PROPOSED 80 000 TPY GALVANIZING PLANT IN THE
COEGA INDUSTRIAL DEVELOPMENT ZONE (IDZ)
FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT
DISCLAIMER ILISO Consulting (Pty) Ltd assumes no
responsibility for any errors that may appear in this document The information contained in this document is subject to change without notice
PROPOSED 80 000 TPY GALVANIZING PLANT IN THE
COEGA INDUSTRIAL DEVELOPMENT ZONE (IDZ)
DEDEA Reference ECm1LN2M11-24
Report Title Draft Environmental Impact Assessment Report
Authors Lea September Martin van Veelen Terry Baker
ILISO project reference no 1000196
Status of report Final v10
First issue April 2012
Final issue
Prepared by Submitted to
ILISO Consulting (Pty) Ltd Eastern Cape Department of Economic
P O Box 68735 Development and Environmental Affairs
Highveld Contact Mr Jeff Govender
0169 Private Bag X 5001
Greenacres 6057
Contact Lea September On behalf of
Tel 012 685 0900 Casa Steel Trading (Pty) Ltd
Fax 012 665 1886 Contact Mrs Leoncie Mukundente Director
Cell 082 455 1157 Tel 041 379 4623
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 i
PROPOSED 80 000 TPY GALVANIZING PLANT IN THE
COEGA INDUSTRIAL DEVELOPMENT ZONE
FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT
TABLE OF CONTENTS
ACRONYMS IV
EXECUTIVE SUMMARY V
1 INTRODUCTION 1-1
11 BACKGROUND 1-1
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS 1-1 13 PURPOSE OF THIS REPORT 1-2
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) 1-2
15 PROJECT TEAM 1-3
16 STRUCTURE OF THIS REPORT 1-4
2 DESCRIPTION OF THE PROPOSED PROJECT 2-1
21 TECHNICAL ASPECTS 2-1
211 The galvanizing process 2-1
212 Main inputs and outputs in operational phase 2-3
213 Installations on site 2-3
22 LOCATION OF THE PROPOSED GALVANIZING PLANT 2-4
23 NEED AND DESIRABILITY 2-6
24 ALTERNATIVES IDENTIFIED 2-6
25 CONSTRUCTION ASPECTS 2-6
26 OPERATION ASPECTS 2-7
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT 3-1
31 OBJECTIVES 3-1
32 AUTHORITY CONSULTATION 3-1
33 PUBLIC PARTICIPATION PROCESS CONDUCTED 3-1
34 LEGISLATION AND GUIDELINES CONSIDERED 3-2
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT 4-1
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION 4-1
42 SOCIO-ECONOMIC CHARACTERISTICS 4-3
43 BIOPHYSICAL CHARACTERISTICS 4-3
431 Surface and ground water 4-3
432 Climate and atmospheric conditions 4-3
433 Geology and soils 4-4
434 Terrestrial ecology 4-4
435 Land use and topography 4-7
436 Heritage and archaeological survey 4-7
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED 5-1
51 AIR QUALITY 5-1
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 ii
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS 5-2
53 BIODIVERSITY AND CONSERVATION 5-2
54 WATER QUALITY 5-2 55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES 5-3
56 HEALTH AND SAFETY 5-5
57 TRAFFIC 5-5
58 NOISE 5-9
59 SOCIO-ECONOMIC ASPECTS 5-10
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY 6-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS 7-1
71 IMPACTS DURING CONSTRUCTION 7-1
711 Air quality 7-1
712 Heritage and archaeological resources 7-1
713 Biodiversity and conservation 7-2
714 Water related impacts 7-3
715 Waste management 7-3
716 Health and safety 7-4
717 Traffic 7-4
718 Noise 7-5
719 Socio-economic 7-5
72 IMPACTS DURING OPERATION 7-6
721 Air quality 7-6
722 Water quality 7-7
723 Waste management and hazardous substances 7-8
724 Health and safety 7-9
725 Traffic 7-9
726 Noise 7-10
727 Socio-economic 7-11
73 COMPARATIVE ASSESSMENT OF IMPACTS 7-11
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME 8-1
9 ENVIRONMENTAL IMPACT STATEMENT 9-1
10 CONCLUSION AND RECOMMENDATIONS 10-1
11 REFERENCES 11-1
LIST OF FIGURES
Figure 1 Process flow diagram for proposed galvanizing plant 2-2
Figure 2 Continuous Galvanizing Line 2-3
Figure 3 Location of the proposed galvanizing plant 2-5
Figure 4 Zone layout in the Coega IDZ 4-1
Figure 5 Site location 4-2
Figure 6 Coega IDZ Open Space Management Plan (OSMP) 4-5
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble gravels
exposed by tracks in Zone 6 (Source Binneman 2010) 4-8
Figure 8 Coega IDZ road network layout (Adapted from BKS 2006) 5-6
Figure 9 Coega IDZ road network 5-7
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 iii
Figure 10 Trip distribution for freight and personnel trips 5-8
Figure 11 Morning peak hour Casa Steel development traffic 5-9
Figure 12 Casa Steel organisation chart 5-10
LIST OF TABLES
Table 1 Coordinates of site corners for the proposed galvanizing plant 4-1
Table 2 Hazardous materials to be used on site 5-4
APPENDICES
APPENDIX A List of registered stakeholders
APPENDIX B Notice of AEL application and advertisements
APPENDIX C Notice of comment period for draft scoping report
APPENDIX D Summary of issues raised and responses thereto
APPENDIX E Background Information Document
APPENDIX F Air Quality Impact Assessment
APPENDIX G Traffic Impact Assessment
APPENDIX H Waste Management and Hazardous Substances specialist study
APPENDIX I Water Quality Specialist Study
APPENDIX J Environmental Management Programme (EMP)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 iv
ACRONYMS
AEL Atmospheric Emissions Licence
BID Background Information Document
CCA Custom Controlled Area
CDC Coega Development Corporation
