiated. The average length of the ingots is 600 mm. Nuclear Waste The nuclear waste consists of the spent fuel and control rods, other metallic waste (mostly irradiated Aluminium and other metals), as well as liquid effluent. As for Safari, the DIPR spent fuel and control rods will be stored for the medium term in dry storage at the Thabana Pipe store. Radiological liquid effluent is monitored and where necessary, stored, treated and gradually released to the environment when radioactive levels are low enough to not cause harm to the environment. Hazard and Safety Management The DIPR is a nuclear installation with associated potential risk of radiation exposure to employees and the surrounding environments. In the worst case, extreme exposure to radiation could cause radiation poisoning in humans and animals which can lead to death, depending on the level of radiation. Therefore Necsa recognizes safety, health, environment and quality (SHEQ) processes as of paramount importance and ensures that strict controls are put in place to manage these aspects. The key concerns are the risk of inadvertent exposure of public, operating personnel and the environment to ionising radiation, above legally permissible limits. These safety concerns are considered to be of critical value to the reactor design and to the external hazards associated with the selected site. The potential consequences of any exposure is controlled by the plant design, hardware design, operation activities, administrative procedures, emergency control measures and even site characteristics, to determine the dispersion of radiation should an event occur that may affect the public. The DIPR is a small reactor, which creates in the order of 10 000 times less risk to the public than a power generating nuclear reactor, such as the reactors at the Koeberg nuclear power station. The NNR specifies acceptance criteria for the exposure risk to the public and for operating personnel. It is internationally accepted that the potential exposure risk to the public is significantly less for research (and isotope production) reactors. Associated Infrastructure Furthermore the design of the DIPR buildings and structures and related services and infrastructure will facilitate expansions during the operating life of the facility.

Necsa DIPR EIA – Draft Scoping Report xi Rev 1 / October 2011

The DIPR site will comprise of:

A DIPR Building (Approximately 35 m x 35 m);

A Utilities/ Service Building (Approximately 30 m x 30 m);

An Administrative Building (Existing building that will be renovated);

Cooling Towers (Approximately 20 m x 10 m) – lower than the SAFARI-1 tower;

Temporary Construction Laydown Area (Used to store machinery and equipment as well as consist of facilities such as diesel storage facilities, toilets, showers and eating facilities);

Access Road (along the existing fence from Gate-2 to the proposed site); and

Services (Necsa Pelindaba) site has connected sewer, water and electricity services. However the proposed development does include the extension of these existing services to the proposed DIPR and associated infrastructure).

Decommissioning Phase It is anticipated that during the decommissioning phase, the type of waste generated will differ from the material and wastes that are routinely handled during the operational phase of the reactor. At all phases of decommissioning, employees, the public and the environment should be adequately protected from hazards resulting from the decommissioning process. A DIPR decommissioning strategy will be compiled specific to the design parameters of the DIPR. The strategy will outline the method and phases of decommissioning of the facility and will fit into the existing Necsa decommissioning strategy. Only the most suitable method will be selected, subject to safety and economic considerations. The decommissioning strategy will dictate the development of a decommissioning plan. The decommissioning strategy will include an indicative estimate of the radiological inventory at final shut down and the likely decommissioning wastes (volumes, masses, activity levels and significant dose rates, for each anticipated type of radioactive waste) taking account of operational histories for the type of reactor proposed. The decommissioning strategy will conform to one of the following decommissioning methods:

Immediate dismantling;

Entombment; or

Long term managed storage. The Decommissioning strategy will be addressed in further detail within the EIA phase of the project.

Project Alternatives

In terms of the EIA Regulations published in Government Notice R543 of 18 June 2010 in terms of Section 24 (5) of the National Environmental Management Act (Act No. 107 of 1998), feasible and reasonable alternatives have to be considered within the environmental scoping phase. All identified, feasible and reasonable alternatives are required to be identified in terms of social, biophysical, economic and technical factors. At this stage of the EIA process (Draft Scoping Report) only site alternatives have been considered. Design, technological and operational activities are in the process of being defined further.

Necsa DIPR EIA – Draft Scoping Report xii Rev 1 / October 2011

Necsa appointed an expert panel based on Necsa’s Suitably Qualified and Experienced Person Framework. The panel was tasked to identify, assess, compare and rank potential locations for the DIPR. Refer to Chapter 3 in the Draft Scoping Report which details the processes to establish the alternative sites identified. Eight (8) site alternatives were identified at the existing Pelindaba site. Alternatives around the country were not investigated as it would not be viable as the existing infrastructure required for the development of the DIPR already exists at the Pelindaba site. As a result of the analysis, only Alternative Sites 3, 5 and 6 were identified for further analysis and assessment. Subsequently Chapter 3 further details the process of eliminating the other Alternative Sites 1, 2, 4 & 7 and establishing Alternative Site 6 as the preferred alternative. Alternative 9: The No Go Alternative The ‘do-nothing’ or ‘no-go’ alternative is the option of not developing the proposed DIPR and associated infrastructure. The “do-nothing’ alternative will represent the status quo, against which the proposed project will be compared in detail during the impact assessment phase of the project.

Legal and Policy Context

The proposed development is governed by a multitude of South African and International Acts and Policies as determined by the project specification. Chapter 4 of the Draft Scoping Report details the legislative framework of which the proposed project must adhere to. Refer below to a summarised list applicable key legislation. The Constitution of the Republic of South Africa (Act 108 of 1996)

National Energy Act (Act 34 of 2008).

The Promotion of Administrative Justice Act (Act 3 of 2000).

Promotion of Access to Information Act (Act 2 of 2000).

Environmental Conservation Act (Act 73 of 1989).

National Heritage Resources Act (Act No. 25 of 1999).

National Environmental Management: Biodiversity Act (Act No. 10 of 2004.

National Environmental Management: Air Quality Act (Act No 39 of 2004).

Conservation of Agricultural Resources Act (Act No. 43 of 1983).

National Water Act (Act No 36 of 1998).

Waste Act (Act No 59 0f 2008).

National Forests Act (Act No. 84 of 1998).

Hazardous Substances Act, 1973 (Act No. 115 of 1973).

The National Key Points Act.

Nuclear Energy Act, 1999 (Act No. 46 of 1999).

National Nuclear Regulator Act, 1999 (Act No. 47 of 1999).

Government Notice No. 287 of March 2004: Regulations on the development surrounding any nuclear installation to ensure the effective implementation of any Nuclear Emergency Plan.

The Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002)

National Spatial Biodiversity Assessment (“NSBA”).

Necsa DIPR EIA – Draft Scoping Report xiii Rev 1 / October 2011

Draft National Strategy for Sustainable Development.

Radioactive Waste Management Policy and Strategy.

Nuclear Energy Policy for the Republic of South Africa.

Public Participation and EIA Process Methodology

An EIA is a legislative tool that is used to ensure that potential impacts that may occur due to the proposed development are avoided or mitigated (minimised). In South African legislation the environment includes social, economic and bio-physical aspects and the EIA must assess these equitably. The EIA procedures are based on the principles of Integrated Environmental Management (IEM) which, in short, comprise pro-active planning, informed decision making, a transparent and participatory approach to development, a broad understanding of the environment, and accountability for decisions and the information on which they are based. The EIA process can be divided into 4 distinct components as detailed below:

The full EIA Process and timeframes are discussed in further detail in Chapter 5. Public Participation Process (PPP) A comprehensive Public Participation Process (PPP) has been implemented as part of the Scoping Phase of the EIA. The PPP aims to:

Application and initial notification

Submit an EIA application to the DEA;

DEA acknowledgement of the EIA application (within 14 days); and

Notify the public of the proposed development through inter alia, newspaper adverts, notification letters, BIDs and notice boards.

Scoping phase

Investigate and gather information on the proposed study area in order to establish an understanding of the area;

Establish how the proposed project will potentially impact on the surrounding environment;

Identify Interested and Affected Parties (I&APs) and relevant authorities by conducting a Public Participation Process (PPP);

Identify potential environmental impacts through investigation and PPP; and

Describe and investigate the alternatives that may be considered.

Impact Assessment phase

Detailed specialist assessment of all issues and proposed alternatives identified in the Scoping phase;

Identify mitigation measures and recommendations to reduce the significance of potential impacts;

Compile an Environmental Management Plan (EMP) which will prescribe environmental specifications to be adhered to during the construction and operational phases of the project; and

As with the Scoping phase, the PPP is an integral and important part of the Impact Assessment phase.

Environmental Authorisation

Environmental Authorisation (EA) issued to Just Energy once DEA has made a decision regarding the proposed project; and

Decision may be positive or negative based on inter alia, information received in the Scoping and Impact Assessment phases.

Necsa DIPR EIA – Draft Scoping Report xiv Rev 1 / October 2011

Ensure all relevant key stakeholders and Interested and Affected Parties (I&APs) have been identified and invited to engage in the scoping phase:

Raise awareness, educate and increase understanding of stakeholders about the proposed project, the affected environment and the environmental process being undertaken:

Create open channels of communication between key stakeholders and I&APS and the project team;

Provide opportunities for key stakeholders and I&APS to identify issues or concerns and suggestions for enhancing potential benefits and to prevent or mitigate impacts:

Accurately document all opinions, concerns and queries raised regarding the project; and

Ensure the identification of the significant alternatives and issues related to the project.

Refer to Chapter 5 which details the public participation process comprehensively.

Description of the Baseline Environment

The description of the baseline environment details the various biophysical and socio-economic factors as described by the various specialists involved in the project. The biophysical aspects includes: Regional context, topography, climate of the study area, geology, meteorology, regional vegetation, ecology. The socio-economic aspects include: baseline demographic processes, economic growth potential and heritage resources. More information regarding these factors can be located in Chapter 6.

Identification of Potential Impacts

Specialist studies were undertaken to identify potential impacts that may occur as a result of the proposed project. The following specialist studies were undertaken:

Ecological Impact Assessment

Air Quality Impact Assessment

Heritage Impact Assessment

Social Impact Assessment Potential impacts identified during the scoping phase will be further investigated and assessed in the impact assessment phase of this EIA. Should additional impacts be identified in the scoping phase it will be included in the Final Scoping Report. Potential impacts for the proposed development are listed below: Ecological Impacts

Loss or fragmentation of indigenous natural vegetation. Construction of infrastructure may lead to direct loss of vegetation. This will lead to localised or more extensive reduction in the overall extent of vegetation. Where this vegetation has already been stressed due to degradation and transformation at a regional level, the loss may lead to increased vulnerability (susceptibility to future damage) of the habitat. Some

Necsa DIPR EIA – Draft Scoping Report xv Rev 1 / October 2011

vegetation types that have suffered regionally high levels of transformation are listed in the Draft Ecosystem List and are protected according to the National Environmental Management: Biodiversity Act.

Loss of habitat or individuals of threatened animals. Loss of a population or individuals could lead to a direct change in the conservation status of the species. This may arise if the proposed infrastructure is located where it will impact on such individuals or populations or the habitat that they depend on.

Loss of populations of threatened plants. Plant species are especially vulnerable to infrastructure development due to the fact that they cannot move out of the path of the construction activities, but are also affected by overall loss of habitat. Loss of a population or individuals could lead to a direct change in the conservation status of the species, possibly extinction. This may arise if the proposed infrastructure is located where it will impact on such individuals or populations. Consequences may include fragmentation of populations of affected species, reduction in area of occupancy of affected species and loss of genetic variation within affected species.

Loss of individuals of protected tree species. In terms of section1 5(1) of the National Forests Act, 1998 “no person may cut, disturb, damage or destroy any protected tree or possess, collect, remove, transport, export, purchase, sell donate or in any other manner acquire or dispose of any protected tree or any forest product derived from a protected tree, except under a license granted by the Minister to an applicant and subject to such period and conditions as may be stipulated”.

Damage to wetlands. Construction may lead to some direct or indirect loss of or damage to seasonal marsh wetlands or drainage lines or impacts that affect the catchment of these wetlands. This will lead to localised loss of wetland habitat and may lead to downstream impacts that affect a greater extent of wetlands or impact on wetland function.

Establishment and spread of declared weeds and alien invader plants. Exotic species are often more prominent near infrastructural disturbances than further away. Consequences of invasion may include further loss of indigenous vegetation, change in vegetation structure leading to change in various habitat characteristics, change in plant species composition, change in soil chemical properties, loss of sensitive habitats, loss or disturbance to individuals of rare, endangered, endemic and/or protected species, fragmentation of sensitive habitats, change in flammability of vegetation, depending on alien species, hydrological impacts due to increased transpiration and runoff and impairment of wetland function.

Air Quality Impact Potentail air pollution: Although it is anticipated that the atmospheric releases of both conventional air pollutants and radionuclides would occur, the former is only expected to occur during construction and decommissioning. Radionuclide emissions are expected to occur during operation and possibly during decommissioning. Air releases may be associated with routine emissions, upset and emergency emissions or accidental releases. However, the assessment is confined to routine and upset emissions only. All air releases will be reported to the National Nuclear Regulator (NNR), who control allowable amounts of emissions. Refer to Chapter 7 for further details. Social Impacts Geographical Change Processes and Potential Impacts: The identification of geographical (land use) change process from a social perspective looks at how the presence of the proposed project site might change the behaviour/lives of land owners and/or land users in the surrounding area. The vacant land in the Pelindaba site on which the proposed DIPR will be located will permanently change to host the reactor. The construction laydown area will only change temporarily for the duration of the construction phase. If a construction camp is

Necsa DIPR EIA – Draft Scoping Report xvi Rev 1 / October 2011

used, it is likely that it will not be located within Pelindaba’s borders due to security measures, it would therefore have to be located elsewhere in close vicinity of the project site. The impact on land use largely depends on the current land use. Although it is not foreseen that the project site would lead to a drastic land use change within Pelindaba itself (as it would blend in with the rest of the activities), the location of the construction camp might lead to a temporary change in land use. The construction camp could be located outside Pelindaba but still in close proximity to the site. This could potentially lead to a temporary change in land use. The impact would largely depend on the current land use and on landownership. Demographical Change Processes and Potential Impacts: The construction and operation of the proposed DIPR and associated infrastructure can lead to a change in the number and composition of the population within the affected local area, which in turn could lead to economic, land use, and socio-cultural change processes.

Economic Change Processes and Potential Impacts: Economic change processes relate to the changes brought about to the employment and general economic profile of the local area as a result of the introduction of any development. For example, job opportunities might be created as a result of the construction and operation of the proposed DIPR. Employment creates a source of income, which in turn enables the employed individual to access services as a support mechanism for his/her family.

Institutional and Legal Change Processes and Potential Impacts: Institutional and Legal Change Processes assesses the way in which a development of this nature could change the face of service delivery in the affected area and how this change in turn could affect the quality of life of local residents. A larger number of people can affect the quality of municipal and other social services, e.g. an influx of ‘strangers’ can increase the crime rate, placing a higher strain on the police services. The potential impact relates to the additional demand on municipal services, such as water, sewerage and roads could impact on health and safety if such services are not available. An influx of unemployed job seekers can lead to the development of informal settlements. This can impact on health (as services are not provided or further taxed) and safety (an increase in crime is possible as people do not find employment and become frustrated with their living conditions).

Socio-Cultural Change Processes and Potential Impacts: As socio-cultural processes recount the way in which humans behave, interact, and relate to each other and their environment, socio-cultural change processes in turn looks at the way in which the proposed developments can alter the interactions and relationships within the local community. This potential impact investigates cultural clashes which may occur where people are brought into the area from elsewhere. Apart from conflict situations, the rules of interaction can be blurred, impacting on family and cultural cohesiveness, and health and safety. At this stage it is not foreseen that the presence of the proposed DIPR would impact on local residents’ sense of place, but this assumption would have to be tested during the EIA phase.

Conclusion

Based on the specialist studies no environmental fatal flaws have been identified to date. However, a number of potentially significant environmental impacts, both positive and negative have been identified as requiring further in-depth study. Therefore, a detailed

Necsa DIPR EIA – Draft Scoping Report xvii Rev 1 / October 2011

Environmental Impact Assessment is required to be undertaken in order to provide an assessment of these potential impacts and recommend appropriate mitigation measures, where required. The terms of references for the detailed specialist studies required in the Impact Assessment phase of the project are included in the Plan of Study for EIA (Chapter 9)

Necsa DIPR EIA – Draft Scoping Report Rev 1 / October 2011

ENVIRONMENTAL IMPACT ASSESSMENT FOR THE PROPOSED

DEVELOPMENT OF A DEDICATED ISOTOPE PRODUCTION REACTOR (DIPR) AND ASSOCIATED INFRASTRUCTURE ON CHURCH STREET WEST

EXTENSION, BRITS DISTRICT, NORTH WEST PROVINCE

CONTENTS

DRAFT SCOPING REPORT

Chapter Description Page

1 INTRODUCTION 1

1.1 Project Description 2 1.1.1 Dedicated Isotope Production Reactor (DIPR) 2 1.1.2 The Building to Contain the DIPR 2 1.1.3 The Utilities and Service Building 3 1.1.4 The Administrative Building 3 1.1.5 Cooling Towers 3 1.1.6 Temporary Construction Laydown Area 3 1.1.7 Access Road 3 1.1.8 Services 3

1.2 Motivation for the Proposed Development 3

1.3 Property Description and Location 4

1.4 Environmental Impact Assessment Process Overview 6 1.4.1 Why is an Environmental Impact Assessment (EIA) Required? 6 1.4.2 Summary of the EIA Process 7

1.5 Details of the EIA Process to Date 10 1.5.1 Environmental Application 10 1.5.2 Draft Scoping Report 10 1.5.3 Details of the Project Team 10 1.5.4 Details of the Environmental Assessment Practitioner (EAP) 11

2 DETAILED PROJECT DESCRIPTION: TECHNICAL DETAILS 13

2.1 The Dedicated Isotope Production Reactor (DIPR) 13 2.1.1 The Purpose of the DIPR 13 2.1.2 How the DIPR Works 13 2.1.3 What are Radioisotopes? 15 2.1.4 Description of the Medical Isotopes Produced 15 2.1.5 Nuclear Waste 15 2.1.6 Hazard and Safety Management 15

2.2 Associated Infrastructure 16

2.3 Nuclear Medicine 17

2.4 Decommissioning Phase 18


2.5 Conclusion 18

3 PROJECT ALTERNATIVES 19

3.1 Site Alternative Selection 20 3.1.1 Identification of the Preferred Alternative 21

3.2 Alternative 9: The No Go Alternative 22

3.3 Alternatives to be assessed in the Impact Assessment Phase 22

4 LEGAL AND POLICY CONTEXT 23

4.1 Introduction 23

4.2 Legislative, Policy, Planning and Guideline Context 23 4.2.1 The National Environmental Management Act, 1998 (Act No. 107

of 1998) (NEMA) 23 4.2.2 Department of Environmental Affairs and Tourism Integrated

Environmental Management Guideline Series (2010) 26 4.2.3 Other Acts/Regulations/Policies/Guidelines Relevant to the Project 27

4.3 Conclusion 33

5 PUBLIC PARTICIPATION AND EIA PROCESS METHODOLOGY 34

5.1 Introduction 34

5.2 Scoping Phase 34 5.2.1 Consultation with Authorities 34 5.2.2 Consultation with other Relevant Authorities 35 5.2.3 Identification of Potentially Significant Environmental Impacts 35 5.2.4 Scoping Report 35 5.2.5 Plan of Study for EIA 36

5.3 Public Participation Process 36 5.3.1 Identification of Key Stakeholders and I&APs 36 5.3.2 Notification and Advertisements 37 5.3.3 Background Information Document (BID) 37 5.3.4 Environmental Scoping Phase Meetings 38 5.3.5 Ongoing Consultation and Engagement 39 5.3.6 Public Review of the Draft Environmental Scoping Report 39 5.3.7 Final Environmental Scoping Report 39

5.4 Conclusion 40

6 DESCRIPTION OF THE BASELINE ENVIRONMENT 41

6.1 Introduction 41

6.2 General Study Area 41 6.1.1 Regional Context 41

6.3 Biophysical Environment 44 6.3.1 Location and Topography 44 6.3.2 Climate 45


6.3.3 Surface Hydrology and Rainfall 45 6.3.4 Geology 46 6.3.5 Nearby Receptors 47 6.3.6 Meteorology 48 6.3.7 Regional Vegetation 49

6.4 Socio-Economic Environment 50 6.4.1 Baseline Geographical Processes 50 6.4.2 Baseline Demographical Processes 55 6.4.3 Baseline Economic Profile 60 4.1.1 Baseline Socio-Cultural Processes 67

6.5 Heritage Resources 68 6.5.1 Stone Age 69 6.5.2 Iron Age 69 6.5.3 Historical period 69

7 POTENTIAL ISSUES AND IMPACTS 70

7.1 Ecology 70

7.2 Air Quality 71 7.2.1 Dedicated Isotope Production Reactor 72 7.2.2 Associated Infrastructure and Laydown Area 72

7.3 Social Impacts 73 7.3.1 Dedicated Isotope Production Reactor and Construction Laydown

Area 73

7.4 Heritage Impacts 77 7.4.1 Dedicated Isotope Production Reactor Location 77 7.4.2 Associated Infrastructure and Laydown Area 77

7.5 Conclusion 78

8 CONCLUSIONS AND RECOMMENDATIONS 79

8.1 Introduction 79 8.1.1 Project Background 79

8.2 Conclusions 81 8.2.1 Ecology 81 8.2.2 Air Quality 81 8.2.3 Social Impacts 82 8.2.4 Heritage 82

8.3 Alternatives for Evaluation in the Impact Assessment Phase 82

8.4 Recommendations 83

9 PLAN OF STUDY FOR EIA 84

9.1 Introduction 84

9.2 Purpose of the Plan of Study for EIA 84


9.3 Detailed Impact Assessment Phase 84 9.3.1 Introduction 84 9.3.2 Impact Assessment Methodology 85 9.3.3 Consideration of Alternatives 88 9.3.4 Assessment of Potential Impacts 89 9.3.5 Public Participation Process (PPP) 91 9.3.6 Environmental Impact Report 91 9.3.7 Draft Environmental Management Programme (EMP) 92 9.3.8 Public Review of EIR and EMP 93 9.3.9 Consultation with the DEA 93 9.3.10 Proposed Project Programme for the EIA 93

9.4 Terms of Reference for Specialist Studies 94 9.4.1 General Terms of Reference for all Specialist Studies 94 9.4.2 Specific Terms of Reference 95

9.5 Conclusion 98

10 REFERENCES 99 FIGURES Figure 1: SAFARI 1 – The nuclear reactor currently used to produce radioisotopes at the

Pelindaba Necsa site 2 Figure 2: Locality map for the proposed development of the Dedicated Isotope Production

Reactor and Associated Infrastructure 5 Figure 3: EIA Process Flowchart 9 Figure 4: Nuclear Fission 13 Figure 5: Medical Scan used in Diagnosis of a Multitude of Diseases 17 Figure 6: Site Alternatives 20 Figure 7: Major topographical features in a study area of 30 km by 30 km 45 Figure 8: Pelindaba Rainfall Figures (2000 - 2010) 46 Figure 10: The study area of 30 km by 30 km with Necsa in the centre 47 Figure 11: Locations of the two weather masts on the Necsa site 49 Figure 12: Overview Map of Radii 52 Figure 13: Social Sensitivity within the 2 km Radius 52 Figure 14: Social Sensitivity within the 5 km Radius 53 Figure 15: Social Sensitivity within the 10 km Radius 54 Figure 16: Overall Preliminary Social Sensitivity Map 55 Figure 17: Racial profile in Madibeng, 2001 versus 2007 56 Figure 18: Age Profile in Madibeng, 2001 vs. 2007 57 Figure 19: Highest level of educational achievement in MLM, 2001 vs. 2007 59 Figure 20: Highest level of educational attainment by municipality, district and province in

2007 60 Figure 21: Major Sectors of Economic Employment in MLM – 2007 61 Figure 22: Occupations in MLM, 2007 62 Figure 23: Monthly income per person in MLM & BPDM for those aged 15 - 65 (2007) 62 TABLES Table 1: Property Description for the Proposed DIPR Site 4 Table 2: Listed activities in terms of section 24 and 24(d) of the NEMA as per GN R544,