DEA Department of Environmental Affairs
DEDEAT Department of Economic Development Environmental Affairs and Tourism
DWA Department of Water Affairs
EAP Environmental Assessment Practitioner
EIA Environmental Impact Assessment
ELC Environmental Liaison Committee
EMP Environmental Management Programme
GN Government Notice
IampAPs Interested and Affected Parties
IDZ Industrial Development Zone
LNG Liquid natural gas
masl Meters above sea level
MSDS Material Safety Data sheet
NEMA National Environmental Management Act
NEMBA National Environment Management Biodiversity Act (No10 of 2004)
NMBM Nelson Mandela Bay Municipality
OSMP Open Space Management Plan
PoS Plan of Study
SAHRA South African Heritage Resources Agency
TNPA Transnet National Ports Authority
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 v
EXECUTIVE SUMMARY
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone
(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province
Galvanizing consists of coating steel with zinc in order to protect it from corrosion An
Environmental Impact Assessment (EIA) is required as the proposed project involves several
activities listed in terms of Section 24 of the National Environmental Management Act
(NEMA) 107 of 1998 as amended and requires an environmental authorisation The
project also involves activities listed in terms of the National Environmental Management Air
Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008
which respectively require an Atmospheric Emissions Licence and a Waste Management
Licence
The Scoping and Environmental Impact Assessment process underway covers all aspects of
the project and informs all three applications
Scoping was the first phase of investigations and aimed to inter alia identify potential key
environmental issues and impacts to be addressed in the EIA phase
The following environmental issues and potential impacts identified in the Scoping Phase
were investigated in the EIA
Air quality
The galvanizing process generates atmospheric emissions which are regulated in terms
of the National Environmental Management Air Quality Act and appropriate measures
are required in order to adhere to the applicable standards Other sources of impact on
air quality include emissions from the LNG burner emissions and dust from the transport
of steel and other materials in trucks as well as dust and gas emissions related to
construction activities Mitigation measures recommended in the EMP will ensure that air
quality impacts are kept to a minimum and compliance with emissions standards is
maintained
Biodiversity and conservation
Certain types of vegetation in the IDZ are of high conservation importance Protected
species will be rescued as per the CDCrsquos requirements
Water quality
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through spills
or leaks This risk can however be minimized if not avoided altogether through design
choices (bunded areas) and the adherence to best practice guidelines for the handling or
the transport of hazardous substances and waste
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vi
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
Waste management and hazardous substances
The plant will generate a relatively small amount of solid waste which will be re-used
recycled or disposed of in accordance with the EMP recommendations
There will be a wastewater treatment plant on site which will neutralise process water
(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer
Hazardous waste from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site
at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and
removed on a monthly basis is limited to 10 m3
A number of substances classified as hazardous are used in the galvanizing process and
the transport and handling of these is subject to certain rules and guidelines
In addition the permanent storage of a high quantity of liquid petroleum on site (20 000
litres at any one time) is subject to certain specifications and requires approval from the
municipality
Health and safety
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling of the various substances used will be done in
accordance with applicable instructions (cf material safety data sheets)
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as provide
site supervision including executing tests (individual test cold run and hot run) during 3
months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the EMP
Traffic
In the operational phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and from
the Port of Ngqura
The traffic expected to be generated during construction as well as operation is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low and
the total traffic generated by Casa Steel is also relatively low
The impact on port traffic is also negligible and well within the portrsquos capacity
Socio-economic aspects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vii
The proposed galvanizing plant will make a positive contribution by creating jobs during
construction and operation and generating business for the various service providers
Fatal flaws
No fatal flaws have been identified
The significance of these potential key environmental impacts were assessed in the EIA