R545 and R546, published on the 18 June 2010 6


Table 3: Details of the DEA Case Officer Handling the EIA Application 10 Table 4: Details of the Proponent Project Manager 11 Table 5: Details of the Environmental Assessment Practitioner (EAP) 11 Table 6: Baseline Criteria for Alternative Assessment 21 Table 7: Activities requiring Environmental Authorisation 26 Table 8: Brief review of other relevant policies, legislation, guidelines and standards

applicable to the proposed development of the DIPR and associated infrastructure 28

Table 9: Specialist Studies 35 Table 10: List of newspapers and dates in which advertisements were published. 37 Table 11: List of places where the site notices were placed. 37 Table 12: Key Stakeholder Workshop 38 Table 13: Scoping Phase Public Meetings 38 Table 14: Approximate Distances from proposed site to Major Settlements 50 Table 15: Population Size and Growth in MLM, BPDM, and North West Province 56 Table 16: Households 57 Table 17: Housing 58 Table 18: Language group breakdown for MLM, BPDM, and the North West 58 Table 19: Employment status of persons in MLM, BPDM, and North West in 2001 and

2007 60 Table 20: Annual Household Income in Madibeng (2001) 63 Table 21: Proportion of population accessing social grants in MLM, 2007 64 Table 22: Municipal service delivery in MLM, BPDM, and the North-West 64 Table 23: Crime profile in the Hartebeespoort area 65 Table 24: Healthcare Facilities in Hartebeespoort Dam 67 Table 25: Emergency, Safety and Security Infrastructure 67 Table 26: Geographical Change Processes and Potential Impacts 73 Table 27: Demographical Change Processes and Potential Impacts 74 Table 28: Economic Change Processes and Potential Impacts 75 Table 29: Institutional and Legal Change Processes and Potential Impacts 76 Table 30: Socio-Cultural Change Processes and Potential Impacts 76 Table 31: Specialist studies undertaken within the Scoping Phase of the project 80 Table 32: Impact assessment Criteria and Rating Scales 87 Table 33: Convention for Assigning a Consequence Rating 88 Table 34: Convention for Assigning a Significance Rating 88 Table 35: Summary of issues which require further investigation in the Impact

Assessment Phase 89 Table 36: Specialist Studies to be undertaken during the Impact Assessment Phase of the

project 94 APPENDICES Appendix A: Authority Consultation Appendix B: Curriculum Vitae of Environmental Assessment Practitioners Appendix C: Conceptual Design Layouts and Pre-Feasibility Reports Appendix D: Specialist Reports Appendix E: Public Participation Documentation Appendix F: Document Control Sheet


ACRONYMS AMSL: Above Mean Sea Level AQMP: Air Quality Management Plan BID: Background Information Documents BPDM: Bojanala Platinum District Municipality CT: Computerised Tomography DEA: Department of Environmental Affairs DEAT: Department of Environmental Affairs and Tourism DIPR: Dedicated Isotope Production Reactor DME: Department of Minerals and Energy DoE: Department of Energy DSR: Draft Scoping Report DWA: Department of Water Affairs EA: Environmental Authorisation EAP: Environmental Assessment Practitioner ECA: Environmental Conservations Act EIA: Environmental Impact Assessment EIR: Environmental Impact Report EMP: Environmental Management Programme FGM: Focus Group Meeting FSR: Final Scoping Report GIBB: Arcus GIBB (Pty) Ltd GN: Government Notice HF: Hydro Fluoride HSE: Health, Safety and Environment I&AP: Interested and Affected Parties IDP: Integrated Development Planning IEM: Integrated Environmental Management IRR: Issues and Response Report KSW: Key Stakeholder Workshop LEU: Low Enriched Uranium MBA: Masters in Business Administration MEC: Member of Executive Committee MLM: Madibeng Local Municipality Mo: Molybdenum MRI: Magnetic Resonance Imaging MW: Mega Watt NAAQS: National Ambient Air Quality Standards NEAS: National Environmental Authorisation System Necsa South African Nuclear Energy Corporation NEMA: National Environmental Management Act, 1998 (Act No.107 of 1998) NEMPAA: National Environmental Management: Protected Areas Act, 2003 (Act 57

of 2003) NNR: National Nuclear Regulator NPT: Non-Proliferation Treaty NSBA: National Spatial Biodiversity Assessment NTP: NTP Radioisotopes (Pty) Ltd NW DEDECT: North West Department of Economic Development, Environment,

Conservation and Tourism NWP: North West Province PBL: Planetary Boundary Layer PDT: Photodynamic Therapy PGDS: Province Growth and Development Strategy


PoS: Plan of Study PPP: Public Participation Process SAFARI -1: South African Fundamental Atomic Reactor Installation SAHRA: South African Heritage Resources Agency SEA: Strategic Environmental Assessments SIA: Social Impact Assessment SMFP: Standard Molybdenum Fuel Plates SOE: State Owned Enterprise ToR: Terms of Reference

J31126-Necsa DIPR EIA – Draft Scoping Report 1 Rev 0 / October 2011

1 INTRODUCTION

The South African Nuclear Energy Corporation (Necsa) proposes to develop a small nuclear reactor with associated infrastructure at the Necsa Pelindaba site, which is located on Church Street, West Extension, Brits District in the North West Province. The nuclear reactor is to be known as the Dedicated Isotope Production Reactor (DIPR). This DIPR is to be solely utilized for the purpose of producing radio isotopes and not for energy production. The thermal power generated by the DIPR would be less than 15 Mega Watts (MW). This process waste heat is ultimately shed to the environment through cooling towers. The radio isotopes produced are used in over 100 000 different medical procedures such as X-rays, Magnetic Resonance Imaging (MRI) scans and Computerised Tomography (CT) scans.. The proposed development will consist of:





The renovation of an existing building, which will be used for the administration of the DIPR.

In order for the proposed development to proceed, authorisation is required from the Department of Environmental Affairs (DEA). Environmental Authorisation is issued subsequent to the undertaking of an Environmental Impact Assessment (EIA). Refer to Section 1.4 for further details on the EIA process. Necsa, as the project proponent, has appointed Arcus GIBB (Pty) Ltd (GIBB) as the independent Environmental Assessment Practitioner (EAP) to undertake the EIA for the proposed development of the DIPR and associated infrastructure. This Draft Scoping Report (DSR) constitutes the culmination of the first phase of the EIA, the Scoping Phase. The Scoping Phase aims to:

Investigate and gather information on the proposed site, in order to establish an understanding of the area;

Establish how the proposed development activities will potentially impact on the environment;

Identify the Interested and Affected Parties (I&AP) by undertaking a Public Participation Process (PPP). Note: An I&AP is a person that is interested and/or affected by the proposed development;

Identify potential environmental impacts through investigation and PPP; and

Describe potential alternatives. This chapter provides background to the proposed project and the associated EIA process and outlines the purpose and details of the EIA application and the project team.


1.1 Project Description

This section provides an overall description of the proposed development of a Dedicated Isotope Production Reactor (DIPR) and associated infrastructure. Further technical details relating to the project are provided in Chapter 2 of this report. The proposed development will consist of the following elements:

1.1.1 Dedicated Isotope Production Reactor (DIPR) The DIPR is a small nuclear reactor. A nuclear reactor is a device within which the nuclear chain reaction is carried out in a controlled manner. In the DIPR, the controlled nuclear chain reaction occurs when uranium (a naturally occurring element) targets are bombarded by intense beams of neutrons to specifically produce Molybdenum 99 and Iodine 131 radioisotopes. It is important to understand that radioisotopes are varieties of the same chemical element that have an unstable nucleus, all of which decay emitting alpha, beta and gamma rays (radiation). Note the DIPR will be powered by Low Enriched Uranium fuel. The operation of the DIPR will produce less than 15 Mega Watts (MW) of thermal power.

Figure 2: SAFARI 1 – The nuclear reactor currently used to produce radioisotopes at the Pelindaba Necsa site

1.1.2 The Building to Contain the DIPR

The development will require a building constructed to certain design and safety standards to house the DIPR. The building will be approximately 35 m x 35 m in size.


1.1.3 The Utilities and Service Building

A second building would be constructed on the allocated site for the DIPR facility, to be utilised for maintenance, service and other utilities for the DIPR. This building would be approximately 30 m x 30 m in size.

1.1.4 The Administrative Building An existing office block next to the allocated DIPR site is to be renovated and used as the administrative building for the DIPR facility.

1.1.5 Cooling Towers Cooling towers will be constructed at approximately 20 m x 10 m footprint in size.

1.1.6 Temporary Construction Laydown Area A temporary laydown area (refer to Figure 2) will be utilised during the construction phase of the project. This area will be used to store machinery and equipment as well as consist of facilities such as diesel storage, toilets, showers and eating facilities.

1.1.7 Access Road An access road will be constructed to provide access to both the laydown area as well as the proposed DIPR site. After the construction phase the constructed access road is so designed to serve as a security patrol road on the inside of the Pelindaba facility perimeter.

1.1.8 Services The Necsa Pelindaba site has established sewer, water and electricity services. These services will be extended and connected to the DIPR site as part of the proposed project.

1.2 Motivation for the Proposed Development

Currently there is a nuclear reactor on the Necsa Pelindaba site which has been in operation since 1965. This reactor is referred to as the South African Fundamental Atomic Reactor Installation (Commonly known as SAFARI -1). The reactor was originally intended as a research tool to undertake basic research in nuclear science. In 1993 there was an identified local need for radio-isotopes for medical purposes. SAFARI-1 was then commissioned to produce these medical isotopes. As the field of nuclear medicine grew so did the international market for these radio-isotopes. South Africa began exporting these isotopes and now produces 20 % of the world supply of medical isotopes. There are only four other countries in the world that produce these isotopes commercially, owing to the high costs of acquiring reactors, processing facilities and supporting infrastructure. In the last 17 years no new reactor based radio-isotopes producers have entered the market.


South Africa currently produces 20% of the world supply of the Molybdenum 99 and Iodine 131 isotopes required for over 100 000 different medical procedures. The demand for the applications in nuclear medicine is growing, because of its ability to accurately diagnose cancer, heart disease and other illnesses. There is a critical global shortage of Molybdenum 99 and Iodine 131, due to the recent unscheduled closure of two reactors in Canada and Europe. In response Necsa increased production by 20% to maintain the global supply. SAFARI -1 has maintained an excellent safety record to date and today ranks as the world’s most reliable reactor for the production of medicines. In line with Government policy, SAFARI -1 has ensured that the South African public is reliably provided with affordable nuclear medicine for the diagnosis and treatment of cancer. However, international experience has shown that reactors of a similar age must be considered for replacement in the near term. Since it can take up to ten years to construct a replacement medicine-producing reactor and to ensure continuity of supply Necsa, is considering the construction of a small new medicine-producing reactor to achieve the following goals:

To permit Necsa to remain a reliable supplier of medical isotopes to the growing local and international markets and to ensure a secure supply of affordable medicines for the detection and treatment of cancer for South African patients.

To allow for more protracted life-extension programmes for the SAFARI-1 reactor, without disrupting the production of isotopes.

1.3 Property Description and Location

Table 3 below outlines the property description for the proposed development and includes the municipal jurisdiction within which the development is bounded by. Table 3: Property Description for the Proposed DIPR Site Refer to the locality map of the proposed site provided below in Figure 3.

Property Description Portion 82, Farm 567–JQ Weldaba

Street Address Church Street West Extension Brits District North West Province South Africa

Approximates Coordinates from centre point of the proposed site

Latitude: 25°47'44.78"S Longitude: 27°55'11.52"E

Project Footprint 19000 Square Metres

Local Municipality Madibeng – Ward 29

District Municipality Brits District Municipality

Ownership The site is owned and operated by the South African Nuclear Energy Corporation

Zoning Industrial 1


Figure 3: Locality map for the proposed development of the Dedicated Isotope Production Reactor and Associated Infrastructure

Proposed

DIPR Site

Construction

Laydown Area

DIPR Admin

Building

Gate 2


1.4 Environmental Impact Assessment Process Overview

1.4.1 Why is an Environmental Impact Assessment (EIA) Required?

In terms of the National Environmental Management Act, 1998 (Act No.107 of 1998) [NEMA] and associated EIA Regulations published on 18 June 2010, an environmental authorisation must be obtained from the relevant decision-making authority prior to the commencement of certain listed activities that may result in potential negative impacts on the environment. The proposed construction of the DIPR and associated infrastructure involves a number of activities that are listed in the EIA Regulations. An EIA must therefore be undertaken in order to obtain the required environmental authorization from the National Department of Environmental Affairs (DEA). The proposed construction of the DIPR involves, inter alia, the following listed activities, as per Government Notice (GN) No. R. 544-546 of NEMA: Table 4: Listed activities in terms of section 24 and 24(d) of the NEMA as

per GN R544, R545 and R546, published on the 18 June 2010

GN Activity No (s):


544

1 The reactor will be powered with Low Enrichment Uranium (LEU) standard plate-type fuel and the DIPR will have a maximum thermal power of 15 MW.


544 22 An access road will be built to permit the delivery of building material and components to the proposed DIPR site.




546 19 Widening of a road by more than 4 metres, or the lengthening of a road by more than 1 kilometre. (d) In North West :

ii. Outside urban areas, in: (hh) A protected area identified in terms of NEMPAA, excluding conservancies; (ii) National Protected Area Expansion Strategy Focus areas; (jj) Sensitive areas as identified in an environmental management framework as

contemplated in chapter 5 of the Act and as adopted by the competent authority; (kk) Sites or areas identified in terms of an International Convention; (ll) Critical biodiversity areas (Terrestrial Type 1 and 2 and Aquatic Type 1) as identified

in systematic biodiversity plans adopted by the competent authority or in bioregional plans;

(mm) Core areas in biosphere reserves; (nn) Areas within 10 kilometres from national parks or world heritage sites or 5

kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve.


1.4.2 Summary of the EIA Process

An EIA is a legislative tool that is used to ensure that potential impacts that may occur due to the proposed development are avoided or mitigated (minimised). In South African legislation, the environment includes social, economic and bio-physical aspects and the EIA must assess these equitably. The EIA procedures are based on the principles of Integrated Environmental Management (IEM) which, in short, comprises pro-active planning, informed decision making, and a transparent and participatory approach to development, a broad understanding of the environment, and accountability for decisions and the information on which they are based. The EIA process is controlled through Regulations published under the Government Notice No. R. 543 and associated guidelines promulgated in terms of Chapter 5 of the National Environmental Management Act (Act 107 of 1998). The EIA process can be divided into 4 distinct phases: (a) Application & Initial Notification

Submit an EIA application to the DEA.

DEA acknowledgement of the EIA application (within 14 days).

Notify the public of the proposed development through inter alia, newspaper adverts, notification letters, Background Information Documents (BIDs) and notice boards.

(b) Scoping Phase

Investigate and gather information on the proposed study area in order to establish an understanding of the area.

Establish how the proposed project will potentially impact on the surrounding environment.

Identify Interested and Affected Parties (I&APs) and relevant authorities by conducting a Public Participation Process (PPP).

Identify potential environmental impacts through investigation and PPP.

Describe and investigate the alternatives that may be considered. (c) Impact Assessment Phase

Detailed specialist assessment of all issues and proposed alternatives identified in the scoping phase.

Identify mitigation measures and recommendations to reduce the significance of potential impacts.

Compile an Environmental Management Programme (EMP) which will prescribe environmental specifications to be adhered to during the construction and operational phases of the project.

As with the Scoping phase, the PPP is an integral and important part of the Impact Assessment phase.


(d) Environmental Authorisation

Environmental Authorisation (EA) issued to Necsa once the DEA has made a decision regarding the proposed project.

Decision may be positive or negative based on inter alia, information received in the Scoping and Impact Assessment phases.

The full EIA Process and timeframes are discussed in further detail in Chapter 6. The EIA process and appeal process as legislated in terms of NEMA is shown diagrammatically in Figure 4 below.


Figure 4: EIA Process Flowchart

THE EIA PROCESS

PUBLIC EAP DEA

Authority Meetings

Notice Boards

Advertisements


Conduct PPP

Notify Stakeholders Distribute BID

Prepare Draft

Scoping Report

Submit Application

to DEA

Solicit Comments on DSR

Submit Final Scoping

Report to DEA

Acknowledge Receipt of the

Application within 14

Days

Reply in 40 Days to Accept DSR

Or Reject DSR

Or Request Amendment

Prepare Draft Environmental

Impact Report (EIR) and Draft

Environmental Management Plan

(EMP) Solicit Comment on

the Draft EIA & EMP

Submit Final reports to the Authority

Environmental

Authorisation

Decided within 60 days:

Accept EIR Or

Refer for reviews Or request

Amendments Or

Reject EIR

Grant or Refuse

Environmental Authorisation within

45 Days of Acceptance


on Draft Scoping Report

40 Day Comment Period

Advise I&APs on the Environmental Authorisation

SCOPING PHASE

ASSESSMENT PHASE


1.5 Details of the EIA Process to Date

1.5.1 Environmental Application

An application form was completed and submitted to the competent authority which, for this project, is the DEA, since the applicant, Necsa is a State Owned Enterprise (SOE). Any application made by a SOE must be submitted to National Department for assessment. The application has since been accepted and registered with DEA Reference Number: 12/12/20/2453 (Appendix A). Table 5: Details of the DEA Case Officer Handling the EIA Application

Name: Ms Nyiko Ngoveni

Title: Environmental Officer: Environmental Impact Evaluation: Parastatal

Postal Address:

Department: Environmental Impact Evaluation: Parastatals Private Bag X 447 Pretoria 0001

Tel: 012 395 1694 / 1768

Fax: 012 320 7539

E-mail: [email protected]

1.5.2 Draft Scoping Report

This Draft Scoping Report including the Plan of Study for EIA is distributed for public comment for a period of 40 calendar days, from 27 October until 07 December 2011. All comments on the document will be considered and responses thereto provided within an Issues and Response Report (IRR) which will be included within the Final Scoping Report (FSR) submitted to the DEA and the North West Department of Economic Development, Environment, Conservation and Tourism (NW DEDECT) for consideration. It is anticipated that NW DEDECT (among others) will provide comment to the DEA on the adequacy of the FSR, and the DEA will consider these comments prior to making a decision on the adequacy of the report. If the report is adequate then the DEA will instruct the EAP to continue on to the next phase of the EIA process.

1.5.3 Details of the Project Team This section provides details on the project proponent and the EAP undertaking the EIA. The Proponent: The South African Nuclear Energy Corporation (Necsa) The South African Nuclear Energy Corporation Limited (Necsa) is a state-owned public company, registered in terms of the Companies Act, (Act No. 61 of 1973), registration number 2000/003735/06.

mailto:[email protected]


Necsa derives its mandate from three regulatory frameworks: The Nuclear Energy Act of 1999, the Nuclear Energy Policy of 2008 as well as directives conferred on it by the Minister of Energy.

Table 6: Details of the Proponent Project Manager

Name: Ms Helene Hausberger

Title: DIPR Project Manager

Postal Address:

PO Box 582 Pretoria 0001

Tel: 012 305 5793

Fax: 012 305 5290


1.5.4 Details of the Environmental Assessment Practitioner (EAP)

Arcus GIBB (Pty) Ltd is a multi-disciplinary engineering and environmental consultancy organisation whose environmental division comprises 25 professionals. Arcus GIBB’s Environmental Division has a proven track record in the planning, co-ordination, management and execution of a wide range of environmental projects. The Arcus GIBB team consists of a number of highly qualified and experienced environmental professionals. The key areas of expertise include:

Environmental Impact Assessments (EIA);

Environmental Management Systems (EMS);

Environmental Management Programmes (EMP);

Environmental Permit Applications;

Environmental Sensitivity Analyses;

Environmental Monitoring And Auditing;

Integrated Catchment Management Plans;

Remediation Services; and

Waste Management. (a) EAP Contact Details Table 7: Details of the Environmental Assessment Practitioner (EAP)

Name Ms Rebecca Thomas

Address: 14 Eglin Road Sunninghill Gauteng 2191

Postal Address: PO BOX 2700 Rivonia 2128

Tel: 011 519 4701

Fax: 011 807 5670


mailto:[email protected]


(b) Environmental Scientist (CV) The expertise of the Environmental Scientists who carried out the EIA is summarised below, whilst detailed CVs are provided in Appendix B. Jaana Ball – EIA Project Director Ms Jaana-Maria Ball holds a M.Sc. in Botany, as well as an MBA. She is currently the Environmental Discipline Leader with 12 years experience in the environmental field. Jaana specialises in the management of large-scale Strategic Environmental Assessments (SEAs), Environmental Impact Assessments (EIAs) and Environmental Management Plans (EMPs), co-ordination and execution of public involvement processes (PPP), botanical and rehabilitation studies, integrated development planning (IDP) and management of multi-disciplinary large project teams. As a specialist botanist Jaana has undertaken a number of botanical assessments and management plans for proposed infrastructural developments. She has managed and co-ordinated a wide range of large, high profile environmental projects, including the Olifants/ Doring River feasibility study, the EIA of Blanco Boulevard, the environmental studies for the Coega Industrial Development Zone, the EIA for the proposed Francistown and Selebi-Pikwe Water Master Plans for Immediate Works, the EIA for the Braamhoek PSS project, the EIA for the Hydra-Perseus 765 kV transmission lines and the EIA for the CoJ’s flagship Strategic Public Transport Project (SPTN) and the EIA for the proposed Staatsartillary Road, north of Pretoria. Jaana has had extensive experience managing public consultation processes for IDPs, SEAs, EIAs, DWA Water Licence Applications and DME Authorisations. Ms Rebecca Thomas – EIA Project Leader Ms Rebecca Thomas - BSc (Environmental Science) is an Environmental Scientist with 7 years experience. She specialises in the management and compilation of Environmental Impact Assessments (EIAs) and Environmental Management Plans (EMPs) primarily related to energy generation and electrical transmission projects. She furthermore has also been involved in undertaking and managing Public Participation Processes and Consultation, Environmental Scans and Fatal Flaw / Feasibility Studies. Some of the projects she has worked on recently include EIAs for the proposed 300 MW Caledon Wind Farm, proposed 30 MW Wind Farm at St. Helena Bay and the Bantamsklip 400 kV Transmission Power Lines, all within the Western Cape Province. She is also currently appointed as one of the advisors in strategic environmental matters for ACSA. Rebecca is currently also completing a Post Graduate Diploma in Business Management (PDM), with the aim of bringing business and project management skills to her projects and unit as a whole. Ms Sanusha Govender – EIA Project Scientist Ms. Sanusha Govender – BSc (Environment and Development). Environmental scientist with five years of experience, specialising in managing environmental processes such as Environmental Impact Assessments, Environmental Basic Assessments, Integrated Waste Management Strategies, the development of Municipal Refuse Bylaws, Tender Adjudication, Contract Management and on site environmental auditing. In addition Sanusha has experience in the drafting Records of Decision in terms of the ECA (The Environmental Conservations Act of 1989) for the Department of Environmental Affairs and Development Planning (Western Cape).


2 DETAILED PROJECT DESCRIPTION: TECHNICAL DETAILS

2.1 The Dedicated Isotope Production Reactor (DIPR)

2.1.1 The Purpose of the DIPR

The purpose of the DIPR is as follows:

Dedicated radioisotope production to meet the growing local and international demand for isotopes, in particular Molybdenum 99 (99Mo).

The new DIPR will: - Maintain and increase the isotope production capacity of NTP in order to

meet expected market demands; - Ensure security as well as reliability of supply by supplementing and later

replace the SAFARI-1 reactor as NTP's primary source of isotopes; and - Allow the SAFARI-1 reactor to continue to play a backup role for isotope

production when required.

2.1.2 How the DIPR Works The DIPR is a small nuclear reactor dedicated only to the production of medical radioisotopes and silicon doping. A nuclear reactor is a device within which a nuclear fission chain reaction is carried out in a controlled manner. Nuclear Fission: In the DIPR, the controlled nuclear chain reaction occurs when Uranium (a naturally occurring element) targets are bombarded by intense beams of neutrons which then cause the uranium targets to break and split. This results in energy being released. This process is called nuclear fission. The split particles produced by nuclear fission are called fission fragments. In the DIPR, Molybdenum 99 and Iodine 131 radioisotopes form part of the fission fragments that are produced. Refer to the Figure 5 below which illustrates nuclear fission and the production on radioisotopes.

Figure 5: Nuclear Fission


The nuclear chain reaction is controlled by using neutron poisons and neutron moderators to change the portion of neutrons that will go on to cause more fission. The DIPR will be a pool type reactor: This kind of nuclear reactor has a core that is immersed in an open pool of water. The water acts as the neutron moderator, cooling agent and radiation shield. Water is a cooling agent because when the nuclear fission reaction in the core generates heat, such heat is removed by circulating water past the reactor core to absorb the heat. The DIPR Fuel and Power Control: The DIPR will be fuelled by Low Enriched Uranium fuel (LEU).The power output of the reactor is adjusted by controlling how many neutrons are able to create more fission. Control rods are used to absorb neutrons. Absorbing more neutrons in a control rod means that there are fewer neutrons available to cause fission, so pushing the control rod deeper into the reactor will reduce its power output, and extracting the control rod will increase it. A maximum of 15 MW of heat will be produced by the DIPR. This heat is removed by circulating water through the pool. The heat is ultimately released into the environment through cooling towers. The layer of water directly above the reactor core, shields the radiation. People may therefore work above the reactor safely. The Control Rods: The design of Control rods vary from one reactor to another, but a typical control rod consists of an upper "poison" section, a fuel element section, a lower support and a piston. The "poison" or neutron absorbing section consists of an aluminium box, containing a neutron absorber (typically Cadmium or Hafnium) insert. The actual Process to Form the Final Product: The reactor is used to irradiate (process by which an object is exposed to neutron radiation) various targets and silicon ingots. The most commonly utilised are Molybdenum targets. This process is the same as what has been established for SAFARI-1 The Molybdenum targets: In the proposed DIPR the Standard Molybdenum (Mo) Fuel Plates (SMFP) which are the targets, will be stored in a vault facility in the reactor building from where the required number of targets will be transferred daily to the reactor hot cell for loading into the target plate holders. The target plate holders are then moved to the reactor pools and loaded into the irradiation positions. Loading into and removing from the core is done by means of a motorised linear actuator to limit and control the rate of change of core reactivity. After a number of hours of irradiation, the target holders are removed from the core manually (whilst keeping adequate shielding) and stored in the storage pool for some hours for cooling. The target plate holders are then transferred manually to the reactor hot cell, from where they are removed from the reactor building in specially designed and constructed casks and transported to a separate processing facility. The processed targets remain in the processing facility and are not returned to the reactor building. At the processing facility the irradiated SMFP undergo chemical processing, separating and purifying the Molybdenum using proprietary and licensed processes, and then ultimately packing the Molybdenum, now in a final carrier, into specially designed and constructed casks, for shipment to the client.


Silicon Ingots: Silicon (Si) ingots consist of cylindrical 99.99999% pure Silicon crystals, either 5" (128 mm) in diameter, or 6" (152 mm) in diameter. In some cases 3" (76 mm) and 4" (101 mm) ingots are also irradiated. The average length of the ingots is 600 mm. Further aspects of the DIPR are listed below:

The reactor will be designed for a lifespan of 50 years;

It will be easily maintained;

It will allow for loading and uploading of targets, without needing to shut down the reactor;

The DIPR core and fuel management requirements will cater for optimal fuel utilisation, while ensuring minimal neutron flux and energy spectrum variations during the cycle from one cycle to the other;

The DIPR will use existing target irradiation technologies; and

The DIPR will be designed and operated with safety as its most important consideration.

2.1.3 What are Radioisotopes?

Radioisotopes are atoms with a different number of neutrons than those that occur in elements in their naturally occurring stable form. This cause, these isotopes to have an unstable nucleus that decays, and in the process emits alpha, beta and gamma rays, until the isotope reaches stability. The isotope is transformed entirely into another element after stability is reached.

2.1.4 Description of the Medical Isotopes Produced

Molybdenum 99: is the parent isotope of Technetium (Tc) 99m, the most widely used isotope in nuclear medical diagnostic procedures and is used in 40-50 million diagnostic procedures annually.

Iodine 131: is a widely used isotope in medical therapeutic and diagnostic procedures.

2.1.5 Nuclear Waste

The nuclear waste consists of the spent fuel and control rods, other metallic waste (mostly irradiated Aluminium and other metals), as well as liquid effluent. As for Safari, the DIPR spent fuel and control rods will be stored for the medium term in dry storage at the Thabana Pipe store. Radiological liquid effluent is monitored and where necessary, stored, treated and gradually released to the environment when radioactive levels are low enough to not cause harm to the environment.

2.1.6 Hazard and Safety Management The DIPR is a nuclear installation with associated potential risk of radiation exposure to employees and the surrounding environments. In the worst case, extreme exposure to radiation could cause radiation poisoning in humans and animals which can lead to death, depending on the level of radiation. Therefore Necsa recognizes safety, health, environment and quality (SHEQ) processes as of paramount importance and ensures that strict controls are put in place to manage these aspects.


The key concerns are the risk of inadvertent exposure of public, operating personnel and the environment to ionising radiation, above legally permissible limits. These safety concerns are considered to be of critical value to the reactor design and to the external hazards associated with the selected site. The potential consequences of any exposure is controlled by the plant design, hardware design, operation activities, administrative procedures, emergency control measures and even site characteristics, to determine the dispersion of radiation should an event occur that may affect the public. The DIPR is a small reactor, which creates in the order of 10 000 times less risk to the public than a power generating nuclear reactor, such as the reactors at the Koeberg nuclear power station. The NNR specifies acceptance criteria for the exposure risk to the public and for operating personnel. It is internationally accepted that the potential exposure risk to the public is significantly less for research (and isotope production) reactors.

2.2 Associated Infrastructure

The DIPR buildings and structures and related services and infrastructure will cater for the diverse needs of:

Safety, security and the environment;

The users, operators, maintainers and managers of the facility;

Visitors to the facility;

Access for disabled persons to all general areas and elsewhere, when practicable;

Redundancy in the flow paths of the product into, within and out of the facility;

Zoning of Material Balance Areas for the adequate Safeguarding and flow control of nuclear material; and

Radiological and fire zoning and access control between zones. Furthermore, the design of the DIPR buildings and structures and related services and infrastructure will facilitate expansion during the operating life of the facility. As detailed in Chapter 1, the DIPR site will consist of:

A DIPR Building (Approximately 35 m x 35 m);

A Utilities/ Service Building (Approximately 30 m x 30 m);

An Administrative Building (Existing building that will be renovated);

Cooling Towers (Approximately 20 m x 10 m) – lower than the SAFARI-1 tower;

Temporary Construction Laydown Area (Used to store machinery and equipment as well as consist of facilities such as diesel storage facilities, toilets, showers and eating facilities);

Access Road (along the existing fence from Gate-2 to the proposed site); and

Services (Necsa Pelindaba) site has connected sewer, water and electricity services. However the proposed development does include the extension of these existing services to the proposed DIPR and associated infrastructure).


2.3 Nuclear Medicine

Nuclear medicine utilises very small amounts of radioactive materials (radiopharmaceuticals made from radioisotopes) to diagnose and treat disease. In diagnosis, the radiopharmaceuticals are detected by special types of cameras that work with computers to provide very precise pictures about the area of the body being imaged. Some of the devices used for imaging include X-rays, MRI scanners, CT scans and ultrasound. The most important benefit of nuclear imaging procedures is that it is non-invasive and, with the exception of intravenous injections, are usually painless medical tests that help physicians diagnose medical conditions. In treatment, radiopharmaceuticals such as iodine (I-131) go directly to the organ being treated. The amount of radiation in a typical nuclear imaging procedure is comparable with that received during a diagnostic x-ray, and the amount received in a typical treatment procedure is kept within safe limits.

Figure 6: Medical Scan used in Diagnosis of a Multitude of Diseases


2.4 Decommissioning Phase

It is anticipated that during the decommissioning phase, the type of waste generated will differ from the material and wastes that are routinely handled during the operational phase of the reactor. At all phases of decommissioning, employees, the public and the environment should be adequately protected from hazards resulting from the decommissioning process. A DIPR decommissioning strategy will be compiled specific to the design parameters of the DIPR. The strategy will outline the method and phases of decommissioning of the facility and will fit into the existing Necsa decommissioning strategy. Only the most suitable method will be selected, subject to safety and economic considerations. The decommissioning strategy will dictate the development of a decommissioning plan. The decommissioning strategy will include an indicative estimate of the radiological inventory at final shut down and the likely decommissioning wastes (volumes, masses, activity levels and significant dose rates, for each anticipated type of radioactive waste) taking account of operational histories for the type of reactor proposed. The decommissioning strategy will conform to one of the following decommissioning methods:

Immediate dismantling;

Entombment; or

Long term managed storage.

The Decommissioning strategy will be addressed in further detail within the EIA phase of the project.

2.5 Conclusion

This chapter describes the various infrastructure and technology requirements for the proposed dedicated isotope production reactor and associated infrastructure.


3 PROJECT ALTERNATIVES

In terms of the EIA Regulations published in Government Notice R543 of 18 June 2010 and in terms of Section 24 (5) of the National Environmental Management Act (Act No. 107 of 1998), feasible and reasonable alternatives have to be considered within the environmental scoping phase. All identified, feasible and reasonable alternatives are required to be identified in terms of social, biophysical, economic and technical factors. A key challenge of the EIA process therefore is the consideration of alternatives1. Most guidelines use terms such as ‘reasonable’, ‘practicable’, ‘feasible’ or ‘viable’ to define the range of alternatives that should be considered. Essentially there are two types of alternatives:

incrementally different (modifications) alternatives to the Project; and

fundamentally (totally) different alternatives to the Project. Fundamentally different alternatives are usually assessed at a strategic level and EIA practitioners recognise the limitations of project-specific EIAs to address fundamentally different alternatives. In terms of incrementally different alternatives, the EIA Regulations define these in relation to a proposed activity, as “different means of meeting the general purpose and requirements of the activity, and which may include alternatives to –

the property on which or location where it is proposed to undertake the activity;

the type of activity to be undertaken;

the design or layout of the activity;

the technology to be used in the activity; and

the operational aspects of the activity.” At this stage of the EIA process (Draft Scoping Report), only site alternatives have been considered. Design, technological and operational activities are in the process of being defined further. Different isotope production technologies have been investigated, and the only viable option is the production of isotopes using uranium fission in a nuclear reactor. Necsa engineers and international contractors will ensure that alternative reactor concept designs will be investigated, focusing on safety, operational and production efficiency. Eight (8) site alternatives were identified at the existing Pelindaba Site. Alternatives around the country were not investigated since it would not be viable as the entire existing infrastructure required for the development of the DIPR already exists at the Pelindaba site.

1 In terms of the EIA Regulations published in Government Notice R543 of 18 June 2010 in terms of Section 24 (5) of the

National Environmental Management Act (Act No. 107 of 1998), the definition of “alternatives” in relation to a proposed activity,

means different means of meeting the general purpose and requirements of the activity which may include: (a) the property on

which or location where it is proposed to undertake the activity; (b) the type of activity to be undertaken; (c) the design or layout

of the activity; (d) the technology to be used in the activity; (e) the operational aspects of the activity and (f) the option of not

implementing the activity.


3.1 Site Alternative Selection2 Necsa appointed an expert panel based on Necsa’s Suitably Qualified and Experienced Person Framework. The panel was tasked to identify, assess, compare and rank potential locations for the DIPR. By using the Pelindaba site, the parameters related to the demographics, emergency planning, the ultimate heat sink, and storage and transport of radioactive waste, fresh and spent fuel were common to all the locations considered at Pelindaba. Thus, these will have no influence on the site selection. Necsa therefore used the criteria listed below for accepting or rejecting a location.

Size of the location;

Terrain of the proposed location and construction area;

Ease of integration into the existing facilities and infrastructure;

Proximity to hazardous facilities; and

Any other known disqualifier. Based on these criteria, eight site alternatives were identified on Pelindaba West as shown in Figure 7 below.

Figure 7: Site Alternatives

2 Extract from IAEA-CN-188, The Evaluation of the Selected On-site Location for a New Nuclear Facility on a Multi-facility Site,

author H Seals to be presented at the IAEA conference in November 2011.


The east campus of Pelindaba was rejected due to the proximity to the HF production facility and the challenge of integration with the existing facilities and infrastructure. Alternative 7 was deemed unsuitable since it is a natural wetland. A multi-attribute analysis was undertaken on the remaining alternative sites to compare the relative safety of all the alternatives and eliminate the less attractive sites from further consideration. This multi-attribute analysis compared each site alternative based on the criteria listed in Table 8 below. Table 8: Baseline Criteria for Alternative Assessment

Environmental Level of Clearance and Excavation

Security

Proximity to Necsa Perimeter

Ability to isolate the location during construction

Access to perimeter fence from outside

Visibility from perimeter fence

Site Safety and Necsa's Emergency Plan

Impact on existing facilities

Impact of existing facilities

Proximity to the Public

Construction

Size of location

HSE impact associated with construction

HSE impact during construction

Site location accessibility during construction

As a result of the analysis only Alternative Sites 3, 5 and 6 were identified for further analysis and assessment.

3.1.1 Identification of the Preferred Alternative It was established from the multi-attribute analysis referred to above that there were no significant differences between the remaining three alternative sites remaining. The following further specialist studies were undertaken: geology, geotechnical and geophysical; seismology; environmental sensitivity; atmospheric dispersion (as an indicator for radiological impact); security; and utility requirements. As per the “The Evaluation of the Selected On-site Location for a New Nuclear Facility on a Multi-facility Site”, the findings of the preliminary studies are as follows:

The geology investigation showed that alternative site 6 was identified as the preferred site regarding geological considerations.

The geotechnical assessment indicated no significant differences between the sites regarding slope instability. However site 3 and 6 are preferred.

Seismic site response studies showed site location 5 and then 6 are preferred.

Environmental sensitivity assessment showed no Red Data, threatened or sensitive species were recorded on any of the sites. Site 6 is the most disturbed site of the three and therefore most preferred.

The atmospheric dispersion investigation assessed a hypothetical on and off-site dose given a unit source term for a typical year’s weather. The results were not significantly different for the three sites, as was anticipated.


Nevertheless, site 6 was considered to be the preferred site from an atmospheric dispersion perspective.

In terms of the security and site impact, site location 5 would have less impact on other site activities, but in terms of security, site 6 is preferred.

Utility requirements for water and effluent estimates were assessed and site 6 was the preferred option.

Overall it was determined that Alternative 6 is the preferred site.

3.2 Alternative 9: The No Go Alternative

The ‘do-nothing’ or ‘no-go’ alternative is the option of not developing the proposed DIPR and associated infrastructure. Currently there are only four other countries in the world that produce these isotopes for sale commercially, due to the high costs of acquiring reactors, processing facilities and supporting infrastructure. In the last 17 years no new reactor based radio-isotopes producers have entered the market. There is a critical global shortage of Molybdenum 99 and Iodine 131, following the unscheduled closure of two reactors in Canada and Europe. In response Necsa increased production by 20% to maintain the global supply. The current SAFARI-1 reactor is 45 years old. Necsa’s intention is to produce isotopes for another 50 years and therefore, a DIPR will be required in future to produce isotopes. In the event of a new DIPR not being built, Necsa would be unable to:

Remain a reliable supplier of medical isotopes to the growing local and international markets in the long term.

Ensure a secure supply of affordable medicines for the detection and treatment of cancer to South African patients.

The “do-nothing’ alternative is therefore not considered to be the preferred alternative. The “do-nothing’ alternative however will be represented by the status quo, against which the proposed project will be compared in detail during the impact assessment phase of the project.

3.3 Alternatives to be assessed in the Impact Assessment Phase

In review of the preliminary investigations by Necsa only Alternative Sites 3, 5 and 6 as well as the Do Nothing / No go Alternative will be represented by the status quo in the assessment phase of this EIA.


4 LEGAL AND POLICY CONTEXT

4.1 Introduction

This section of the Scoping Report details applicable legal provisions and the policy context for the EIA. It provides a review of relevant international legal instruments as well as national legislation, regulations and policy documents, which are applicable to (or have implications for) the proposed Dedicated Isotope Production Reactor development within Necsa, Pelindaba in the Republic of South Africa. One of the main focus areas of this section is on the provisions of the National Environmental Management Act (NEMA). NEMA is the primary South African legislation governing the requirements for Environmental Impact Assessment. This chapter also describes other legislation relevant to constitutional and administrative legal precepts in South African law, as well as environmental legislation of specific relevance inter alia to the control of nuclear installations, biodiversity, waste management and air pollution. The activities associated with the project have the potential to trigger the South African requirements for EIA, and are likely to require a number of particular consents and authorisations. An analysis of the range of consents and authorisations required for the operation of the project will be the subject of a detailed legal (including environmental) analysis. This chapter does not provide such an analysis. Rather, this chapter provides a preliminary input at the Scoping phase of the EIA process, by describing the environmental and other legislation that may be relevant during the undertaking of the project.

4.2 Legislative, Policy, Planning and Guideline Context

The legislative framework applicable to this project is diverse and consists of a number of Acts and Regulations which must be complied with. A summary of the key environmental legislation and relevant policies and/or guidelines is provided in the following sections:

4.2.1 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA)

NEMA3 is the most significant single piece of legislation dealing with environmental management in South Africa. The stated purpose of NEMA is, amongst other things, “to provide for co-operative environmental governance by establishing principles for decision-making on matters affecting the environment, institutions that will promote

3 NEMA applies throughout the territory of the Republic of South Africa which effectively means that it applies throughout the

terrestrial area of the Republic and seaward beyond the low-water mark, to the outer extent of the territorial waters (which

extend for 12 nautical miles from the low-water mark or specifically demarcated baselines – see the provisions of the Maritime

Zones Act, 15 of 1994 in this regard).


co-operative governance and procedures for co-ordinating environmental functions exercised by organs of state...”4 NEMA takes the form of “framework” legislation. It establishes a set of 18 principles which apply throughout the Republic to the actions of all organs of state that may significantly affect the environment and - “a) shall apply alongside all other appropriate and relevant considerations,

including the State's responsibility to respect, protect, promote and fulfil the social and economic rights in Chapter 2 of the Constitution and in particular the basic needs of categories of persons disadvantaged by unfair discrimination.

b) serve as the general framework within which environmental management and implementation plans must be formulated.

c) serve as guidelines by reference to which any organ of state must exercise any function when taking any decision in terms of this Act or any statutory provision concerning the protection of the environment.

d) serve as principles by reference to which a conciliator appointed under this Act must make recommendations.

e) guide the interpretation, administration and implementation of this Act, and any other law concerned with the protection or management of the environment.” 5

The following principles contained in section 2 of NEMA are of particular relevance in that they potentially impact on any decision that may be taken by organs of state in relation to the authorisation of the construction of electricity transmission infrastructure in South Africa:

“Environmental management must place people and their needs at the forefront of its concern, and serve their physical, psychological, developmental, cultural and social interests equitably.”6

“Development must be socially, environmentally and economically sustainable.”7

“Sustainable development requires the consideration of all relevant factors including the following:

(i) That the disturbance of ecosystems and loss of biological diversity are avoided, or, where they cannot be altogether avoided, are minimised and remedied.

(ii) that pollution and degradation of the environment are avoided, or, where they cannot be altogether avoided, are minimised and remedied.

(iii) that the disturbance of landscapes and sites that constitute the nation's cultural heritage is avoided, or where it cannot be altogether avoided, is minimised and remedied.

4 Long title of NEMA. Section 239 of the Constitution defines an “organ of state” as:

(a) any department of state or administration in the national, provincial or local sphere of government; or (b) any other functionary or institution- (i) exercising a power or performing a function in terms of the Constitution or a provincial constitution; or (ii) exercising a public power or performing a public function in terms of any legislation,

but does not include a court or a judicial officer. 5 Section 2(1) of NEMA.

6 Section 2(2) of NEMA.

7 Section 2(3) of NEMA.


(iv) that waste is avoided, or where it cannot be altogether avoided, minimised and re-used or recycled where possible and otherwise disposed of in a responsible manner.

(v) that the use and exploitation of non-renewable natural resources is responsible and equitable, and takes into account the consequences of the depletion of the resource.

(vi) that the development, use and exploitation of renewable resources and the ecosystems of which they are part do not exceed the level beyond which their integrity is jeopardised.

(vii) that a risk-averse and cautious approach is applied, which takes into account the limits of current knowledge about the consequences of decisions and actions.

(viii) that negative impacts on the environment and on people's environmental rights are anticipated and prevented, and where they cannot be altogether prevented, are minimised and remedied.”8

“The participation of all interested and affected parties in environmental governance must be promoted, and all people must have the opportunity to develop the understanding, skills and capacity necessary for achieving equitable and effective participation, and participation by vulnerable and disadvantaged persons must be ensured.”9

“The social, economic and environmental impacts of activities, including disadvantages and benefits, must be considered, assessed and evaluated, and decisions must be appropriate in the light of such consideration and assessment.”10

“There must be intergovernmental co-ordination and harmonisation of policies, legislation and actions relating to the environment.”11

“Global and international responsibilities relating to the environment must be discharged in the national interest.”12

NEMA also contains provisions on the creation of environmental management plans (programmes) and environmental implementation plans and stipulates the respective organs of state responsible for doing so, as well as what such management and implementation plans are to include13. Chapter 5 of NEMA, entitled “Integrated Environmental Management” establishes the environmental impact assessment regime in South Africa. Since 3 July 2006, the procedural and substantive requirements for undertaking EIAs in South Africa have been regulated in terms of the provisions contained in section 24 of NEMA and the NEMA EIA Regulations14. The NEMA EIA Regulations identify lists of activities which require either “basic assessment”15 or “scoping and environmental impact assessment”16; and prescribe the procedural and substantive requirements for the undertaking of EIAs and the issue of environmental authorisations.

8 Section 2(4)(a) of NEMA.

9 Section 2(4)(f) of NEMA.

10 Section 2(4)(i) of NEMA.

11 Section 2(4)(l) of NEMA.

12 Section 2(4)(n) of NEMA.

13 Chapter 3 of NEMA (Sections 11-16).

14 Published respectively in Government Notices R544, 545 and 546 in Government Gazette dated 2 August 2010, as

amended. 15

GN R544 and R546 in Government Gazette dated 2 August 2010. 16

GN R545 in Government Gazette dated 2 August 2010.


Activities identified in terms of section 24(2)(a) and (d) of NEMA, which may not commence without environmental authorisation from the competent authority and in respect of which the investigation, assessment and communication of potential impact of such activities must follow the procedure as described in regulations 22 to 26 of the NEMA EIA Regulations. If the activity is listed in GN R. 544, GN R. 545 and GN R. 546, an applicant applies for authorisation either by undertaking a basic assessment or a scoping and EIA process, respectively. Activities that apply to the proposed development of the Dedicated Isotope Production Reactor and Associated Infrastructure are detailed in Table 9 below. Table 9: Activities requiring Environmental Authorisation

GN Activity No (s):


544

1 The reactor will be powered with Low Enrichment Uranium (LEU) standard plate-type fuel and the DIPR will have a maximum thermal power output of 15 MW.


544 22 A proposed access road will be built on the site for delivery of building materials and components to the proposed DIPR site.




546 19 Widening of a road by more than 4 metres, or the lengthening of a road by more than 1 kilometre. (e) In North West :

iii. Outside urban areas, in: (oo) A protected area identified in terms of NEMPAA, excluding conservancies; (pp) National Protected Area Expansion Strategy Focus areas; (qq) Sensitive areas as identified in an environmental management framework as

contemplated in chapter 5 of the Act and as adopted by the competent authority; (rr) Sites or areas identified in terms of an International Convention; (ss) Critical biodiversity areas (Terrestrial Type 1 and 2 and Aquatic Type 1) as identified

in systematic biodiversity plans adopted by the competent authority or in bioregional plans;

(tt) Core areas in biosphere reserves; (uu) Areas within 10 kilometres from national parks or world heritage sites or 5

kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve.