phase and the findings of this phase of investigations are presented in this report
The main findings of the EIA are as follows
During construction impacts post-mitigation are low with the exception of noise and
biodiversity as the construction of the plant will result in the destruction of habitat
and loss of fauna and flora and noise impacts inherent to construction activities
Mitigation measures have been included in the EMP for these impacts and they have
a medium significance post-mitigation
All impacts were assessed as low during operation after mitigation
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium
to long term similar impacts are likely to occur due to ongoing developments in the
IDZ
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
The CDC has its own requirements regarding the monitoring of certain aspects of the
project such as the quality of the effluent and the noise levels These have been
incorporated into the EMP Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as other
infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified and
assessed No fatal flaws have been identified
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 viii
It is recommended that the project be approved subject to the conditions listed above
and adherence to the EMP recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-1
1 INTRODUCTION
11 BACKGROUND
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)
Nelson Mandela Bay Municipality Eastern Cape Province
The demand for galvanised steel products is high in South Africa and Africa and is
expected to increase in the foreseeable future From an economic point of view the
proposed project has therefore been found to be viable
Casa Steel will source the steel coils from various markets internationally and in
South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is
destined to be exported mainly to African countries
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
An Environmental Impact Assessment (EIA) is required as the proposed project
involves several activities listed in terms of Section 24 of the National Environmental
Management Act (NEMA) No 107 of 1998 as amended and requires an
environmental authorisation
The following listed activities requiring environmental authorisation have been
identified
Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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
Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped
land to industrial use greater than 1 ha but less than 20 ha in size outside an
urban area
Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any
process or activity requiring a license in terms of national or provincial legislation
governing the generation or release of emissions
Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5
hectares or more of vegetation where 75 or more of the vegetative cover
constitutes indigenous vegetation except where such removal of vegetation is
required for
(i) purposes of agriculture or afforestation inside areas identified in
spatial instruments adopted by the competent authority for
agriculture or afforestation purposes
(ii) the undertaking of a process or activity included in the list of waste
management activities published in terms of section 19 of the
National Environmental Management Waste Act 2008 (Act No 59
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-2
of 2008) in which case the activity is regarded to be excluded from
this list
(iii) the undertaking of a linear activity falling below the thresholds in
Notice 544 of 2010
Hot dip galvanizing is a listed activity in terms of section 21 of the National
Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires
an Atmospheric Emissions Licence (AEL)
In addition the treatment of wastewater with an annual throughput capacity of more
than 2000 m3 is a listed activity in terms of the National Environmental Management
Waste Act 59 of 2008 and requires a waste management licence
ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental
Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact
Assessment process in terms of section 24 of NEMA for the construction and
operation of the proposed galvanizing plant The EIA process covers all aspects of
the project and informs all three applications (for environmental authorisation waste
management licence and AEL)
13 PURPOSE OF THIS REPORT
This report builds on the scoping report submitted to the Eastern Cape Department of
Economic Development and Environmental Affairs (DEDEA) and the Nelson
Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It
describes the proposed project and presents the findings of the second phase of
investigations (EIA phase)
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP)
The EIA was managed by Ms Terry Baker a certified Environmental Assessment
Practitioner with 20 years of working experience She has a MA in Environmental
Management and specialises in Environmental Impact Assessments and Project
Management She has been involved in a variety of different types of EIAs including
for water supply projects dams transmission lines roads and airports in South
Africa Botswana Uganda Lesotho and Mozambique She has been involved in
water resource management and public participation programmes on a number of