4.2.2 Department of Environmental Affairs and Tourism Integrated Environmental

Management Guideline Series (2010) The DEA has developed a series of guidelines to assist environmental assessment practitioners, potential applicants and interested and affected parties in understanding the roles, responsibilities and Regulations associates with the EIA process. The 2010 series currently includes:


Guideline 3: General guide to the EIA Regulations;

Guideline 4: Public participation;

Guideline 5: Assessment of alternatives and impacts; and

Guideline 6: Environmental management frameworks.

4.2.3 Other Acts/Regulations/Policies/Guidelines Relevant to the Project Several other Acts, Plans, Policies and Guidelines have also informed the project. Table 8 below provides a brief review of other relevant policies, legislation, guidelines and standards applicable to the proposed development. A more detailed review of legislative requirements applicable to the proposed project will be included in the Impact Assessment Phase.


Table 10: Brief review of other relevant policies, legislation, guidelines and standards applicable to the proposed development of the DIPR and associated infrastructure

Legislation Details/Applicable Sections

National Legislation

The Constitution of the Republic of South Africa (Act 108 of 1996)

The Constitution of the Republic of South Africa is the supreme law of South Africa and is the statute against which all other law (both statutory instruments and the common law) must be measured. To the extent that other laws conflict with the Constitution, they are as a general rule invalid, subject to the provisions of the limitations clause contained in section 36.

The Bill of Rights forms the cornerstone upon which the constitutional dispensation in South Africa is built. It applies to all law, and binds the legislature, the executive, the judiciary and all organs of state. (Chapter 2, Section 7 – 39);

Environmental Rights i.e. “Everyone has the right to an environment which is not harmful to their health or well-being; and to have the environment protected for the benefit of present and future generations through reasonable legislative and other measures (Section 24);

Rights to Freedom of Movement and Residence (Section 22);

Property rights (Section 25);

The Right of Access to Information (Section 32);

The Right to Just Administrative Action (Section 33);

Enforcement of Rights (Section 38 of the Constitution);

Limitations of Rights (Section 36);

Provincial Competence (Section 44 and 104); and

Local Authority Competence (Section 44, 104, 154, 156 and Part B of Schedule 4 and Part B of Schedule 5).

National Energy Act (Act 34 of 2008)

The Act is aimed to ensure that diverse energy resources are available, in sustainable quantities and at affordable prices, to the South African economy in support of economic growth and poverty alleviation, taking into account environmental management requirements and interactions amongst economic sectors.

The Act also provides for energy planning, increased generation and consumption of renewable energies, contingency energy supply, holding of strategic energy feedstock’s and carriers, adequate investment in, appropriate upkeep and access to energy infrastructure.

The act also establishes an institution to be responsible for promotion of efficient generation


and consumption of energy and energy research; and to provide for all matters connected therewith.

The Promotion of Administrative Justice Act (Act 3 of 2000)

Definitions (Section 1);

Procedural Fairness (Section 3, 4 and 6);

Right to Reasons for Decisions (Section 5); and

Judicial Review (Section 6 and 8).

Promotion of Access to Information Act (Act 2 of 2000)

The purpose of the Promotion of Access to Information Act (“PAIA”) is to give effect to the constitutional right of access to any information held by the State and any information that is held by another person and that is required for the exercise or protection of any rights, and to provide for matters connected therewith.

Environmental Conservation Act (Act 73 of 1989)

National Noise control Regulations (GN R154 dated 10 January 1999).

National Heritage Resources Act (Act No. 25 of 1999)

Stipulates assessment criteria and categories of heritage resources according to their significance (Section 7);

Provides for the protection of all archaeological and Paleontological sites, and meteorites (Section 35);

Provides for the conservation and care of cemeteries and graves by SAHRA where this is not the responsibility of any other authority (Section 36);

List activities which require developers to notify the responsible heritage resources authority and furnish it with details regarding the location, nature and extent of the proposed development (Section 38); and

Requires the compilation of a conservation management plan as well as a permit from SAHRA for the presentation of archaeological sites as part of tourism attraction (Section 44).

National Environmental Management: Biodiversity Act (Act No. 10 of 2004

Provides for the MEC or Minister to list ecosystems which are threatened and in need of protection (Section 52) (none published as yet);

Provides for the MEC or Minister to identify any process or activity in such a listed ecosystem as a threatening process (Section 53) (none published as yet);

A list of threatened and protected species has been published in terms of Section 56(1), Government Gazette 29657; and

Three government notices have been published, i.e. GN R150 (commencement of Threatened and Protected Species Regulations, 2007), GN R 151 (Lists of critically endangered, vulnerable and protected species) and GN R 152 (Threatened or Protected Species Regulations).


National Environmental Management: Air Quality Act (Act No 39 of 2004)

The Act reforms the law regulating air quality in South Africa by providing reasonable measures for the prevention of pollution and ecological degradation, such as national norms and standards regulating air quality monitoring, management and control by all spheres of government, as well as specific air quality measures which will be regulated by virtue of an atmospheric emissions licensing system.

Emissions Licences: No person may conduct an activity so listed without a provisional atmospheric emission licence. A list of activities requiring an emissions licence has recently been promulgated.

Measures in respect of dust control (Section 32) (no regulations promulgated as yet); and

Measures to control noise (Section 34). (No regulations promulgated as yet).

Conservation of Agricultural Resources Act (Act No. 43 of 1983)

Prohibition of the spreading of weeds (Section 5);

Classification of categories of weeds and invader plants (Regulation 15 of GN R1048) and restrictions in terms of where these species may occur; and

Requirement and methods to implement control measures for alien and invasive plant species (Regulation 15E of GN R1048).

National Water Act (Act No 36 of 1998)

National Government is the public trustee of the Nation’s water resources (Section 3);

Entitlement to use water (Section 4);

Duty of Care to prevent and remedy the effects of pollution to water resources (Section 19);

Procedures to be followed in the event of an emergency incident which may impact on a water resource (Section 20);

Definition of Water Use (Section 21);

Requirements for registration of water use (Section 26 and Section 34); and

Definition of offences in terms of the Act (Section 151).

Waste Act (Act No 59 0f 2008) Waste Management Measures; and

Regulations and schedules.

National Forests Act (Act No. 84 of 1998)

Protected Trees; and

Forests.

Hazardous Substances Act, 1973 (Act No. 115 of 1973)

Measures for the control of substances and certain electronic products which may be toxic, corrosive, irritant, strongly sensitizing or flammable in nature which may cause injury or ill-health to or death of humans.

The Act divides the substances or products into groups in relation to the degree of danger and makes provision for the prohibition and control of the importation, manufacture, sale, use, operation, application, modification, disposal or dumping of such substances and


products.

The National Key Points Act The Act places certain duties on the owner of such a Key Point, and requires the owner to take steps at his/her own expense to the satisfaction of the Minister in respect of the security of the said Key Point. If the said owner without reasonable cause refuses or fails to take the steps specified, he/she shall be guilty of an offence and liable on conviction to a fine not exceeding R20 000.00 or to imprisonment for a period not exceeding 5 years or to both such fine and such imprisonment. Note that Pelindaba is a national key point.

Nuclear Energy Act, 1999 (Act No. 46 of 1999)

The 1999 Act establishes the South African Nuclear Energy Corporation Limited (Necsa), a public company wholly owned by the State, and defines the Necsa functions and powers, and its financial and operational accountability.

Sets out Necsa’s main functions which include: o To undertake and promote research and development in the field of nuclear energy and

radiation sciences and technology and, subject to the Safeguards Agreement, to make these generally available;

o to process source material, special nuclear material and restricted material and to reprocess and enrich source material and nuclear material; and

o to co-operate with any person or institution in matters falling within these functions subject to the approval of the Minister.

National Nuclear Regulator Act, 1999 (Act No. 47 of 1999)

Section 3 of the National Nuclear Regulator Act, 1999 establishes the National Nuclear Regulator. In terms of section 5(a) to 5(f) of the Act, the objects of the Regulator are, amongst others, to provide for the protection of persons, property and the environment against nuclear damage through the establishment of safety standards and regulatory practices and to ensure that the provisions for nuclear emergency planning are in place.

Nuclear installation licences are those referred to in section 21(1) of the Act. The process of applying for a licence to site, construct, operate, decontaminate or decommission a nuclear installation may be made by any person, who (or which) may apply in the prescribed format to the Chief Executive Officer of the National Nuclear Regulator. That person “…must furnish such information as the board requires”.

Government Notice No. 287 of March 2004: Regulations on the development surrounding any nuclear installation to ensure the effective implementation of any Nuclear Emergency Plan.

Sets out the specific requirements relating to the control and/or monitoring of development within the formal emergency planning zone surrounding a specific nuclear installation, after consultation with the relevant provincial and/or municipal authorities.


The Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002)

“give effect to section 24 of the Constitution by ensuring that the nation’s mineral and petroleum resources are developed in an orderly and ecologically sustainable manner while promoting justifiable social and economic development”.

Municipal by-laws

This chapter, which considers the potentially relevant national and provincial environmental legislative dimension of the project, does not include discussion on relevant municipal by-laws. However, it is possible that certain municipal by-laws will be relevant to the project and these will be discussed further during the impact assessment phase of the EIA.

Policy and Planning Context

National Spatial Biodiversity Assessment (“NSBA”)

The NSBA establishes protection and conservation priority status for terrestrial, inland water, estuarine and marine ecosystems at a 1:250,000 scale nationally and suggested implementation options for priority areas. It provides the national context for development of biodiversity plans at the sub-national and local scale.

Draft National Strategy for Sustainable Development

The (draft) National Strategy notes that the nation’s biodiversity provides critical ecosystem services on which socio-economic systems depend. Although still in development, the final product is set to be used by government and stakeholders to enhance South Africa’s long term planning capacity. It would specifically influence national and provincial development strategies.

Radioactive Waste Management Policy and Strategy

The purpose of the Radioactive Waste Management Policy and Strategy for the Republic of South Africa (2005) is to ensure the establishment of a comprehensive radioactive waste governance framework by formulating, additional to nuclear and other applicable legislation, a policy and implementation strategy in consultation with all stakeholders.

Nuclear Energy Policy for the Republic of South Africa

The Nuclear Energy Policy for the Republic of South Africa (DME, 2008) represents South Africa’s vision for the coordinated development of the nuclear energy sector. The vision is premised on article IV of the Treaty on the Non-Proliferation of Nuclear Weapons (NPT) which, the policy states, affirms South Africa’s inalienable right to research, develop, produce and use nuclear energy for peaceful purposes.


4.3 Conclusion

This legal review has provided a preliminary overview of the key aspects of environmental policy and the key environmental legal framework relating to the project. It provides a preliminary identification and review of the most relevant international, national and provincial environmental legislation as well as relevant international standards and guidelines. It must be noted that this preliminary review does not include all potentially relevant laws, policies, standards and guidelines.


5 PUBLIC PARTICIPATION AND EIA PROCESS METHODOLOGY

5.1 Introduction

The EIA process for the proposed development of the DIPR and associated infrastructure consists of two main phases, namely the scoping phase and impact assessment phase. This report details and evaluates the tasks undertaken during the scoping phase of the EIA. Scoping has been undertaken in accordance with the requirements of Government Notices R543 of 2010, and the IEM Information Series (DEA, 2002). The objectives of the scoping phase are to:

Ensure that the process is open and transparent and involves the authorities, proponent and stakeholders;

Identify the important characteristics of the affected environment;

Ensure that feasible and reasonable alternatives are identified and selected for further assessment; and

Determine possible impacts of the project on the environment.

5.2 Scoping Phase

5.2.1 Consultation with Authorities

The National Department of Environmental Affairs (DEA) is the competent authority for the proposed project since the proponent, Necsa is a State Owned Enterprise (Owned or controlled wholly or partly by the government). Furthermore the proposed development is of national significance and therefore the National Department must be the competent authority. As such the DEA is required to evaluate the EIA in terms of the relevant legislation and determine whether an Environmental Authorisation will be issued by DEA in order for the proposed development to proceed. The key commenting authority for the proposed development is the North West Provincial Department of Economic Development, Environment, Conservation and Tourism (NW DEDECT). These authorities were consulted from the outset of this study, and have been engaged throughout the project process. Authority consultation included the following activities:

Submission of an application for authorisation in terms of NEMA (Act 107 of 1998) on 12 September 2011. This application was initially rejected on the 27 September 2011, based on the omission of the project schedule which was required by DEA to process the application. On the 27 September 2011 GIBB submitted the project schedule to DEA. The application was officially accepted on 07 October 2011.

Submission of a copy of the application for authorisation to NW DEDECT on 10 October 2011.

Following the submission of the application for authorisation, the DEA acknowledged receipt thereof in the form of an Acknowledgement of Receipt


letter from DEA dated 07 October 2011 (Appendix A) and issued EIA Reference Number 12/12/20/2453 and NEAS Reference Number DEA/EIA/0000547/2011.

5.2.2 Consultation with other Relevant Authorities

Background information regarding the proposed project was provided to other relevant authorities, together with a registration and comment form formally requesting their input into the EIA process. These authorities include inter alia:

Madibeng Local Municipality (MLM);

Bojanala Platinum District Municipality (BPDM);

Department of Energy (DoE);

Department of Water Affairs (DWA); and

South African Heritage Resources Agency (SAHRA). A full list of key stakeholders consulted during the environmental scoping phase is included in the I&AP database (Appendix E). Authority consultation will continue throughout the remainder of the EIA process.

5.2.3 Identification of Potentially Significant Environmental Impacts Potential positive and negative direct and indirect environmental impacts associated with the proposed project were identified within the scoping phase and have been evaluated through desktop studies and a one day site visit. In evaluating the potential impacts, studies were provided by the following specialists: Table 11: Specialist Studies

Specialist Study Specialist Name Appendix

Ecology (Fauna and Flora) David Hoare: David Hoare Consulting Appendix D1

Air Quality Impact Assessment Lucian Burger: Airshed Planning Professionals

Appendix D2

Social Impact Assessment Nonka Byker: MasterQ Research Appendix D3

Heritage Impact Assessment Johnny van Schalkwyk: NCM Appendix D4

5.2.4 Scoping Report

The scoping report represents the findings of the scoping phase of the proposed project and the purpose of the report is therefore to document these findings in the form of a Draft and Final Scoping Report. The report documents the issues identified through the site visit, the Public Participation Process (PPP) as well as through the professional input of the relevant specialists and the GIBB team. The Draft Scoping Report (DSR) constitutes the first preliminary report which has been made available to the public and the relevant authorities for comment from 27 October 2011, for a period of 40 days (excluding public holidays) until the 07 December 2011. The Final Scoping Report (FSR) will be an updated version of the DSR and evaluates and integrates all the public and authority comments arising from the PPP after the publication of the DSR. Furthermore all I&AP comments will be captured in an updated Issues and Response Report (IRR). Thereafter correspondence will be sent to all I&APs registered on the I&AP database, informing them of the availability of the FSR submitted to DEA in order for the public to note how their comments have been addressed.


5.2.5 Plan of Study for EIA

The Terms of Reference (ToR) for specialist studies are outlined in the Plan of Study (PoS) for EIA, presented in Chapter 9. The results of the specialist studies will form part of the Environmental Impact Report (EIR), which will be compiled during the detailed Impact Assessment Phase of the EIA process.

5.3 Public Participation Process

A comprehensive Public Participation Process (PPP) has been implemented as part of the Scoping Phase of the EIA. The PPP aims to:

Ensure all relevant key stakeholders and Interested and Affected Parties (I&APs) have been identified and invited to engage in the scoping phase:

Raise awareness, educate and increase understanding of stakeholders about the proposed project, the affected environment and the environmental process being undertaken:

Create open channels of communication between key stakeholders and I&APS and the project team;

Provide opportunities for key stakeholders and I&APS to identify issues or concerns and suggestions for enhancing potential benefits and to prevent or mitigate impacts:

Accurately document all opinions, concerns and queries raised regarding the project; and

Ensure the identification of the significant alternatives and issues related to the project.

5.3.1 Identification of Key Stakeholders and I&APs

The identification and registration of I&APs will be an ongoing activity during the course of the project. Please note however that only registered I&APs are entitled to comment, in writing, on all written submissions made to the competent authority by the applicant or the EAP managing an application, and to bring to the attention of the competent authority any issues which that party believes may be of significance to the consideration of the application, provided that comments are submitted within the timeframes that have been approved or set by the competent authority or any extension of a timeframe agreed to by the application or EAP. GIBB will develop, maintain and constantly update an electronic I&AP database for the project (see Appendix E). The I&APs for the project have been identified using the following:

Existing I&AP databases obtained from the client;

Existing I&AP databases for other projects within the study area;

Placement of newspaper advertisements in three newspapers;

Placement of site notices at identified site locations;

Placement of site notices in venues in the surrounding towns;

Distribution of Background Information Documents (BIDs);

Discussions with community leaders and relevant ward councillors; and

Completed comments sheets.


5.3.2 Notification and Advertisements

In accordance with the requirements of the NEMA EIA Regulations, the project has been advertised in a number of newspapers and site notices. The purpose of the advertisement and site notice is to notify the public about the proposed project and to invite them to register as I&APs (see Appendix E). The relevant advertisement dates are listed in Table 12 below. The list of places where the site notice was placed is provided in Table 13 below and photographic evidence included in Appendix E. Table 12: List of newspapers and dates in which advertisements were

published.

Newspaper Publication Date Language

Brits Pos 27 October 2011 Afrikaans

Kormorant 27 October 2011 Afrikaans

The Citizen 27 October 2011 English

Table 13: List of places where the site notices were placed. On Site at the Entrances and Exits at Necsa Gates 1, 2 and 3

Broederstroom stall at the intersection of the R512 and R104

Maluti Shopping Centre in Schoemansville

Village Mall in Hartbeespoort

Sediba Plaza in Hartbeespoort

Mountain Lake Shopping Centre in Broederstroom

Community Library in Atteridgeville

Madibeng Local Municipality Offices

Bojanala Platinum District Municipality Offices

The project and environmental assessment process have been widely announced, with an invitation to the general public to register as I&APs and to actively participate in the PPP. This was achieved using:

Print media advertisements in English and Afrikaans that were placed in regional and local newspapers for the Project.

A letter of notification written in English and Afrikaans that was sent to identified I&APs, announcing the project and opportunities for participation.

A Background Information Document (BID) and comment sheet were produced in English and Afrikaans detailing the proposed project and explaining the EIA process. The BID was mailed to I&APs on the database and delivered to identified strategic public venues.

Copies of the BID were made available to I&APs as and when requested. Public documents were also made available in public libraries and other local public venues.

5.3.3 Background Information Document (BID)

The Background Information Document (BID) that briefly describes the proposed project was compiled in English and Afrikaans and distributed to all identified and registered I&APs. The BID introduces the proposed project and contains background information on the project, the proponent, consultants and proposed process to be followed. It also includes a locality map and a registration/comment sheet inviting I&APs to submit details of any issues, concerns or inputs they might have with regards to the proposed project. A copy of the BID is included in Appendix E.


5.3.4 Environmental Scoping Phase Meetings

There are various forms of public meetings. These include Key Stakeholder Workshops (KSWs), Focus Group Meetings (FGMs), Public Meetings with different public sectors, organisations and individuals, as well as one-on-one interactions. The purpose of these meetings is to present I&APs with information pertaining to the project and the process being followed, as well as, to document and discuss any issues which the public wishes to raise.

A Key Stakeholder Workshop to discuss the issues around the proposed DIPR and associated infrastructure will be held as shown in Table 14. Key Stakeholders that have been invited to the workshop are representatives of relevant sectors. Table 14: Key Stakeholder Workshop

Province Area Venue Date

North West Necsa, Pelindaba

Necsa Visitors Centre at Gate 1

Friday 11 November 2011, 10h00 until 12h00

In addition, invitations to Public Meetings have been extended in letters, telephone and public notices. Table 15 provides a list of the dates and venues where the public meetings are to be held. The purpose of the Public Meetings will be to provide an appropriate platform to enable I&APs to raise issues and have the opportunity to interact one-on-one with the applicant and the EIA Project Team, either in English or Afrikaans. Presentations and poster displays will be given at the public meetings. Table 15: Scoping Phase Public Meetings

No. Area Venue Date

1 Necsa, Pelindaba

Necsa Visitors Centre at Gate 1

Saturday 12 November 2011, 11h00 until 13h00

2 Atteridgeville Atteridgeville Community Centre

Monday 14 November 2011, 18h00 until 20h00

One-on-one interactions will be held with individuals and representatives of relevant sectors. These interactions will be particularly useful in identifying key issues and other relevant stakeholders. For groups with significant common interest around a particular issue or geographic area, meetings will be held with these interest groups. Interaction with members of various Focus Groups will continue throughout the EIA process. Additional Key Stakeholder Workshops will also be held if required. Minutes of all meetings held with I&APs will be taken and will be forwarded to the attendees for verification of their issues. The minutes of the consultation will be included within the FSR. The comments raised during the public participation process described above, will be recorded in the updated Issues and Response Report (IRR) to be included in the Final Scoping Report.


5.3.5 Ongoing Consultation and Engagement

In addition to the public documents distributed to I&APs, there will be ongoing communication between the applicant, the EIA team and I&APs. These interactions include the following:

In addition to the project announcement letter, a letter will be sent out to all registered I&APs providing them with an update of the project in the next phase of the project;

Interactions with I&APs will take place in English and Afrikaans where required;

Feedback to Key stakeholders, individually and collectively; and

Written responses (email, faxes and letters) have been and will continue to be provided to numerous I&APs acknowledging issues and providing information requested (dependent on availability).

The consultation with all Key stakeholders and I&APs will continue into the environmental impact assessment and EMP phase. Consultation will continue and will include:

Distribution of all project information and findings to I&APs.

EIA feedback open day and public meeting.

5.3.6 Public Review of the Draft Environmental Scoping Report

This draft Environmental Scoping Report has been made available for review, for a period of 40 days (excluding public holidays) from 27 October 2011 to 07 December 2011 at the following public locations:

Reception Building at Gate 2, Necsa Pelindaba;

Schoemansville branch of the Madibeng Municipality;

Atteridgeville Public Library;

GIBB Offices, 14 Eglin Road, Sunninghill;

http://projects.gibb.co.za/; and

http://www.necsa.co.za. All registered I&APs have been notified in writing of the availability of the report. Comments received during the review period will be included in the FSR to be submitted to the authorities for decision-making.

5.3.7 Final Environmental Scoping Report The final stage in the environmental scoping phase entails the capturing of responses and comments from I&APs on the Draft Scoping Report, in order to refine the Environmental Scoping Report, and ensure that all issues of significance are addressed. The Final Environmental Scoping Report will be submitted to DEA for review and decision-making.

http://projects.gibb.co.za/


5.4 Conclusion

This chapter discusses the various tasks that have been undertaken as part of the scoping phase of the EIA process. Two of the main components, include the Public Participation Process and the identification of the impacts that will be assessed in the detailed specialist studies completed as part of the impact assessment phase. The Environmental Scoping phase has been undertaken in accordance with the requirements of the National Environmental Management Act (NEMA) (Act 108 of 1998), as read with Government Notices R 544, 545 and 546 of the NEMA and the IEM Information Series (DEA, 2002).


6 DESCRIPTION OF THE BASELINE ENVIRONMENT

6.1 Introduction

This section provides a description of the baseline environment in the study area, which may be affected by the proposed project. The receiving environment is described in terms of biophysical and socio-economic environmental factors, those which could potentially be directly or indirectly affected by the project, or which could themselves, affect the proposed project. This information was extracted from the various specialist studies undertaken during the EIA phase of this study as well as readily available information for the study area.

6.2 General Study Area

6.1.1 Regional Context

This information was obtained from the Social Impact Study (Appendix D). The proposed project site is located entirely within Necsa’s Pelindaba site. Pelindaba is located along the R104 in the Madibeng Local Municipality which forms part of the Bojanala District of the Northwest Province. This section provides a broad overview of the province and district, and will be followed by a more detailed baseline profile of the local municipal area in the ensuing sections. The Northwest Province (NWP) is located on the northern border of South Africa and has land surface area of approximately 116,180.3 km2, which represents approximately 9.5% of South Africa’s total land surface. The province is bordered by the Northern Cape to the southwest, the Free State to the south, Gauteng to the southeast, and the Limpopo Province to the northeast. According to Community Survey 2007, the province is home to 3 271 948 people, which represents approximately 6.8% of the total population of South Africa. The average population density within the NWP stands at approximately 28.2 people per km2 (although this will be much higher in urban areas). Significant towns within the province include Brits, Klerksdorp, Lichtenburg, Potchefstroom, Rustenburg, Vryburg, and the capital, Mafikeng. Initially these towns were agricultural centres, but later evolved into mining centres. Rustenburg is reportedly the fastest growing urban centre in Africa due to increased mining activities along the Bushveld Igneous Complex. This situation gave rise to a steady increase in the urbanisation rate within the province over the past 10 years: in 2006, 11% more of the province’s total population lived in urban areas than in 1996, and close on 9% more than was the case in 2001. Despite this increase, the province’s urbanisation rate is still approximately 10% lower than that of the country as a whole (estimated at around 56%). The province’s economy is largely based on the mining industry, which generates more than half of the province’s revenue. This sector also employs approximately 23% of the economically active population. Platinum, vanadium and a host of other


minerals are mined in the province, most notably along the Merensky Reef (between Brits and Rustenburg), from which approximately 94% of the country’s platinum is extracted. Other noteworthy minerals being mined in the province include granite (46% of South Africa’s granite) in the Brits area and gold (25% of the country’s gold) in the Klerksdorp/Potchefstroom area. According to the province’s environment outlook (2008) the main minerals being mined in the Northwest include:

Gold, mined in the Orkney, Klerksdorp and Carltonville areas;

Uranium, mined in the Klerksdorp area;

Platinum Group Metals and Chrome, mined in the Rustenburg and Brits areas; and

Diamonds, mined in the Lichtenburg, Christiana and Bloemhof areas.

Although agriculture is not viewed as the major contributor to the province’s economy from a purely financial perspective, this sector remains the largest employer in the province. According to Statistics South Africa (StatsSA) (in the Northwest Environment Outlook, 2008), over 40% of the province’s total population are considered to be ‘not economically active’, while a further 21% are unemployed. This means that only approximately 38.5% of the province’s total population are formally employed, which leaves the province with a fairly high unemployment rate. It would furthermore appear that unemployment amongst females is much higher than amongst males. With such a high unemployment rate, it follows that, in 2006, approximately 53% of the province’s total population lived in poverty. This means that the poverty level in 2006 was approximately 8% higher than it was in 1996. For this reason the provincial government developed a poverty relief programme with the aim to:

Provide basic service delivery;

Reduce poverty by helping the poor to help themselves;

Create human capital to assist the poor; and

Improve institutions and management systems. As could be expected, the largest concentration of people living in poverty are found close to major urban areas and other centres of potential employment, such as mines and industrial areas. As is the case with all the provinces in South Africa, the Northwest’s spatial pattern is characterised by a system of economic and social segregation, which means that large segments of the population still have limited access to economic and social opportunities. The settlement patterns in the province are described as ‘unsustainable’, contributing to the fact that human development progress has been hampered by a lack of basic infrastructure, such as water, sanitation and electricity. Currently settlement patterns are therefore shaped by the availability of water and land, and the proximity of the area to minerals, markets, and social and economic opportunities. During the 2007/08 financial year, the province spent approximately R 785.5 million with which they delivered in excess of 19,000 new housing units. However, despite the improved performance in housing delivery, it is estimated that the housing backlog currently stands in excess of 168,000 households in need of formal housing. According to the Northwest Province Growth and Development Strategy (PGDS), other challenges facing the province include the following:


The rural nature of the province;

The low population density and the resultant inadequate infrastructure, most notably in remote rural areas;

An enormous backlog in basic service delivery and maintenance;

A predominantly poor population with high levels of illiteracy and dependency that affects people’s productivity and ability to compete for jobs;

Inequalities between the rich and the poor, including disparities between urban and rural areas;

The HIV/AIDS prevalence rate; and

The availability of resources that is unevenly distributed, which means that it offers limited potential for improved service delivery and growth.

Of these challenges, employment creation and the eradication of poverty resulting from low levels of expertise and skills, are deemed to be the greatest challenges faced by the provincial government. These challenges are regarded as both immediate and long term challenges that require primary goals for sustained growth and economic development. The primary goals have been classified as follows:

The Economic Goal, which requires an average economic growth rate of at least 6.6% per annum to enable the province to halve the unemployment rate over a 10-year period. In order to achieve this, the investment required from both the private and public sector is estimated at around R 6.3 billion per annum; and

The Poverty Eradication Goal with the aim to clear the basic needs backlog. It is estimated that approximately R 854 million per annum would be required to achieve this goal.

The Bojanala District within the Northwest Province consists of five local municipalities, namely the:

Rustenburg Local Municipality (Rustenburg and surrounds);

Madibeng Local Municipality (Brits and surrounds);

Moses Kotane Local Municipality (Mogwase and surrounds);

Moretele Local Municipality (Makapanstad and surrounds); and

Kgetlengrivier Local Municipality (Koster and surrounds). Most of these municipalities are predominantly rural and this poses some serious challenges in terms of service delivery – especially to remote rural areas within the district. According to the District’s IDP (2007-2011), there are marked discrepancies between the services available to residents of urban areas versus their counterparts in rural areas, especially in terms of the provision of purified water and electricity. Mining plays a dominant role in the district’s economy and is also the biggest employer in the district. Mining activities are mostly concentrated along the Merensky Reef that stretches west of Pilanesberg, southwards through the Bafokeng area, parallel to the Magaliesberg, and eastwards towards Marikana and Brits. The presence of these mines has led to the creation of many supporting industries that manufacture supplementary products. Two of the world’s largest platinum mines are located in the district. Despite the intense mining activity taking place in the district, a large portion of its employees are migrant labourers from elsewhere in the country. Unemployment and the resultant high levels of poverty are therefore still rife in the district – especially in


the remote rural areas, which indicates the need for poverty alleviation programmes and similar interventions in the district. The district is also home to popular tourist destinations such as Sun City and the Pilanesberg Nature Reserve. The North West State of the Environment Report published by the Department of Agriculture, Conservation and Environment in 2002 identified the following main corridors for tourism development in the North West Province:

Hartebeespoort – Rustenburg – Sun City – Madikwe Game Reserve;

Hartebeespoort – Rustenburg – Zeerust – Mafikeng – Lehurutshe; and

Gauteng – Klerksdorp – Wolmaransstad – Bloemhof. Of the three identified corridors, two fall within the area of jurisdiction of the Bojanala District Municipality. The Ga-Rankuwa, Brits, Hartebeespoort and Rustenburg area is under severe pressure from industrial and mining activities; despite the fact that this area is one of the key tourism nodes of the province that should be sustained at all costs. The Magaliesberg Mountain Range is also found in this area and extends from the west of Rustenburg, southwards and then eastward towards Pretoria North - a distance of approximately 120 km. The Magaliesberg region was declared a protected natural environment in 1977.

6.3 Biophysical Environment

6.3.1 Location and Topography

Pelindaba is situated in the North-West Province, in the Brits Magisterial district, within the Madibeng Regional Council area. The site is approximately 27 km west of Pretoria, 37 km north of Johannesburg and 128 km northeast of Potchefstroom. It is located on the farm Weldada 567 JQ, which is 2 362 hectares in area and approximately 4 km southeast of the Hartebeespoort Dam. Pelindaba is situated on the ridges of the Skurweberg with its western boundary being the Crocodile River. As shown in Figure 8, the topography is relatively complex. Necsa is located along the northern slopes of the Skurweberg Mountain range. The height above mean sea level (AMSL) of the site is about 1290 m. The topography rises towards the south to a height of about 1500 m AMSL.


Figure 8: Major topographical features in a study area of 30 km by 30 km

6.3.2 Climate The annual rainfall decreases slightly from east to west. The eastern section of the Bankenveld around Pretoria receives an average of 686 mm whereas the Rustenburg area to the west has an average of 674 mm. The average of the area around Pelindaba receives 681 mm. Most of the rainfall occurs during thunderstorms between November and March. Seasonal rainfall for the period 2001 to 2010 is shown in Figure 8 below. In Pretoria, the average maximum temperature varies from 18.3° C in winter to 27.8° C in summer and the average minimum from 2.3° C in winter to 17.3° C in summer. The temperature in the Pelindaba area ranges from a mean daily minimum of 2.5° C in July to a mean daily maximum of 28° C in January.

6.3.3 Surface Hydrology and Rainfall Pelindaba is situated virtually on a watershed in the Moganwe River catchment area. Three seasonal streams follow the local valleys and flow north, where they join the Moganwe River. The Moganwe river flows west to the Crocodile River. The Crocodile River flows into the Hartebeespoort dam, approximately 5 km north-west of Pelindaba. To the west of the watershed, Pelindaba is drained by the Hennops River that also joins the Crocodile to the north-west.


Error! Reference source not found.Figure 9: Pelindaba Rainfall Figures (2000 - 2010)

6.3.4 Geology

(a) Regional Geology The Pelindaba area is underlain by rocks of the Transvaal Supergroup which display an accurate distribution around the Halfway House Granite dome. Well to the southwest of the Pelindaba area, on the western side of the granite dome, the Transvaal Supergroup overlies the Ventersdorp Supergroup and thrusted remnants of the c. 3 000-2 700 Ma Witwatersrand Supergroup. The basal member of the Transvaal Supergroup is the siliciclastic Black Reef Quartzite Formation (not present on site), which is conformably overlain by the predominantly chemo-sedimentary Malmani Subgroup and unconformably overlain by the volcano-sedimentary Pretoria Group successions. The area is characterized by quartzite ridges of the Klapperkop Quartzite Member within the Timeball Hill Formation and the valley to the north of Pelindaba is underlain by Hekpoort Formation andesite. To the north the intrusive rocks of the Bushveld Complex (also known as the Rustenburg Layered Suite) overlie the Transvaal Supergroup. The intrusive rocks, found on site, include syenite dykes and diabase sills. The sedimentation within the Transvaal Basin took place in a shallow marine, tidal environment that was controlled by cycles of extensional and/or thermal subsidence separated by stages of uplift or glacio-eustatic base-level fall (Catuneanu and Eriksson, 1999). Prior to the out-pouring of the Hekpoort Formation lava, Visser (1969) describes the Transvaal basin as consisting of two elongated basins with anticlinal ridges. After the volcanic event the basin coalesced into a single trough. The evolutionary history of the Transvaal Supergroup was terminated by the intrusion of the Bushveld Complex 2060 Ma ago.

(b) Local Geology The geology covering the Pelindaba site was conducted by Von Bacherström (1960). He also mapped some Bevets Conglomerate at the base of the Pretoria Series. All the other mapping was concerned with localised developments, which include foundation studies (Toens, 1971, Pike 1970) or disposal facilities or pollution studies. Levin et al (1986, 1987, 1993 and 1997) and Viviers (1997). As stated previously the major area of development at Pelindaba is located on interbedded slates and quartzites of the Timeball Hill formation of the Pretoria Group. Two of the four quartzite bands are magnetic and can be used as markerbands (Levin, 1987). These rocks are intruded by diabase sills and dykes as was found north of the Pelindaba East evaporation ponds (Levin, 1987). Faults and other structures associated with the Brits Graben (Jansen, 1977) were mapped and are responsible for the topographic features of the area (Levin, 1987). The main drainage lines on Pelindaba are structurally controlled and require effluent and environmental management.


6.3.5 Nearby Receptors There are a number of small communities in the neighbourhood living on small holdings and small farms. The farming activities include grazing and limited agriculture. These are mainly towards the west, north and east of the site. The communities to the south are located along the southern foothills, mainly along the Hennops River. There are also a number of residences along the Crocodile River to the west of Necsa. Larger residential developments are found along the banks of the Hartebeespoort Dam, towards the north Figure 10. The closest, Port d’Afrique,is located approximately 2.8 km and Meerhof approximately 4 km, north-northwest of the site. The towns of Ifafi, Schoemansville and Kosmos are approximately 5.5 km, 7.6 km and 9 km, north-northwest and west of the site, respectively. Pecanwood Estate lies about 6 km northwest of the site. Atteridgeville lies approximately 8.5 km east of Necsa, Gerhardville, approximately 9 km southeast, Copperleaf Golf Estate approximately 12.7 km southeast and Laudium about 16 km west southwest.

Figure 10: The study area of 30 km by 30 km with Necsa in the centre


6.3.6 Meteorology

The meteorological characteristics of a site describe the mechanisms which allow pollution to be transported, diluted and removed from the atmosphere. The extent to which pollution will accumulate or disperse in the atmosphere is dependent on the degree of thermal and mechanical turbulence within the earth's boundary layer (planetary boundary layer or PBL). Dispersion comprises vertical and horizontal components of motion. The stability of the atmosphere and the depth of the surface-mixing layer define the vertical component. The horizontal dispersion of pollution in the boundary layer is primarily a function of the wind field and atmospheric stability. The wind speed determines both the distance of downwind transport and the rate of dilution as a result of plume 'stretching'. The generation of mechanical turbulence is similarly a function of the wind speed, in combination with the surface roughness. Parameters that need to be taken into account in the characterisation of dispersion potential include wind speed, wind direction, extent of atmospheric turbulence, ambient air temperature and mixing depth. The study made reference to meteorological data from two surface metrological stations (Figure 11). The site is situated in the summer rainfall area with thunderstorm activity and warm to hot conditions during this period. The strongest winds tend to occur during August and September. The prevailing wind direction ranges from the northwest through north to the east with a southerly component that can be associated with cold fronts moving from the southwest through the interior of the country during winter.


Figure 11: Locations of the two weather masts on the Necsa site

6.3.7 Regional Vegetation The area falls within the Bankenveld Biome, being the transition between the Rocky Highveld Grassland (Grassland Biome) and the Mixed Bushveld (Savanna Biome). The vegetation consists of grass and trees, with the latter growing mainly in the valleys but also as sporadically developed clusters. Small deciduous and evergreen trees and groups of aloes are typical of the dolomite ridges and the suikerbos (Protea caffra) of the chert ridges. The Camdeboo stinkwood (Celtis kraussiana) grows mainly on the dolomite flats. On the acid soils developed along the quartzite ridges, the following species (amongst others) are common: stamvrug (Englerophytum magaliesmontanum), suikerbos (Protea caffra), white seringa (Burkea africana), bergpruim (Pappea fulva), moepel (Mimusops zeyheri), and locally on deeper soils, boekenhout (Faurea saligna) and wag-‘n-bietjie (Ziziphu mucronata). The kareeboom (Rhus lancea) and soetdooring (Acacia karroo) amongst others are found in the longitudinal valleys on the sweeter soils derived from the basic rocks and lavas.


6.4 Socio-Economic Environment

6.4.1 Baseline Geographical Processes

Geographical processes relate to land use patterns and infrastructure in the area. This section therefore describes the land use in the study area from a social perspective, specifically in terms of settlement patterns and land use developments. Land use in this regard is therefore defined as “…the way land is developed and used in terms of the types of activities allowed [zoned] (agriculture, residences, industries, etc.) and the size of buildings and structures permitted”.17 The proposed site is surrounded by a number (and great variety) of socially significant variables. In addition, the nature of the project might attract the interest and concerns of people from further afield than merely the immediate study area. For this reason several figures (in the form of satellite images) are presented below with an explanation and discussion for each of the images. Major settlements, as well as their respective orientations and distances from the site location are provided in the table below: Table 16: Approximate Distances from proposed site to Major Settlements

Area Orientation from Proposed Site Location

Approximate Distance From Proposed Site Location

Hartebeespoort West 6 km

Elandsfontein East 10 km

Atteridgeville East 14 km

Diepsloot South-South-East 17 km

Brits North-North-West 24 km

Centurion East-South-East 26 km

Pretoria (central) East 29 km

Midrand (central) South-East 29.5 km

Sandton (central) South-South-East 31 km

Krugersdorp (central) South-South-West 36 km

Johannesburg City Centre South-South-East 46 km

17

www.soil.ncsu.edu/publications/BMPs/glossary.html

http://www.google.co.uk/url?sa=X&start=1&oi=define&q=http://www.soil.ncsu.edu/publications/BMPs/glossary.html&usg=AFrqEzd6XjIqJOYyy_Jg86dJnvMb3RTL_g


Rustenburg East-North-East 71 km

This table allows insight into just how socially significant the surrounding areas are. Within a 50 km radius of the proposed site is Pretoria (the administrative capital city of South Africa), Diepsloot (the sprawling and densely populated township north of Johannesburg), the large urbanised areas of Midrand and Centurion, the Western Gauteng city of Krugersdorp, the urban and recreational area of Hartebeespoort, the medium settlement of Brits (the main seat of Madibeng) and finally Johannesburg, the “economic hub of Africa”. The following figures provide an overview of the preliminary social sensitivity of the proposed DIPR site and construction laydown area, within the context of the surrounding area. The social sensitivity map was developed based on a desktop study, using satellite imagery from Google Earth, and as such the map might not be all-inclusive - it is entirely possible that more areas of a social sensitive nature might be found and documented during the Impact Assessment phase. For the purposes of the scoping study, the social specialists endeavoured to identify socially sensitive areas such as residential areas (human settlement), scattered households, commercial/industrial areas, irrigated farmlands, etc. The project site (that is both the DIPR site and the construction laydown area) has been taken as the centre point of the map. From this point the study area was divided into three radii: 1) 0-2 km from the project site; 2) 2-5 km from the project site; and 3) 5-10 km from the project site (refer to Figure 12). As previously stated, the argument is that the sensitivity of social receptors will decrease the further away they are located from the site. Depending on the issues raised during the public participation process and the availability of more technical and safety information from the project proponent, these radii might have to be extended (or reduced) during the detailed impact assessment phase, but for the purposes of the scoping report they have been used as a general guideline to identify preliminary/possible social sensitive receptors.


Figure 12: Overview Map of Radii The land use within each of these segments or radii has been illustrated and discussed below.

Figure 13: Social Sensitivity within the 2 km Radius

0-2km

0-2km

2-5km

5-10km

Project Site


Figure 13 refers: Within the 2 km radius there is Pelindaba itself and a number of scattered infrastructures, which appears to be mostly houses. Approximately 250 m west of the project site there is a cluster of houses, which are located within the Necsa premises and are use as staff accommodation. The bulk of the land in this sector is void of structures and is zoned as ”Nature Orientated Country Living” (“Hartbeespoortdam structure plan’ – 1995)

Figure 14: Social Sensitivity within the 5 km Radius Figure 14 refers: Approximately 4 km northwest of the project site lies the densely populated residential area Meerhof and just to the south of Meerhof lies Port d’ Afrique. A portion of the Xanadu Eco-Park falls within the 2-5 km radius, which lies directly north of the project site. This section is furthermore characterised by a number of agricultural holdings, both to the west and east of the project site. Large portions of the surrounding area are open vacant land with quite a large number of scattered houses, lodges, and smallholdings, all of which appear to loosely follow roads and rivers. A portion of the Necsa Pelindaba complex intrudes into the 5 km radius and forms part of many industrial complexes (both light and heavy industry) particularly in the North and East of the radius. Again it is likely that large segments of land within this radius would be zoned as agricultural land.


Figure 15: Social Sensitivity within the 10 km Radius Figure 15 refers: The 10 km radius encompasses a diversity of land uses. In the north-western segment is the Hartebeespoort dam with a number of associated tourist and leisure spots (i.e. jetties; hotels; golf courses; lodges). In this area there are also a number of residential and urbanised land uses, particularly Kosmos; Pecanwood Estate; Ifafi; Hartebeespoort Town; Schoemansville; Flora Park; Melodie; Xanadu Eco-Park; The Island Estate and surrounds. In the western segment are an array of smallholdings and semi-densely arranged houses built around agricultural land. It also appears as if this area contains some heavy industrial activity, the nature of which, at this time, is unknown. The southern sections are less densely populated and do not appear to have any formally urbanised areas. Rather, there are many semi-densely populated areas, scattered portions of agricultural land and what would appear to be a multitude of leisure/holiday homes built along the river banks. In addition the southern section contains several smaller, but unique, social land uses such as two very small airstrips; bird hides; look out points; and light industry. The transient population within the area can at times also increase over weekends and holidays due to the area as a popular tourism destination. Taken as a whole, the overall preliminary social sensitivity map of the surrounding area in relation to the project site is depicted in Figure 16 below.


Figure 16: Overall Preliminary Social Sensitivity Map

6.4.2 Baseline Demographical Processes Demographical processes relate to the number of people and the composition of the community, and include variables such as the population size, their race, age, gender and educational profile. For the purpose of the scoping study the profile centred on the Madibeng Local Municipality, even though some of the sensitive receptors identified are located within the City of Tshwane. This was done as the project sites are located in Madibeng – if it becomes evident that the City of Tshwane has to be included in the study this will be done in the impact assessment phase.

(a) Population Size and Growth

In terms of population size and growth, Madibeng, Bojanala, and the North West Province have all shown population increases in the 6-year period from 2001 to 2007. Both the district and the local municipality showed steady population increases of approximately 1.1% on average per annum, while the provincial growth was somewhat lower at an average of 0.4% per annum. The population density in Madibeng is very high when compared to the district and province – a possible reason for this might be the municipality’s close proximity to economic activity in neighbouring City of Tshwane while offering its residents a more affordable way of life.


Table 17: Population Size and Growth in MLM, BPDM, and North West Province

Area 2001 Population

2007 Population

Annual Average %

Change

Population Density (2007)

Madibeng 346 675 371 197 1.1% 97.4 / km2

Bojanala 1 188 457 1 268 618 1.1% 69.2 / km2

Northwest 3 193 676 3 271 948 0.4% 31.2 / km2

Sources: Census 2001 & CS 2007

The indication above of the numbers of people living in these areas is not of any use without insight into the nature of these populations. The subsections that follow provide brief but concise profiles pertaining to race, age and gender, language groups, and education levels in the local areas.

(b) Race, Gender and Age

By 2007, the gender split in Madibeng was nominal, with 50.5% of the population being male and 49.5% female. It is evident that there may be very few external factors at play affecting/forcing one or other gender to be present in greater proportions. Black African is the predominant racial group in the area followed by the White population. Both of these racial groups showed very little variation in their growth during the years between 2001 and 2007.


Figure 17: Racial profile in Madibeng, 2001 versus 2007 The age profiles for Madibeng in 2001 and 2007 show that there has been very little change for those aged 40 and above. It is the decline in numbers of people aged 5 to 15 and 30 to 40 by 2007 which shows the greatest disparity. This may indicate the


presence of disease (e.g. HIV/AIDS) or perhaps of migrant tendencies for those aged 30 to 40 who in turn leave with their children aged 5 to 15.

Figure 18: Age Profile in Madibeng, 2001 vs. 2007

(c) Households and Housing The number of households in all three areas showed increases between 2001 and 2007 with Madibeng making up for 29.6% of all district housing numbers by 2007, although it did show the lowest proportional increase in this period. Table 18: Households

Area 2001 2007 Growth/Decline in Numbers

Average number of

persons per household

(2007)

Madibeng 95 244 96 361 +1 117 3.8

Bojanala 324 335 357 201 +32 866 3.4

North West 816 643 911 120 +94 477 3.5

Of concern for the North West, Bojanala, and Madibeng is the slow rate of housing delivery. In all three areas very few differences can be seen between 2001 and 2007 regarding the proportion of formal housing. In fact only Bojanala has shown an increase in housing and even this increase only stands at 2.6%. By 2007, 37.5% of Madibeng’s homes were still informal.


Table 19: Housing

Area % Formal 2001

% informal 2001

% formal 2007

% informal 2007

Madibeng 61.2% 35.2% 57.2% 37.0%

Bojanala 65.8% 30.3% 59.2% 33.2%

North West 71.7% 23.4% 66.5% 23.8%

(d) Language Groups

The Census of 2001 provides the most comprehensive information in terms of language group profiles. The widely spoken home language is Setswana by a significant margin in all three regions. In Madibeng specifically, more than half of the population speak Setswana as their home language (52.2%), followed by Xitsonga (9.2%), then Sepedi (8.8%), and then Afrikaans (8%) with various other language groups making up a small proportion of the entire profile. The table below summarises all of these language groups for the three regions under consideration. Table 20: Language group breakdown for MLM, BPDM, and the North West

Language Madibeng Bojanala Northwest

Afrikaans 8.0% 6.6% 9.2%

English 1.3% 1.4% 1.4%

IsiNdebele 1.8% 1.3% 0.6%

IsiXhosa 4.0% 5.4% 7.6%

IsiZulu 4.7% 3.1% 2.1%

Sepedi 8.8% 5.8% 2.5%

Sesotho 6.8% 4.0% 6.8%

Setswana 52.2% 62.4% 64.8%

SiSwati 1.0% 0.7% 0.6%

Tshivenda 1.4% 0.8% 0.4%

Xitsonga 9.2% 7.6% 3.4%

Other 0.8% 0.8% 0.7%

Source: Census 2001


(e) Education Profile In Madibeng the education levels remain somewhat low with only 32.7% of all persons having completed high school by 2007 and 11% having had no exposure to the education system whatsoever. Between 2001 and 2007 there have been several positive trends indicating an increase in general education levels. By 2007 fewer people had no exposure to education, while more had completed basic education and almost twice as many had attained tertiary qualifications (certificates, diplomas, and degrees).


Figure 19: Highest level of educational achievement in MLM, 2001 vs. 2007 If one accounts only for the more recent 2007 statistics and compares the municipal area, district, and province, then certain differences can be observed. The three profiles are largely similar, except that the district had a lesser proportion of people with no exposure to education and more individuals with tertiary qualifications, although Madibeng showed a greater proportion of people with matriculation certificates. Overall it seems that Madibeng has an education profile slightly superior to provincial standards but somewhat inferior to district standards.


Source: CS 2007

Figure 20: Highest level of educational attainment by municipality, district and province in 2007

6.4.3 Baseline Economic Profile

The local economic profile was based on employment status, major economic sectors locally, income levels, and social grants accessed by local people. Beginning with employment characteristics, Madibeng showed increases in the proportion of employed persons between 2001 and 2007, including a small reduction in the proportion of economically inactive people. Overall these figures are better than the provincial standard but slightly behind the district standard. In addition, employment is an area of concern for Madibeng since the current dependency ratio (that is the ratio of earners to non-earners) is 1.23. This means that for every salary earner, on average, 1.23 persons depended on him/her to sustain their livelihood. Table 21: Employment status of persons in MLM, BPDM, and North West in

2001 and 2007

Employment Status

2001 - MLM

2007 - MLM

2001 - BPDM

2007 - BPDM

2001 – North West

2007 – North West

Employed 38.0% 43.9% 36.6% 43.4% 33.8% 38.5%

Unemployed 27.4% 22.2% 25.3% 22.1% 23.8% 20.9%

Not Economically Active 34.6% 33.9% 38.1% 34.6% 42.4% 40.6%



Of the 43.9% of people employed in 2007, the majority were employed in mining and quarrying (25.7%), followed by community, social and personal services (15.9%), and then wholesale and retail trade (13.5%). A summary of all employment sectors in 2007 is provided by the figure below:

Source: CS 2007

Figure 21: Major Sectors of Economic Employment in MLM – 2007 Tying in directly with industries of employment are the skills levels of the local people. Also of significance is the relationship between education levels, skills levels, occupation, and income. Nonetheless, the figure below provides an indication of occupations held by employed people in Madibeng in 2007. It shows that the majority of employed people (20%) are involved in elementary occupations, followed by craft and trade workers (16.1%), plant and machine operators and assemblers (15.3%), and various specified and unspecified occupations.


Source: CS 2007 Figure 22: Occupations in MLM, 2007 Of equal significance are the actual earnings per person in the region in 2007. Having shown that the dependency ratio is moderately high it is important to show how abundant financial resources are required as support for many people appears to be necessary. Below is a profile of monthly income for Madibeng juxtaposed against Bojanala’s income profile for contextual value.

Source: CS 2007

Figure 23: Monthly income per person in MLM & BPDM for those aged 15 - 65 (2007)


It is apparent that both Madibeng and Bojanala have similar proportions of people between 15 and 65 who have no discernible income, but disparities are evident in the fact that Madibeng has higher proportions of people in the lowest income increments. Overall, the highest income categories are almost barren for both regions; there is a high proportion of non-earners, and a large proportion of people in the lower income categories indicating the possibility of poverty and economic upheaval locally. This statement may be viewed against household income statistics from Census 2001 (below). In 2001 (not directly comparable to 2007 but noteworthy nonetheless), 23.3% of all households had no annual income and a further 69.6% of all households earned less than R19 200 per annum (R1600 per month is the minimum RDP standard). All annual household income categories from 2001 for Madibeng are listed below. Table 22: Annual Household Income in Madibeng (2001)

Income Category Proportion of households

No income 23.3%

R1 - R4 800 8.3%

R4 801 - R 9 600 19.0%

R9 601 - R 19 200 19.0%

R19 201 - R 38 400 16.8%

R38 401 - R 76 800 7.5%

R76 801 - R153 600 3.6%

R153 601 - R307 200 1.7%

R307 201 - R614 400 0.5%

R614 401 - R1 228 800 0.1%

R1 228 801 - R2 457 600 0.2%

R2 457 601 and more 0.1%

Source: Census 2001

The statistics in the graphs above paint a generally bleak picture as regards the economic situation of people in MLM. This further necessitates the availability of social grants to those who qualify for them and who require them. The table below shows the proportion of the population accessing social grant facilities in 2007 as well as the nature of the grants available (the most popular of which is the child support grant).


Table 23: Proportion of population accessing social grants in MLM, 2007

Type of Grant Proportion of Population

Not Applicable 78.70%

Old age pension 5.30%

Disability grant 2.10%

Child support grant 13.30%

Care dependency grant 0.30%

Foster care grant 0.10%

Grant in aid 0.20%

Social relief 0%

Multiple social grants 0.10%

Source: CS 2007

(a) Municipal Services Profile

The table below outlines the major municipal services, i.e. primary energy source used for cooking, heating, and lighting, as well as the status of refuse removal, sanitation facilities, and water access in terms of RDP requirements. Please note that national service delivery statistics were unavailable. Table 24: Municipal service delivery in MLM, BPDM, and the North-West

South Africa

North West

Bojanala District Madibeng Local

2007 2001 2007 2001 2007

Energy Cooking

- Electricity (65.8%)

Non- Electricity (52.3%)

Electricity (68.8%)

Non-Electrical (53.4%)

Electricity (71.2%)

Energy Heating


Electricity (49.9%)

Electricity (64%)

Non-electrical (54.8%)

Electricity (61.8%)

Energy Lighting


Electricity (74.4%)

Electricity (83.9%)

Electricity (69.8%)

Electricity (85.8%)

Refuse - Removed once a week (52.6%)

Own refuse dump (62.3%)

Removed once a week (54.1%)




South Africa

North West

Bojanala District Madibeng Local

2007 2001 2007 2001 2007

Sanitation - Equal or above RDP standard (45.4%)

Equal or above RDP standard (38.6%)




Water - Equal or above RDP standard (45.4%)


Equal or above RDP standard (90%)




What is evident from the above table is the fact that generalised improvements can be seen across all 6 areas of focus above. The areas requiring particular attention though are sanitation and refuse removal.

(b) Crime Profile Bojanala and Madibeng both cover large areas of land and contain settlements which may not necessarily be of significance to the crime profile for the study area. For this reason, statistics from the Hartebeespoort police station have been extracted and interpreted in order to provide a crime profile for the urbanised areas surrounding the proposed project site. Table 25: Crime profile in the Hartebeespoort area

Crime in Hartebeespoort No of Crimes reported between 2003 and 2011

Relevant Trend

Contact Crimes

Murder 61 Relatively stable

Sexual Crimes 312 Relatively stable

Attempted Murder 171 Erratic

Assault-attempt to do grievous bodily harm

1 170 Recent Increase

Common Assault 1 614 Relatively stable

Common Robbery 425 Decreasing

Robbery with Aggravating Circumstances

857 Erratic

Contact-related Crime


Arson 75 Erratic

Malicious damage to property 1 200 Increasing

Property-related Crime

Burglary 897 Increase

Theft of Motor Vehicle 5 682 Relatively stable

Stock Theft 80 Increase

Crime heavily dependent on police action for detection

Illegal possession of fire arms and ammunition

76 Relatively stable

Drug-related crime 341 Increase

Driving under the influence of alcohol/drugs

189 Relatively stable

Other serious crime

Other theft 4 972 Decrease

Commercial Crime 667 Increase

Shoplifting 214 Erratic

Subcategories of aggravated robbery

Hijacking 82 Relatively stable

Robbery at residential Premises 209 Increasing

Robbery at non-residential premises 82 Increasing

Other crimes

Culpable homicide 143 Increasing

Public violence 5 Erratic

Crimen injuria 226 Relatively stable

Neglect and ill-treatment of children 21 Erratic

Kidnapping 11 Erratic

Source: Crime Research & Statistics – South African Police Services


(c) Social Infrastructure The tables below provide a brief overview of the social infrastructure in the Hartebeespoort area and surrounds as the area closest to the project site. Table 26: Healthcare Facilities in Hartebeespoort Dam

Facility Numbers

Hospitals 0

Healthcare Clinics – Vrederus Kliniek; Hartebeespoort Medical Centre; Madibeng Clinic.

3

Table 27: Emergency, Safety and Security Infrastructure

Type Number Description

Fire Brigade 1 Necsa Fire Brigade

Police Stations & Prisons 1 Police Station; 0 correctional facilities.

SAPS Hartebeespoort

Traffic Police None Nearest traffic department - Brits

*The Necsa complex currently has its own emergency staff to respond to medical emergencies, fires, and security issues.

Unknown Located within the Necsa Pelindaba facility.

4.1.1 Baseline Socio-Cultural Processes

Socio-cultural processes relate to the way in which humans behave, interact and relate to each other and their environment, as well as the belief and value systems which guide these interactions.

(a) Historical Overview

Hartebeespoort General Hendrik Schoeman was the original owner of the farm Hartebeespoort and in 1896 he decided that the community could benefit from the construction of a dam. He built a dam on the Crocodile River and named it Sophiadam, after his wife. It cost him 10 000 Pounds to build and was then the largest dam in the Southern Hemisphere. The new dam wall as it is today took some time to build due to various extraneous factors but by 1918 farms were divided up for residential purposes and the wall built. In 1921 it was washed away by torrential rains and the engineer F.W. Scott was called in to re-construct the wall in 1923.


Schoemansville Schoemansville, named after General Hendrik Schoeman, developed alongside the urbanisation of farmlands and greenfields areas after the construction of the dam. The area flourished due to the availability of irrigation, its location between Johannesburg and Rustenburg (and later Sun City), and the recreational attractions associated with the dam. Today a wide variety of Golf courses, water sports, and cultural attractions are on offer in addition to the presence of farms, smallholdings, houses, and high end housing estates. Pelindaba Soon after World War II South Africa began its nuclear energy programme when Uranium deposits were discovered in the country. The project initially began without any military ambitions and in 1965 the U.S. firm Allis Chalmers supplied South Africa with the 20MW Safari 1 reactor as well as highly enriched uranium to fuel it.

(b) The Local Community According to Census 2001 and the more recent Community Survey 2007 the main groups of people in the municipal area are Black/African people (91.4%) who are mostly Setswana speakers. The Tswana are a tribe who migrated from East Africa in the 14th century. Tswana history is filled with dissension and splintering and today around 59 different groups in South Africa hold the overall name of Tswana. The Tswana are closely related to the Sotho (of Lesotho and South Africa). The Sotho-Tswana are bonded in language and customs. They claim a common ancestor, Mogale. They share an agrarian culture, social structures, political organization, religious and magical beliefs and also a family life. All the Sotho and Tswana languages are inherently intelligible, but for political and historical reasons, they have generally been considered as three languages. The larger sub-tribes are often considered as separate tribes with their separate languages. Traditional Tswana society included men, women, children and "badimo" (ancestors, living dead, having metaphysical powers). A Tswana does not think in terms of individual rights, but of responsibilities to his family and tribe. The father is to be obeyed and respected by his wife and children at all times. The Sotho-Tswana are organized by lineages, which developed as the tribe grew. The lineages are organized in subunits and communities. Every level exhibits the same social organization, such as the Kgotla, the traditional court, with various officials assigned various duties in the social structure at each level. In traditional Tswana religion (tribal animism) "Modimo" is the great God, or "The Great Spirit." Because of the fact that job availability in Botswana is changing from rural to urban, many Tswanas are leaving the villages and not returning. Thus the Tswana are fast becoming a modern secular society, in Botswana as well as South Africa.

6.5 Heritage Resources

This information was obtained from the Heritage Impact Study (Appendix D).


6.5.1 Stone Age

A large number of well-known sites containing hominid fossils are known to occur in the Cradle of Humankind area. These sites occur some distance to the west of the study area. Stone Age tools associated with the Early and Middle Stone Age are common, especially along the spruits and rivers where they cut through ridges and at the lower parts of the ridges and larger outcrops. These are viewed as find spots rather than sites per sé. That means that as most of these are surface finds, they are viewed to be out of context and do not have any significance. Only a few stratified sites are known in the Magaliesberg range, but even these have little significance as the deposits have either eroded away, or have been impacted upon by later occupants of the shelters.

6.5.2 Iron Age Although the Early Iron Age dates back to c. AD 200, such sites are not known from the larger region. The closest one is the famous Broederstroom site locate to the south of Hartebeespoort dam in North West Province. Sites dating to the Late Iron Age are found all over the larger region. These can be related to the Tswana-speakers that occupied the region since the early 1600. Iron Age sites dating to the Late Iron Age abound in the study area. They are all stonewalled and each site probably made up one individual settlement unit.

6.5.3 Historical period Early white farmers selected farms and then provided a description of the farm to the local landdrost, who noted the detail in a registration book and gave the claimant a copy. Claimed land was then inspected before a title and deed were issued. Since the registration of land entailed registration costs and annual land taxes, it was often delayed as long as possible. As a result, the registration of land claimed on the basis of burgher rights continued well into the 1890s. This was also the area over which the British troops advanced during the 2nd Anglo-Boer War, and some skirmishes took place in the larger region. In order to prevent the Boer forces freedom of movement, a system of block houses were built, some of which are located on the farm Kalkheuwel (Van Vollenhoven & Van den Bos, 1997).


7 POTENTIAL ISSUES AND IMPACTS

In terms of Regulation 29 of the EIA Regulations which describes the contents of a Scoping Report, sub-regulation (f) states that the Scoping report must contain “a description of environmental issues and potential impacts, including cumulative impacts, that have been identified.” The purpose of this chapter is, therefore, to provide a brief description of both the potential positive and negative environmental impacts which could occur as a result of the proposed development of the DIPR and associated infrastructure. The chapter does not attempt to assess, rank in terms of significance or mitigate any of the identified impacts or issues, positive or negative. The Plan of Study described in Chapter 9 describes the methodology by which the impacts will be assessed in the Impact Assessment Phase. Although not assessing impacts, this chapter will identify those consolidated issues which are known at this stage to be significant and require specialist input and investigations, either to research and understand the impact/issues, and/or to determine their significance. The impacts associated with activities during construction are usually short lived and mitigated in a Draft Environmnetal Management Programme (EMP), included in the Draft EIR. Once approved, the EMP will be implemented on-site and enforced by regular monitoring, with submission of audit reports to the DEA Compliance Department. As a living document, the EMP can be modified, with approval from the DEA, to suit the conditions, constraints and practicalities of the construction once it has begun. The EMP will furthermore address mitigation measures required for the operational phase of the DIPR and associated infrastructure. Due to the life excpectancy of the DIPR, it is anticipiated that the decommissioning activities will have to be addressed at a later stage and take into account the environment when decommissioning is to be undertaken. It is expected that additional impacts and issues will be identified during the public review process and the Impact Assessment Phase. These will be highlighted, described and assessed as per all other impacts in the Impact Assessment Phase.

7.1 Ecology

From an ecology perspective, the following potential impacts have been identified and will be determined during the EIA phase of the project:

Loss or fragmentation of indigenous natural vegetation. Construction of infrastructure may lead to direct loss of vegetation. This will lead to localised or more extensive reduction in the overall extent of vegetation. Where this vegetation has already been stressed due to degradation and transformation at a regional level, the loss may lead to increased vulnerability (susceptibility to future damage) of the habitat. Some vegetation types that have suffered regionally high levels of transformation are listed in the Draft Ecosystem List and are protected according to the National Environmental Management: Biodiversity Act.


Loss of habitat or individuals of threatened animals. Loss of a population or individuals could lead to a direct change in the conservation status of the species. This may arise if the proposed infrastructure is located where it will impact on such individuals or populations or the habitat that they depend on.

Loss of populations of threatened plants. Plant species are especially vulnerable to infrastructure development due to the fact that they cannot move out of the path of the construction activities, but are also affected by overall loss of habitat. Loss of a population or individuals could lead to a direct change in the conservation status of the species, possibly extinction. This may arise if the proposed infrastructure is located where it will impact on such individuals or populations. Consequences may include fragmentation of populations of affected species, reduction in area of occupancy of affected species and loss of genetic variation within affected species.

Loss of individuals of protected tree species. In terms of section1 5(1) of the National Forests Act, 1998 “no person may cut, disturb, damage or destroy any protected tree or possess, collect, remove, transport, export, purchase, sell donate or in any other manner acquire or dispose of any protected tree or any forest product derived from a protected tree, except under a license granted by the Minister to an applicant and subject to such period and conditions as may be stipulated”.

Damage to wetlands. Construction may lead to some direct or indirect loss of or damage to seasonal marsh wetlands or drainage lines or impacts that affect the catchment of these wetlands. This will lead to localised loss of wetland habitat and may lead to downstream impacts that affect a greater extent of wetlands or impact on wetland function.

Establishment and spread of declared weeds and alien invader plants. Exotic species are often more prominent near infrastructural disturbances than further away. Consequences of invasion may include further loss of indigenous vegetation, change in vegetation structure leading to change in various habitat characteristics, change in plant species composition, change in soil chemical properties, loss of sensitive habitats, loss or disturbance to individuals of rare, endangered, endemic and/or protected species, fragmentation of sensitive habitats, change in flammability of vegetation, depending on alien species, hydrological impacts due to increased transpiration and runoff and impairment of wetland function.

7.2 Air Quality Although it is anticipated that the atmospheric releases of both conventional air pollutants and radionuclides would occur, the former is only expected to occur during construction and decommissioning. Radionuclide emissions are expected to occur during operation and possibly during decommissioning. Air releases may be associated with routine emissions, upset and emergency emissions or accidental releases. However, the assessment is confined to routine and upset emissions only. More severe, accidental releases would be included as part of a quantitative risk assessment. All air releases will be reported to the National Nuclear Regulator (NNR), who determine the allowable levels of emissions.


7.2.1 Dedicated Isotope Production Reactor

From the historical records of emissions from SAFARI-1, it is expected that there may potentially be emissions of alphas, betas, iodine, tritium and noble gases, such as krypton and xenon. Once released to the atmosphere, air pollutants and radionuclides undergo downwind transport (advection) and mixing (diffusion). These may be removed from the atmosphere by both wet and dry deposition onto the ground or a water body. Radionuclides would contribute concentrations on the ground and in the water. In addition to deposition, radionuclides will undergo radioactive decay. The temporal and spatial distribution of radionuclide concentrations in the air, water or on the ground, as well as in the applicable terrestrial and aquatic food chains, may result in radiation exposure to human beings, through various pathways, potentially contributing to a human health impact. These impacts are a function of the radionuclide concentration in the air, water or on the ground as well as the human behavioural characteristics of the exposure group. The air quality impact is confined to the contribution of the atmospheric pathway to human health impact from the proposed DIPR. If possible, emission norms provided by all the vendors considered for the DIPR, would be used to develop an envelope of potential emissions. This approach would ensure that the impact of any of the potential vendors would be included in the assessment. In the event that this information is unavailable, the radionuclide emissions would be based on observations of the existing SAFARI-1. Emission releases from normal operations and design basis accident conditions must comply to the acceptance criteria specific in Regulations 388 of the National Nuclear Regulator Act. If the applicant is unable to demonstrate adherence to these criteria, a license to site, construct, operate or decomission a facility will not be granted.

7.2.2 Associated Infrastructure and Laydown Area Conventional air quality impacts of the proposed DIPR project are expected to occur during the construction stage. Only non-radioactive emissions, associated with the DIPR project would occur during the construction period, whereas radionuclide emissions within statutory criteria may additionally be associated with the other operations at Necsa. Air emissions during construction include airborne particulates and gaseous emissions. However, airborne particulates are considered to potentially result in significantly higher impact than the gaseous pollutants. This could be both as inhalable air concentrations and dust levels. An accurate calculation of emissions during the construction period is generally not possible due to the requirement for detailed information, which only becomes available at the final stages of the project. However, typical construction activities, such as scraping, excavation, loading, offloading and haulage are all potential sources for causing dust and combustion fuel exhaust emissions from heavy vehicles. Wind erosion of exposed surfaces such as topsoil storage piles and open construction areas are also potential sources. The limitations that could be encountered with the quantification of construction phase dust and combusion fuel exhaust emissions from heavy vehicles include sufficient construction activity detail, exact locations and timing of construction activities, soil


characteristics (particularly the silt content, i.e. particle sizes less than 75 micron), number and types of construction vehicles. In the event that of insufficient detail at the time of the comprehensive impact assessment, area-wise emission factors would be applied. These are generally regarded to be conservative estimates.

7.3 Social Impacts

As with the baseline profile, there will be no difference in the potential social impacts associated with the proposed DIPR and construction laydown area and therefore the sites have been grouped together for the purposes of the social specialist study and will be referred to as the project site.

7.3.1 Dedicated Isotope Production Reactor and Construction Laydown Area (a) Geographical Change Processes and Potential Impacts

The identification of geographical (land use) change process from a social perspective looks at how the presence of the proposed project site might change the behaviour/lives of land owners and/or land users in the surrounding area. This is done by considering actual or perceived land use changes, whether on a temporary or permanent basis. The geographical change processes and potential impacts are summarised as per Table 28 below. Table 28: Geographical Change Processes and Potential Impacts

ISSUE Geographical Change Processes

Discussion The vacant land in the Pelindaba site on which the proposed DIPR will be located will permanently change to host the reactor. The construction laydown area will only change temporarily for the duration of the construction phase. If a construction camp is used, it is likely that it will not be located within Pelindaba’s borders due to security measures. It would therefore have to be located elsewhere in close vicinity of the project site.

Existing Impact The DIPR project site is located within Pelindaba. The land use of the directly surrounding the sites is therefore of a similar nature as described in Chapter 6.

Potential Impact The impact on land use largely depends on the current land use. Although it is not foreseen that the project site would lead to a drastic land use change within Pelindaba itself (as it would blend in with the rest of the activities), the location of the construction camp might lead to a temporary change in land use. If, for example, the construction camp would be located outside Pelindaba but still in close proximity to the site, this could potentially lead to a temporary change in land use. The impact would largely depend on the current land use and on land ownership.


ISSUE Geographical Change Processes

Cumulative Effect Construction waste water potentially generated from the project that is not properly managed can seep into the ground and affect the quality of the soil, which could lead to a permanent change in the way the land can be used.

(b) Demographical Change Processes and Potential Impacts

The construction and operation of the proposed DIPR and associated infrastructure can lead to a change in the number and composition of the population within the affected local area, which in turn could lead to economic, land use, and socio-cultural change processes. The demographical change processes and potential impacts are summarised as per Table 29 below. Table 29: Demographical Change Processes and Potential Impacts

ISSUE Demographical Change Processes

Discussion The proposed development will lead to an increase of a certain section of the population, i.e. an influx of migratory workers into the proposed study area in the form of the construction team.

Existing Impact As per Community Survey 2007, the current total population within Madibeng stands at 371 183 people, with an average annual growth rate estimated at around 1.1%. Of the economically active population, 33.5% are unemployed (CS, 2007).

Potential Impact A change in the number and composition of the inhabitants in the local area can lead to economic, health, safety and social-wellbeing impacts.

Cumulative Effect The presence of the construction team and the prospect of employment could also lead to an influx of unemployed jobseekers.

(c) Economic Change Processes and Potential Impacts

Economic change processes relate to the changes brought about to the employment and general economic profile of the local area as a result of the introduction of any development. For example, job opportunities might be created as a result of the construction and operation of the proposed DIPR. Employment creates a source of income, which in turn enables the employed individual to access services as a support mechanism for his/her family. The economic change processes and expected impacts are summarised as per Table 28 below.


Table 30: Economic Change Processes and Potential Impacts

ISSUE Economical Change Processes

Discussion The proposed development can enhance economic opportunities for vulnerable communities by creating and affording job opportunities to local community members. However, it is not foreseen that such opportunities would be sustainable as most of the jobs will be restricted to the construction phase.

During the construction phase, it is likely that the local area will experience economic injections due to the activities on the project, and this will result in increased business and consumer spending.

Existing Impact As one of the largest corporations in Madibeng, Necsa can possibly be regarded as one of the biggest employers in Madibeng and more so in the more immediate area surrounding Pelindaba. Its activities probably also creates a large revenue stream for the local municipality in terms of services and taxation. Bearing this in mind it would appear that Necsa currently has a positive economic impact on the local area.

Potential Impact 1. The likelihood of a positive economic impact on local individuals who are employed during the construction phase.

2. Increase in disposable income and business earning, thus resulting in business and consumer spending.

3. Increased revenues from taxation and provision of services and utilities.

Cumulative Effect Employment creates a source of income for an individual, which also brings economic relief to the potentially poverty stricken family from which the individual comes from.

If training takes place as part of the project, skills will be uplifted, making individuals more employable, hence possibly creating a more sustainable source of income.

(d) Institutional and Legal Change Processes and Potential Impacts

Institutional and Legal Change Processes assesses the way in which a development of this nature could change the face of service delivery in the affected area and how this change in turn could affect the quality of life of local residents. The institutional and legal change processes and expected impacts are summarised as per Table 29 below.


Table 31: Institutional and Legal Change Processes and Potential Impacts

ISSUE Institutional and Legal Change Processes

Discussion A larger number of people can affect the quality of municipal and other social services, e.g. an influx of ‘strangers’ can increase the crime rate, placing a higher strain on the police services.

Existing Impact The existing baseline municipal profile suggests that most of the basic municipal services are adequately supplied throughout the area. The quality of services might diminish towards the more rural areas and in informal settlements.

Potential Impact Additional demand on municipal services, such as water, sewerage and roads could impact on health and safety if such services are not available. An influx of unemployed job seekers can lead to the development of informal settlements. This can impact on health (as services are not provided or further taxed) and safety (an increase in crime is possible as people do not find employment and become frustrated with their living conditions).

Cumulative Effect None expected at this stage.

(e) Socio-Cultural Change Processes and Potential Impacts

As socio-cultural processes recount the way in which humans behave, interact, and relate to each other and their environment, socio-cultural change processes in turn looks at the way in which the proposed developments can alter the interactions and relationships within the local community. The socio-cultural change processes and expected impacts are summarised as per Table 32 below. Table 32: Socio-Cultural Change Processes and Potential Impacts

ISSUE Socio-Cultural Change Processes

Discussion It’s a given that culture powerfully influences thoughts, emotions and behaviours. It is for these and other reasons that intercultural interactions can cause anxiety and arouses emotions. When people of different cultures meet there can be uncertainty and confusion about the rules of interaction, which can lead to conflict, amongst others.

Apart from human interaction, socio-cultural change processes also assesses the sense of place of the project site.

Existing Impact At the time of the study the social specialist was unaware of any pertinent conflict situations between the neighbouring residents and Necsa, but due to the nature of the corporation’s business the possibility of existing conflict situations does exist.


ISSUE Socio-Cultural Change Processes

In terms of sense of place, the project site is located within Pelindaba’s existing boundaries and that forms part of Necsa’s property. As Pelindaba has a long-standing presence in the area, it is likely that by now it forms part of the visual landscape of the area and those local residents are accustomed to its presence.

Potential Impact Cultural clashes can occur where people are brought into the area from elsewhere. Apart from conflict situations, the rules of interaction can be blurred, impacting on family and cultural cohesiveness, and health and safety.

At this stage it is not foreseen that the presence of the proposed DIPR would impact on local residents’ sense of place, but this assumption would have to be tested during the EIA phase.

Cumulative Effect None expected at this stage.

7.4 Heritage Impacts

Impact analysis of cultural heritage resources under threat of the proposed development, are based on the present understanding of the development.

No sites, features or objects of cultural heritage significance were identified in the study area.

7.4.1 Dedicated Isotope Production Reactor Location

Stone Age No sites, features or objects dating to the Stone Age were identified in the study area.

Iron Age No sites, features or object dating to the Iron Age were identified in the study area.

Historic period No sites, features or object dating to the historic period were identified in the study area.

7.4.2 Associated Infrastructure and Laydown Area

Stone Age No sites, features or objects dating to the Stone Age were identified in the study area.

Iron Age


No sites, features or object dating to the Iron Age were identified in the study area.

Historic period No sites, features or object dating to the historic period were identified in the study area.

From a heritage point of view it is recommended that the proposed development be allowed to continue. It is requested that should archaeological sites or graves be exposed during construction work, construction will be stopped immediately and the site must immediately be reported to a heritage practitioner so that an investigation and evaluation of the finds can be made.

7.5 Conclusion

This chapter provides a discussion of potential impacts which can be expected to arise as a result of the proposed DIPR, associated infrastructure. These potential impacts were identified through the various specialists’ studies. The more detailed description and assessment of these potential impacts, as well as any mitigation measures, will be conducted during the Environmental Impact Assessment phase.


8 CONCLUSIONS AND RECOMMENDATIONS

8.1 Introduction

8.1.1 Project Background

The South African Nuclear Energy Corporation (Necsa) proposes to develop a small nuclear reactor with associated infrastructure at the Necsa Pelindaba site which is located on Church Street, West Extension, Brits District in the North West Province. The nuclear reactor is to be known as the Dedicated Isotope Production Reactor (DIPR). This DIPR is to be solely utilized for the purpose for producing radio isotopes and not for energy production. The reactor power of the DIPR would be less than 15 Mega Watts (MW). Part of this heat is ultimately shed to the environment through cooling towers. The radio isotopes produced are used in over 100 000 different medical procedures such as X-rays, Magnetic Resonance Imaging (MRI) scans and Computerised Tomography (CT) scans. The proposed development will consist of:





The renovation of an existing building which will be used for the administration of the DIPR.

In terms of the EIA Regulations, an application of this nature has to undergo both Scoping and Environmental Impact Assessment (EIA). Arcus GIBB (Pty) Ltd has been commissioned by Necsa, who is the (appointed project manager) project developer, to undertake the EIA process. This report documents the tasks which have been undertaken as part of the Scoping phase of the EIA. These tasks include the public participation process and Scoping level specialist studies, as well as the documentation of the issues which have been identified as a result of these activities. To date, tasks that have commenced include the:

Identification of stakeholders or I&APs;

Notification and advertisements;

Background Information Documents;

Specialist scoping studies; and

Ongoing consultation and engagement.

Detail on the above has been discussed in Chapter 6. This Draft Scoping Report has been released for public review and comment for a period of 40 days from 27 October 2011 – 07 December 2011. During the review period public participation will also be undertaken, allowing Interested and Affected Parties (I&APs) and Key Stakeholders from government and the private sector to


engage with the project proponents and independent environmental consultants. The PPP consists of key stakeholder workshops, focus group meetings, public meetings and one-on-one interactions. Issues raised by I&APs and key stakeholders during the public participation process will be documented and included in the Final Scoping Report. The relevant authorities required to review the proposed project and provide Environmental Authorisation have been consulted from the outset of this study, and have been engaged throughout the project process. These authorities include the National Department of Environmental Affairs (DEA), who are the lead authority for this project. The North West Department of Economic Development, Environment, Conservation and Tourism (NW DEDECT) is noted as a key commenting authority. In addition, a number of other authorities have been consulted. For a comprehensive list refer to Chapter 6. The Scoping phase of an EIA serves to provide detailed assessments of the potential impacts of the proposed project. Scoping has been undertaken in accordance with the requirements of Government Notices R543 of 2010, and the IEM Information Series (DEA, 2002). The objective of the Scoping phase is to:

Ensure that the process is open and transparent and involves the Authorities, proponent and stakeholders;

Identify the important characteristics of the affected environment;

Ensure that feasible alternatives are identified and selected for further assessment;

Assess and determine potential impacts of the proposed project on the biophysical and socio-economic environment and associated mitigation measures; and

Ensure compliance with the relevant legislation. Specialist studies were undertaken to identify potential impacts that may occur as a result of the proposed project. The studies undertaken are listed in Table 33. Table 33: Specialist studies undertaken within the Scoping Phase of the

project

Specialist Study Specialist Name Appendix

Ecology (Fauna and Flora) David Hoare: David Hoare Consulting

Appendix D1

Air Quality Impact Assessment

Lucian Burger: Airshed Planning Professionals

Appendix D2

Social Impact Assessment Nonka Byker: MasterQ Research Appendix D3

Heritage Impact Assessment Dr Johnny van Schalkwyk: NCM Appendix D4

The specialist studies identified potential impacts that could occur as a result of the proposed project and that will require detailed investigation during the Impact Assessment phase of the EIA. The conclusions of the Scoping phase specialist studies are discussed below.


8.2 Conclusions

8.2.1 Ecology

The proposed sites have been identified for the construction laydown, access road and the location of the proposed DIPR building. The potential ecological impacts associated with the proposed project have been identified. These are as follows:

Loss or fragmentation of indigenous natural vegetation.

Loss of habitat or individuals of threatened animals.

Loss of populations of threatened plants. Loss of individuals of protected tree species.

Damage to wetlands.

Establishment and spread of declared weeds and alien invader plants. The actual occurrence of the following potential impacts will be investigated in detail within the EIA phase of the project. The method in which these will be determined is discussed in Chapter 9.

8.2.2 Air Quality The proposed sites have been identified for the construction laydown, access road and the location of the proposed DIPR building. The potential air pollutants associated with the proposed project have been identified. These are discussed briefly below.

(a) Dedicated Isotope Production Reactor

It is expected that the proposed DIPR would have emissions of radionuclides during normal operation. From the historical records of emissions from SAFARI-1, it is expected that there may potentially be emissions of alphas, betas, iodine, tritium and noble gases, such as krypton and xenon. The impact of these radionuclide emissions would require the quantification of an emissions envelope, which would be developed from the potential vender emission specifications. However, in the event that this information would not be available, the historical emissions from the SAFARI-1 reactor will be used. This is considered to be conservative due to the old design, age of the reactor, as well as the larger size of the SAFARI-1 reactor compared to the proposed new DIPR reactor.

(b) Associated Infrastructure and Laydown Area

Given the slope of the construction laydown area, it is expected that there may be significant groundwork required to level off the area for equipment laydown. Furthermore, it is also expected that construction activities for the proposed DIPR would generate air pollutants. Whilst the air pollutants during construction include both particulate and gaseous emissions, it is anticipated that particulate emissions may be more significant, and that mitigation measures would be required to minimise the impact to comply with the NAAQS. Due to the expected limited information normally available at the EIA stage, generic emission factors may be required to estimate the particulate emissions during the


construction phase. These emission factors are generally regarded to be conservative. In order to assess the gaseous emission from the construction equipment, the number and types of equipment, the operational hours, the construction duration and the expected fuel usage will be required.

8.2.3 Social Impacts The conclusions and recommendations apply to the project site (that being both the DIPR site and the construction laydown area as an entity due to their close proximity to one another and the fact that they would not affect the social environment in significantly different ways). At this stage, no issues emerged that can be considered as fatal flaws from a social perspective. Based on the findings of the scoping phase, it is recommended that a full SIA be undertaken during the next phase to test the assumptions made in this scoping report in respect of issues such as the expected land use change, temporary influx of people to the area and the likelihood of the project impacting on sense of place. In addition, it is believed that the creation of a new operating entity will increase Necsa’s impact on the production of medical isotopes worldwide and as such it is expected that this would increase their international sales significantly. This could have a significant economic impact, not only on the corporation itself, but also quite possibly extending to downstream service providers. Due to the international significance of the project, the economic impacts can be widely spread and for this reason it is strongly recommended that an Economic Impact Assessment be done during the next phase or as an alternative, that the current study be expanded to a detailed Social and Economic Impact Assessment with one integrated report.

8.2.4 Heritage The aim of the heritage survey was to locate, identify, evaluate and document sites, objects and structures of cultural significance found within the area of the proposed development, to assess the significance thereof and to consider alternatives and plans for the mitigation of any adverse impacts.

As no sites, features or objects of cultural heritage significance were identified in either the dedicated isotope production reactor area or the associated infrastructure and laydown area, there would be no impact from the proposed development.

Therefore, from a heritage point of view it is recommended that the proposed development be allowed to continue. It is requested that should archaeological sites or graves be exposed during construction work, construction should stop and it must immediately be reported to a heritage practitioner so that an investigation and evaluation of the finds can be made.

8.3 Alternatives for Evaluation in the Impact Assessment Phase

The following project alternatives must be investigated in the EIA:


The “do nothing” alternative: The ‘do-nothing’ or ‘no-go’ alternative is the option of not developing the proposed DIPR and associated infrastructure;

Site alternatives: Eight site alternatives were identified on Pelindaba West during the initial pre-feasibility stages by an external panel of experts appointed by Necsa. As a result of the analysis Alternative Sites 3, 5 and 6 were identified for further analysis and assessment and will be carried through for comparative investigation within the EIA phase of the project.

The selection of the most suitable project alternatives will be based on the following principles:

The opinion of the public, ascertained through the public consultation process;

Specialists’ recommendations for the minimisation of environmental impacts;

Environmental constraints;

Optimisation of existing infrastructure, such as access roads;

Technical and Feasibility Studies; and

Economic cost-benefit analyses.

8.4 Recommendations

A number of potentially significant environmental impacts have been identified as requiring further in-depth study. Therefore, a detailed Environmental Impact Assessment is required to be undertaken in order to provide an assessment of these potential impacts and recommend appropriate mitigation measures, where required. The terms of reference for the detailed specialist studies required in the Impact Assessment phase of the project are included in the Plan of Study for EIA (Chapter 9).


9 PLAN OF STUDY FOR EIA

9.1 Introduction

This Draft Scoping Report was compiled in line with the requirements of the NEMA EIA Regulations and has provided a brief description of the pre-development biophysical and socio-economic environment of the broader region, a description of the nature and extent of the project, as well as the potential issues identified and evaluated to date in the Scoping Phase of the EIA. This provides the context for the Plan of Study for the Impact Assessment Phase of the project. The Plan of Study describes how the Impact Assessment Phase of the project will proceed and provides the terms of reference for specialists, the impact assessment methodology to be used to rate impacts as well as clearly indicating the deliverables of the Impact Assessment Phase and the proposed timeframe. Following acceptance of the Final Scoping Report, the detailed Impact Assessment Phase of the EIA process commences. This phase considers the potential impacts identified for the proposed project on the environment taking into account the following:

Potential impacts of the proposed project during the construction phase;

Potential impacts of the proposed project during the operational phase; and

The potential cumulative impacts of the proposed project.

9.2 Purpose of the Plan of Study for EIA

The Plan of Study for EIA sets out the proposed approach to the EIA. The following requirements of Regulation 28 of Government Notices R 543 promulgated in terms of section 24 of NEMA have been considered in compiling this Plan of Study for EIA:

A description of the tasks that will be undertaken as part of the Environmental Impact Assessment process, including any specialist reports or specialised processes, and the manner in which such tasks will be undertaken;

An indication of the stages at which the competent authority will be consulted;

A description of the proposed method of assessing the environmental issues and alternatives, including the no development option;

Particulars of the PPP to be conducted during the detailed environment Impact Assessment Phase of the EIA process; and

Any specific information required by the competent authority.

9.3 Detailed Impact Assessment Phase

9.3.1 Introduction

The purpose of the Impact Assessment Phase of an EIA is as follows (DEA, 2005):

Address issues that have been raised during the Scoping Phase;


Assess alternatives to the proposed activity in a comparative manner;

Assess all identified impacts and determine the significance of each impact; and

Formulate mitigation measures in order to minimise negative impacts and optimise the effects of positive impacts.

Numerous acceptable approaches and methodologies exist by which the above purpose can be achieved. The legislation in South Africa, including the guideline documents published in support thereof, does not provide a specific methodology for the assessment of impacts. Rather, an assessment framework is provided within which Environmental Assessment Practitioners (EAPs) are expected to structure a project-specific assessment methodology. This assessment framework recognises that there are different methodologies available for assessing the impact of a development but that the specific methodology selected must provide for the following (DEA, 2005):

A clear process for impact identification, prediction and evaluation;

The specification of impact identification techniques;

Criteria for evaluating the significance of impacts;

The design of mitigation measures to address impacts;

Defining types of impacts (direct, indirect or cumulative); and

Specification of uncertainties.

This section of the Plan of Study for EIA serves to describe the manner in which GIBB, as the appointed EAP, intends undertaking the detailed Impact Assessment Phase of the EIA process. To ensure consistency in the assessment, all the specialists will be required to make use of the same assessment methodology.

9.3.2 Impact Assessment Methodology The objective of the assessment of impacts is to identify and assess all the significant impacts that may arise because of the proposed development of the DIPR and associated infrastructure. The process of assessing the potential impacts of the project encompasses the following four activities:

Identification and assessment of potential impacts;

Prediction of the nature, magnitude, extent and duration of potentially significant impacts;

Identification of mitigation measures that could be implemented to reduce the severity or significance of the impacts of the activity; and

Evaluation of the significance of the impact after the mitigation measures have been implemented i.e. the significance of the residual impact.

The possible impacts associated with the proposed DIPR are identified in the Scoping Phase through public and stakeholder consultation, as well as through input from the authorities and the EIA team. These impacts are derived from the issues that are identified in respect of all phases of the development including the construction and operational phases. During the detailed Impact Assessment Phase of the EIA process, additional impacts will be identified through the various specialist studies to be undertaken and through the ongoing consultation process with I&APs. In accordance with GNR 543, promulgated in terms of section 24 of NEMA, specialists will be required to assess the significance of potential impacts in terms of the following criteria:


Cumulative impacts;

Nature of the impact;

Extent of the impact;

Intensity of the impact;

Duration of the impact;

Probability of the impact occurring;

Impact non-reversibility;

Impact on irreplaceable resources;

Confidence level; and

Degree to which the impact can be mitigated.

Table 34 provides a summary of the criteria and the rating scales, which will be used in this regard. The assignment of a rating18 will be done based on past experience of the EIA team, the professional judgement of the specialists as well as through desktop research.

Once the potential impacts have been assessed in terms of the above criteria a consequence rating will be applied as per the convention in Table 35. The consequence of the potential impacts will be determined according to the main criteria for determining the consequence of impacts, namely the extent, duration and intensity of the impacts. This assessment will be done initially for the scenario where no mitigation measures are implemented. The professional experience of the specialists will determine the allocation of the pre-mitigation impact consequence rating. The overall significance of the impacts will be defined based on the result of a combination of the consequence rating and the probability rating, as set out in Table 36. Mitigation measures will then be identified and considered for each impact and the assessment repeated in order to determine the significance of the residual impacts (the impact remaining after the mitigation measure has been implemented). The criteria that will be used to determine the significance of the residual impacts will include the following:

Probability of the mitigation measure being implemented; and

Extent to which the mitigation measure will affect the assessment criteria in Table 36.

The results of the assessment of the significance of the residual impacts will then be linked to decision-making by authorities in the following manner:

Low – will not have an influence on the decision to proceed with the proposed project, provided that recommended mitigation measures are implemented;

Medium – should influence the decision to proceed with the proposed project, provided that recommended mitigation measures are implemented; and

High – would strongly influence the decision to proceed with the proposed project regardless of the implementation of recommended mitigation measures.

18

Cumulative impacts, impact non-reversibility, and impact on irreplaceable resources will together inform the impact intensity

rating


Table 34: Impact assessment Criteria and Rating Scales

19

A resource for which no reasonable substitute exists, such as Red Data species and their habitat requirements

Criteria Rating Scales

Cumulative impacts (incremental impacts of the activity and other past, present and future activities on a common resource)

Low (there is still significant capacity of the environmental resources within the geographic area to respond to change and withstand further stress)

Medium (the capacity of the environmental resources within the geographic area to respond to change and withstand further stress is reduced)

High (the capacity of the environmental resources within the geographic area to respond to change and withstand further stress has been or is close to being exceeded)

Nature Positive

Negative

Neutral

Extent (the spatial limit of the impact)

Local (site-specific and/or immediate surrounding areas)

Regional (North West / Madibeng Municipality)

National or beyond

Intensity (the severity of the impact)

Low - where the impact affects the environment in such a way that natural, cultural and social functions and processes are minimally affected

Medium - where the affected environment is altered but natural, cultural and social functions and processes continue albeit in a modified way; and valued, important, sensitive or vulnerable systems or communities are negatively affected

High - where natural, cultural or social functions and processes are altered to the extent that it will temporarily or permanently cease; and valued, important, sensitive or vulnerable systems or communities are substantially affected.

Duration (the predicted lifetime of the impact)

Short-term (0 to 5 years)

Medium term (6 to 15 years)

Long term (16 to 30 years) - where the impact will cease after the operational life of the activity either because of natural processes or by human intervention.

Probability (the likelihood of the impact occurring)

Improbable – where the possibility of the impact occurring is very low

Probable – where there is a good possibility (<50 % chance) that the impact will occur

Highly probable – where it is most likely (50-90 % chance) that the impact will occur

Definite – where the impact will occur regardless of any prevention measures (>90 % chance of occurring)

Non-Reversibility (ability of the impacted environment to return to its pre-impacted state once the cause of the impact has been removed)

Low (impacted natural, cultural or social functions and processes will return to their pre-impacted state within the short-term)

Medium (impacted natural, cultural or social functions and processes will return to their pre-impacted state within the medium to long term)

High (impacted natural, cultural or social functions and processes will never return to their pre-impacted state)

Impact on irreplaceable

19

resources (is an irreplaceable resource impacted upon)

Yes

No

Confidence level (the specialist’s degree of confidence in the predictions and/or the information on which it is based)

Low

Medium

High


Table 35: Convention for Assigning a Consequence Rating

Consequence Rating Intensity, Extent and Duration Rating

HIGH Consequence

High intensity at a national level and endure in the long term

High intensity at a regional level and endure in the long term

High intensity at a national level and endure in the medium term

Medium intensity at a national level and endure in the long term

High intensity at a regional level and endure in the medium term

High intensity at a national level and endure in the short term

Medium intensity at a national level and endure in the medium term

Low intensity at a national level and endure in the long term

High intensity at a local level and endure in the long term

Medium intensity at a regional level and endure in the long term

MEDIUM Consequence

High intensity at a local level and endure in the medium term

Medium intensity at a regional level and endure in the medium term

High intensity at a regional level and endure in the short term

Medium intensity at a national level and endure in the short term

Medium intensity at a local level and endure in the medium term

Medium intensity at a local level and endure in the long term

Low intensity at a national level and endure in the medium term

Low intensity at a regional level and endure in the long term

LOW Consequence

Low intensity at a regional level and endure in the medium term

Low intensity at a national level and endure in the short term

High intensity at a local level and endure in the short term

Medium intensity at a regional level and endure in the short term

Low intensity at a local level and endure in the long term

Low intensity at a local level and endure in the medium term

Low intensity at a regional level and endure in the short term

Low to medium intensity at a local level and endure in the short term

Table 36: Convention for Assigning a Significance Rating

Consequence Rating Consequence x Probability

HIGH Significance

High x Definite

High x Highly Probable

High x Probable

High x Improbable

Medium x Definite

MEDIUM Significance

Medium x Highly Probable

Medium x Probable

LOW Significance

Medium x Improbable

Low x Definite

Low x Highly Probable

Low x Probable

Low x Improbable

9.3.3 Consideration of Alternatives

The following project alternatives will be investigated in the EIA:

The “do nothing” or ‘no-go’ alternative: The ‘do-nothing’ alternative is the option of not developing the proposed DIPR;

The Alternative 1: The Preferred Alternative;

The Alternative 2: The North Alternative; and

The Alternative 3: The West Alternative. The selection of the most suitable project alternatives will be based on the following principles:

The opinion of the public, ascertained through the public consultation process;


Specialists’ recommendations;

Environmental constraints;

Minimal environmental impacts; and

Technical and feasibility studies.

9.3.4 Assessment of Potential Impacts Based on the findings of the Scoping Phase, the issues presented in Table 37 below were identified as requiring further investigation within the Impact Assessment Phase. The specialists involved in the EIA are also reflected in Table 37. These specialist studies will consider the site proposed for the development of the DIPR associated infrastructure, as well as all of the project alternatives. The ToR for the specialist studies is provided in Section 9.4 below. Table 37: Summary of issues which require further investigation in the

Impact Assessment Phase

Specialist Study Potential Impact Specialist Name

Ecological Assessment (Fauna and Flora)

Loss or fragmentation of indigenous natural vegetation.

Loss of habitat or individuals of threatened animals.

Loss of populations of threatened plants. Loss of individuals of protected tree species.

Damage to wetlands.

Establishment and spread of declared weeds and alien invader plants.

David Hoare of David Hoare Consulting CC

Social Assessment Geographical Change Processes

The impact on land use largely depends on the current land use. Although it is not foreseen that the project site would lead to a drastic land use change within Pelindaba itself (as it would blend in with the rest of the activities), the location of the construction camp might lead to a temporary change in land use. This would lead to a temporary change in land use, from presumably agricultural vacant land to an area of human settlement with associated services. The impact would largely depend on the current land use and on landownership.

Demographical Change Processes

A change in the number and composition of the local area can lead to economic, health, safety and social-wellbeing impacts.

Economic Change Processes

The likelihood of a positive economic impact on local individuals who are employed during the construction phase.

Increase in disposable income and business earning, thus resulting in business and consumer spending.

Increased revenues from taxation and provision of services and utilities.

Institutional and Legal Change Processes

Nonka Byker of MasterQ Research


Additional demand on municipal services, such as water, sewerage and roads could impact on health and safety if such services are not available. An influx of unemployed job seekers can lead to the development of informal settlements. This can impact on health (as services are not provided or further taxed) and safety (an increase in crime is possible as people do not find employment and become frustrated with their living conditions).

Socio Cultural Change Processes

Cultural clashes can occur where people are brought into the area from elsewhere. Apart from conflict situations, the rules of interaction can be blurred, impacting on family and cultural cohesiveness, and health and safety. At this stage it is not foreseen that the presence of the proposed DIPR would impact on local residents’ sense of place, but this assumption would have to be tested during the EIA phase.

Heritage Assessment As no sites, features or objects of cultural heritage significance were identified in either the dedicated isotope production reactor area or the associated infrastructure and lay down area, there would be no impact from the proposed development.

Johnny van Schalkwyk of NCM

Air Quality Assessment Dedicated Isotopes Production Reactor

It is expected that the proposed DIPR would have normal operation emissions of radionuclides. From the historical records of emissions from SAFARI-1, it is expected that there may potentially be emissions of alphas, betas, iodine, tritium and noble gases, such as krypton and xenon.

The impact of these radionuclide emissions would require the quantification of an emissions envelope, which would be developed from the potential vender emission specifications. However, in the event that this information would not be available, the historical emissions from the SAFARI-1 reactor will be used. This is considered to be conservative due to the old design, age of the reactor and size of the SAFARI reactor core in comparison to the DIPR core.

Associated Infrastructure and Laydown Area

Given the slope of the construction laydown area, it is expected that there may be significant groundwork required to level off the area for equipment laydown. Furthermore, it is also expected that construction activities for the proposed DIPR would generate air pollutants. Whilst the air pollutants during construction include both particulate and

Lucian Burger of Airshed Planning Professionals


gaseous emissions, it is anticipated that particulate emissions may be more significant, and that mitigation measure would be required to minimise the impact to comply with the NAAQS.

Due to the expected limited information normally available at the Scoping stage, generic emission factors may be required to estimate the particulate non-radiological emissions during the construction phase. These emission factors are generally regarded to be conservative.

In order to assess the gaseous emission from the construction equipment, the number and types of equipment, the operational hours, the construction duration and the expected fuel usage will be required.

9.3.5 Public Participation Process (PPP)

Ongoing consultation with all stakeholders and registered I&APs will continue beyond the approval of the Scoping Report into the Impact Assessment Phase of the EIA process. Consultation will continue in the form of the following:

Maintaining an open channel of communication with all stakeholders and authorities;

Distribution of all project information and findings to registered I&APs;

Public information sharing meeting on completion of the Draft EIR;

Commenting period on the Draft EIR prior to submission of the report to the authorities; and

Information in the media and press (if required).

9.3.6 Environmental Impact Report The contents of the Environmental Impact Report (EIR) will include the following:

Details and expertise of the EAP to undertake an EIA;

Detailed description of the proposed activity;

Detailed description of the property on which the activity is to be undertaken and the location of the activity on the property;

A description of the environment that may be affected by the activity and the manner in which the physical, biological, social, economic and cultural aspects of the environment may be affected by the proposed activity;

Details of the PPP conducted during the detailed assessment phase of the EIA process;

A description of the need and desirability of the proposed activity and identified potential alternatives to the proposed activity, including advantages and disadvantages that the proposed activity or alternatives may have on the environment and the community that may be affected by the activity;

An indication of the methodology used in determining the significance of potential environmental impacts;

A description and comparative assessment of all alternatives identified during the environmental impact assessment process;

A summary of the findings and recommendations of any specialist report or report on specialised process;


A description of 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 issues could be addressed by the adoption of mitigation measures;

An assessment of each identified potentially significant impact in terms of cumulative impacts, the nature of the impact, the extent and duration of the impact, the probability of the impact occurring, the degree to which the impact can be reversed, the degree to which the impact may cause irreplaceable loss of resources and the degree to which the impact can be mitigated;

A description of any assumptions, uncertainties and gaps in knowledge;

A reasoned opinion as to whether the activity should or should not be authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation;

An environmental impact statement which contains a summary of the key findings of the environmental impact assessment, a comparative assessment of the positive and negative implications of the proposed activity and identified alternatives;

A draft Environmental Management Plan (EMP);

Copies of any specialist reports and reports on specialised processes; and

Any specific information that may be required by the competent authority.

9.3.7 Draft Environmental Management Programme (EMP) During the compilation of the EIA Report, a draft EMP will be compiled in accordance with the NEMA EIA Regulations. The draft EMP will provide the actions for the management of identified environmental impacts emanating from the proposed project and a detailed outline of the implementation programme to minimise and/ or eliminate the anticipated negative environmental impacts. The draft EMP will provide strategies to be used to address the roles and responsibilities of environmental management personnel on site, and a framework for environmental compliance and monitoring. The draft EMP will be included as part of the EIR. The EMP will include the following:

Details and expertise of the person who prepared the EMP;

Information on any proposed management or mitigation measures that will be taken to address the environmental impacts that are identified in the Environmental Impact Report (EIR), including environmental impacts or objectives in respect of planning and design, pre-construction and construction activities, operation or undertaking of the activities, rehabilitation of the environment and closure where relevant;

A detailed description of the aspects of the activity that are covered by the draft EMP;

An identification of the persons who will be responsible for the implementation of the measures;

Proposed mechanisms for monitoring compliance with the EMP and reporting thereon;

As far as possible, measures to rehabilitate the environmental affected by the undertaking of any listed activity or specified activity to its natural or predetermined state or to a land use which conforms to the generally accepted principle of sustainable development, including where appropriate concurrent or progressive rehabilitation measures;

A description of the manner in which it intends to modify, remedy activities causing pollution or environmental degradation and how it will comply with


prescribed environmental management standards and provision of any relevant Acts;

Time periods within which the measures contemplated in the EMP must be implemented;

The process for managing any environmental damage, pollution, ecological degradation as a result of undertaking a listed activity;

An environmental awareness plan describing the manner in which the applicant will inform his or her employees of environmental risk and how risk must be dealt with to avoid pollution; and

Where appropriate, closure plans, including closure objectives.

9.3.8 Public Review of EIR and EMP The Draft EIR will be distributed to suitable public venues with comment sheets, which will be collected at the end of the comment period. I&APs will be informed of the location and contact details of the public venues. A commenting period of at least 40 days will be provided for I&APs to comment on the Draft EIR. Comments on the Draft EIR will be captured and responded to in the updated IRR. A Revised Draft EIR will be compiled should the comments suggest that substantial amendments to the document will be necessary and this Revised Draft EIR will be circulated. Thereafter, the Draft EIR will be finalised into a Final EIR, which will be submitted to the DEA for their review. All registered I&APs will be informed of the availability of the Final EIA Report. Any comments received on the Final EIA Report will be submitted directly to the DEA for their review and consideration.

9.3.9 Consultation with the DEA It is envisaged that consultation with the DEA will coincide with the compilation of the following key documents:

Scoping Report and Plan of Study for EIA;

Draft EIR and EMP; and

Final EIR Report and EMP. Consultation outside of the above deliverables will be undertaken as necessary in order to ensure that the DEA is aware of the status of the project.

9.3.10 Proposed Project Programme for the EIA The programme for the EIA suggests the following timeframes with respect to the most important activities to be undertaken:

Submission of the Final Scoping Report to the DEA – January 2012.

Submission of the Draft EIR for public comment – April to June 2012.

Submission of the Final EIR to the DEA – July 2012.

The EIA process is iterative by nature and it should therefore be appreciated that the above dates are provided as guidance only and are subject to change.


9.4 Terms of Reference for Specialist Studies

A team of three (3) specialists will be involved in the detailed Impact Assessment Phase of the EIA process. A summary of the specialist studies and the proposed specialist responsible for that study is provided in Table 38 below. Table 38: Specialist Studies to be undertaken during the Impact

Assessment Phase of the project

Specialist Study Specialist Name

Ecology (Fauna and Flora) David Hoare: David Hoare Consulting

Social Impact Assessment Nonka Byker: MasterQ Research

Air Quality Impact Assessment Lucian Burger: Airshed Planning Professionals

The scope of each of the above individual studies is provided in this section of the Plan of Study for EIA.

9.4.1 General Terms of Reference for all Specialist Studies

In April 2006, the Department of Environmental Affairs and Tourism (DEAT), now known as the Department of Environment Affairs (DEA) issued guidelines for involving specialists in EIA processes. The specialists should make themselves aware of these guidelines and amendments thereof, as well as any other guidelines, codes, standards, or applicable legislation relative to their field of expertise, and will utilise them to more precisely determine methods and approaches to their specialist studies and will reference compliance with the above-mentioned requirements accordingly. Specialists are also expected to consider best practise when undertaking their study. The assessment of impacts should be broadly undertaken in accordance with the guidelines provided in the Guideline Document: EIA Regulations (DEA, 1998), NEMA principles, Section 24(4) of NEMA (as amended) and both the DEA and the North West Department of Economic Development, Environment, Conservation and Tourism (NW DEDECT) guideline documents as appropriate to the specific field of study. In addition, the following General Terms of Reference apply to each of the specialist studies:

Attend a one day site visit;

Design and undertake the specialist study in accordance with the specifications provided;

Describe the baseline conditions that exist in the study area and identify any sensitive areas that would need special consideration;

Provide an outline of the approach used in the study;

Assessment of all project alternatives including the no-go alternative;

Identify, assess and evaluate the possible impacts of the proposed DIPR facility and associated infrastructure during all development phases (construction and operation) of the proposed project;

Identify and assess any cumulative impacts arising from the proposed project;

Determine the significance of assessed impacts according to the methodology provided by the Environmental Assessment Practitioner (EAP) and provide a revised significance rating of assessed impacts after the implementation of mitigation measures;


Undertake field surveys, as appropriate to the requirements of the particular specialist study;

Identify areas where integration of studies with other specialists would ensure a better assessment and coordinate with other specialists in this regard;

Apply the precautionary principle in the assessment of impacts, in particular where there is major uncertainty, low levels of confidence in predictions and poor data or information;

Recommend practicable mitigation measures to minimise or eliminate negative impacts and/or enhance potential project benefits;

Recommend appropriate auditing, monitoring and review measures;

Compile all information into a stand-alone report according to the format provided by Arcus GIBB; and

All specialist studies must take cognisance of and comply with the relevant guideline documents applicable to that specialist study.

9.4.2 Specific Terms of Reference

The specific Terms of Reference for all specialist studies are presented below:

(a) Air quality Assessment The following assessments will be done during the EIA phase in order to properly assess potential impacts on the air quality due to the proposed development of the DIPR and associated infrastructure. The impact assessment would require the following three main tasks:

Establishment of the baseline;

Determine the predicted impact; and

Development of Mitigation and Air Quality Management Plans (AQMP). Establishing the baseline includes the following enabling outputs: 1. A general description of the region’s climatology; 2. A description of local meteorological parameters, important for the prediction of

future air pollution impacts; 3. A general description of the dispersion potential; 4. A description of the current air quality in the area; 5. A list of other sources of air pollution that may contribute to the area of impact; 6. The identification of sensitive receptors (e.g. residential areas); and 7. A legal (pertaining to air pollution) review. The air concentrations and fallout would be simulated using a suitable atmospheric dispersion model that would accommodate the relatively complex topography surrounding the Necsa complex. All emissions would be simulated using NNR approved atmospheric dispersion model(s). Typical dispersion models, which can be chosen from, include the US Environmental Protection Agency’s (US EPA’s) Industrial Source Complex Model (ISC), US EPA’s AERMET/AERMOD, US EPA’s CALMET/CALPUFF, Cosyma, Canada’s Integrated Model for the Probabilistic Assessment of Contaminant Transport (IMPACT), the HAWK model, etc. The UK’s ADMS model may also be suitable for radiological emissions. These models require a comprehensive meteorological database, which includes as a minimum, wind speed, wind direction and ambient temperature. Other parameters


that would be useful include solar radiation and standard deviation of wind direction. These measurements would be sourced from the South African Weather Services (upper air) and the two meteorological stations at Necsa. At least five year’s hourly average data will be used. The necessary assessment criteria will be identified to check compliance with the Department of Environmental Affairs for conventional pollutants and the National Nuclear Regulator for radionuclide emissions, respectively. Recommendations will be made regarding mitigation and / or management measures to address the unavoidable impacts identified. However, whilst the mitigation will detail the expected emission reduction, only generic methodologies would be provided; specific mitigation equipment and products will not be given. The air predictions will also provide the basis for designing an air quality monitoring plan for inclusion in the Environmental Management Plan.

(b) Social Impact Assessment Data will be gathered during the EIA phase as per the EIA studies segment of the tables listed in Section 9.3.2. The data will be analysed and to ensure uniformity between with other specialists’ reports, the assessment methodology as supplied will be used to assess impacts. For each of the identified impacts for consideration during the Impact Assessment Phase of the project, the following will be done: Geographical Change Processes 1. Consult with the project proponent to determine the standards and requirements

that contractors have to meet in terms of construction camps. 2. Consult with the project proponent on the possible location(s) of the

construction camp and determine if any consultation has taken place with the landowner(s).

3. Undertake a site visit to the area to determine the land use on the property as well as the surrounding area.

Demographical Change Processes 1. Consult with the project proponent and/or its appointed or shortlisted

contractor(s) on aspects 1-3 mentioned above. 2. Attend a public meeting within a PDI community (if such a meeting will be held)

to determine the expressed interest for jobs and the likelihood that the availability of such jobs would be communicated to people outside the project area.

Economic Change Processes 1. Conduct a desktop study to determine the effect of similar projects elsewhere

(in terms of job creation and local employment). 2. Obtain information from the project proponent or its appointed or short-listed

contractors on points all the points mentioned above.

Institutional and Legal Change Processes 1. Consult with interest groups (residents associations, etc.) to determine their

experience of local municipal services.


2. Consult with the local municipality to determine their capacity to handle additional services and to determine the possibility of other large scale developments planned in the area.

3. Obtain information from the project proponent and/or its appointed or short-listed contractor to determine how services will be supplied at the construction camp and how waste will be disposed of.

Socio Cultural Change Processes 1. Consult with public participation consultants to determine pertinent issues

raised. 2. Consult with local residents to determine their sense of place and place

attachment. 3. Assess information obtained from focus group meetings.

(c) Ecological Impact Assessment The following assessments will be done during the EIA phase in order to properly assess potential impacts on the ecological receiving environment by the proposed project: 1. A description of the broad vegetation types and/or habitats for the site will be

provided, including any areas of potential conservation value. This will be based on published sources, including the vegetation map of South Africa (Mucina et al., 2006), the National Spatial Biodiversity Assessment and any Biodiversity Conservation Plans that exist for the Province.

2. The national conservation status of major vegetation types in which the study sites are located will be provided, as listed in The Draft National List of Threatened Ecosystems (GN1477 of 2009), published under the National Environmental Management: Biodiversity Act (Act No. 10, 2004).

3. An assessment will be undertaken of the general status of vegetation on site in order to provide a description of which areas contain natural habitat versus those that are transformed and/or degraded. This will be shown in the form of an ecological sensitivity map for the site.

4. The presence of plant and animal species of concern will be evaluated during the EIA phase. This will be done by assessing habitat suitability for those species that have been assessed as potentially occurring in the general area. Lists of species that could potentially occur in the general area will be compiled from databases and literature sources. Those that are considered to have a high probability of occurring on site will be searched for in the field.

5. The presence and distribution of watercourses and drainage lines on site will be determined. This will be done primarily using aerial photograph interpretation, but will be confirmed in the field using topographic and floristic indicators.

6. Investigation into the potential presence of trees protected according to the National Forests Act and fauna and flora protected under the National Environmental Management: Biodiversity Act. The presence of any of these species on site will be determined in the field.

7. Potential impacts will be assessed according to standard criteria (nature, extent, duration, magnitude, probability, significance, status as well as the degree to which impacts can be reversed, the degree to which impacts will cause


irreplaceable loss of resources and the degree to which impacts can be mitigated).

The proposed approach will identify any ecological features of concern and assess the potential impacts of the proposed project on such features. The impacts assessed will be site specific and will include mitigation measures for reducing potential impacts.

(d) Heritage Impact Assessment From a heritage point of view it is recommended that the proposed development be allowed to continue. It is requested that should archaeological sites or graves be exposed during construction work, it must immediately be reported to a heritage practitioner so that an investigation and evaluation of the finds can be made. No further studies are required for the EIA Phase of the project.

9.5 Conclusion

This Plan of Study for EIA is aimed at meeting the requirements of the EIA Regulations as a minimum. The methodologies proposed for obtaining the information required to effectively identify and assess the potential environmental impacts of the project are considered to be comprehensive and sufficient to allow for the compilation of an EIR which addresses I&AP concerns and which will provide the competent authority with the appropriate information necessary to allow for informed decision-making on the application for authorisation.


10 REFERENCES

Acocks, J.P.H. 1975. Veld Types of South Africa. Memoirs of the Botanical Survey of South Africa, No. 40. Pretoria: Botanical Research Institute. Bojanala Platinum District Municipality Integrated Development Plan (2010/2011) Dr David Hoare, (2011), Ecological Scoping Phase Assessment, David Hoare: David Hoare Consulting, Gauteng Dr Johnny van Schalkwyk (2011), Heritage Impact Assessment, National Cultural Museum, Gauteng Holm, S.E. 1966. Bibliography of South African Pre- and Protohistoric archaeology. Pretoria: J.L. van Schaik.

Lucian Burger, (2011), Air quality Impact Assessment, Airshed Planning Professionals, Gauteng Madibeng Local Municipality Integrated Development Plan (2010/2011) Mason, R. 1968. Prehistory of the Transvaal. Johannesburg: Witwatersrand University Press. Necsa (2011) Radiological Environmental Monitoring at Necsa Pelindaba Site, Report Number SHEQ-2011-REP-0076 NNR (1999a). National Nuclear Regulator Act, 1999. NNR (1999b). R.388 National Nuclear Regulator Act (47/1999): Regulations: Safety Standards and Regulatory Practices. Nonka Byker, (2011), Social Impact Assessment, MasterQ Research, Gauteng NTP (2010) Dedicated Isotope Production Reactor: Specification for the DIPR Site Safety Report. Document Number: DIPR-LiC-SPE-0001 Rev 0, Necsa NTP (2011) Dedicated Isotope Production Reactor: Background Information Supporting the Scope of Work for Environmental Assessment Practitioner (EAP), Document Number: DIPR-SITE-SQW-OOOl Rev 0, Necsa South African Police Service: Crime Statistics. http://www.saps.gov.za/statistics/reports/crimestats/2011/crime_stats.htm Statistics South Africa: Census 2001 Interactive Data. http://www.statssa.gov.za/census01/html/C2001Interactive.asp Statistics South Africa: Community Survey 2007 Interactive Data. http://www.statssa.gov.za/community_new/content.asp?link=interactivedata.asp Vanclay, F. (2002). ‘Conceptualising Social Impacts.’ Environmental Impact Assessment Review 22 (2002: pp. 183– 211).

http://www.saps.gov.za/statistics/reports/crimestats/2011/crime_stats.htm

http://www.statssa.gov.za/census01/html/C2001Interactive.asp

http://www.statssa.gov.za/community_new/content.asp?link=interactivedata.asp


Van Schalkwyk, J.A. 1998. A survey of cultural resources for the Lomond/Scheerpoort powerline, Broederstroom area, west of Pretoria. Unpublished report 1998KH18. Pretoria: National Cultural History Museum. Van Schalkwyk, J.A. 2004. Heritage survey for the proposed Blair Atholl Golf Estate, Pretoria District, Gauteng Province. Unpublished report 2004KH52. Pretoria: National Cultural History Museum. Van Schalkwyk, J.A. 2005. Heritage impact scoping report for the proposed residential development on the farm Rietfontein 522JQ, Gauteng Province. Unpublished report 2005KH115. Pretoria: National Cultural History Museum. Van Schalkwyk, J.A. 2010. Heritage impact assessment for the proposed mountain view estate development on portions of the farms Simonsview, Kalkheuwel, Rhenosterspruit and Riverside, North West and Gauteng Provinces. Unpublished report 2010/JvS/042. Van Vollenhoven, A. & Van den Bos, J. 1997. 'n Kultuurhulpbronstudie van die Britse blokhuisstelsel van die Tweede Anglo-Boe re-oorlog (1899-1902) in die voormalige Transvaal (ZAR). Pretoria: Raad vir Geesteswetenskaplike Navorsing. Voigt, E. 1973. Preliminary report on Welgegund: an Iron Age burial site. South African Archaeological Bulletin 27:155-163. (2011), Nuclear Medicine, online @ http://www.world-nuclear.org/info/inf55.html

http://www.world-nuclear.org/info/inf55.html

South African Nuclear Energy Corporation (Necsa)projects.gibb.co.za/Portals/3/projects/201111...

Documents

Transcript of South African Nuclear Energy Corporation (Necsa)projects.gibb.co.za/Portals/3/projects/201111...