projects Terry has also been involved in the use of Geographic Information Systems
environmental status quo reports water quality assessments socio-economic and
institutional development projects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-3
15 PROJECT TEAM
In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen
(water quality specialist) and Lea September (EAP) with specialist input from Renee
von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous
substances) and Seniel Pillay (Traffic Impact Assessor)
The Business Unit Head of the ILISO Environmental Management Discipline Group
Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is
a Fellow of the South African Institution of Civil Engineers a member of the South
African Society of Aquatic Scientists of the Environmental Scientific Association of
the International Water Association of the Water Institute of South Africa and of the
Vaal River Catchment Association He is a certified Environmental Assessment
Practitioner with 30 years experience who specialises in project management
environmental impact assessments and water resource planning He specifically has
extensive experience in water quality especially water quality management water
quality monitoring and water quality assessment Martin has experience in managing
projects that involve multi-disciplinary teams and public consultation and
participation in South Africa and abroad
Lea September is an Environmental Assessment Practitioner with a Masters degree
in Environmental Management She has experience in impact assessment and
environmental management and has been responsible for drafting impact
assessment reports and Environmental Management Programmes and conducting
public participation processes as well as high level environmental screenings for a
variety of projects in the energy water transport and industrial sectors
Renee von Gruenewaldt has nine-years experience in the field of air pollution
impact assessment and air quality management Prior to becoming involved in air
quality consultation she was part of the Highveld Boundary Layer Wind Research
Group based at the University of Pretoria Since joining Environmental Management
Services (the company now Airshed Planning Professionals) she has undertaken
numerous air pollution impact studies and has provided extensive guidance to both
industry and government on air quality management practices
Pieter Smuts graduated as a Civil Engineer and became involved in the field of
municipal engineering and infrastructure construction He has specialized during the
last twelve years in solid waste management He has completed waste management
plans feasibility studies and final designs of waste management facilities in South
Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and
the review of the Mavoco hazardous waste landfill design in Maputo Mozambique
and completed a study on hazardous waste (textile factory sludge) management in
Maseru Lesotho
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-4
Seniel Pillay is a transportation engineer with over 16 years experience in
transportation planning and traffic engineering He has been involved in a wide
range of projects ranging from developing the Transport Operations Plan for the
FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System
for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller
traffic impact assessments for inter alia road improvement schemes Of particular
relevance to this project his experience includes Heavy Goods Vehicle Study for
eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact
Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash
Preliminary Transportation Assessment
16 STRUCTURE OF THIS REPORT
The proposed project and the alternatives considered are described in Chapter 2
Chapter 3 details the approach adopted for the EIA phase
The biophysical and socio-economic environment affected by the activity is described
in Chapter 4
The environmental impacts identified are discussed in Chapter 5
The EIA methodology is described in Chapter 6 and Chapter 7 presents the results
of the impact assessment
The environmental impact statement is presented in Chapter 8
Finally Chapter 9 spell out the conclusions and recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-1
2 DESCRIPTION OF THE PROPOSED PROJECT
21 TECHNICAL ASPECTS
211 The galvanizing process
Galvanizing consists of coating steel with zinc in order to protect it from corrosion
Before steel strips can be galvanized they undergo a pre-treatment in order to
ensure that the steel sheets are free from any surface oxides as they enter the
molten zinc coating Bath This is done by removing the oil from the steel sheets (in
the degreasing unit) and then removing the rust from the surface of the sheet (in the
pickling unit)
The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The
melting zinc on the strip surface will be cooled and solidified through air cooling in the
cooling tower
Finally the galvanised steel sheets are dipped into a water quenching tank in order to
further cool the sheets from about 150degC to 40degC
It is possible to make galvanised steel more durable by chromating it Approximately
50 of the galvanised steel production output will receive chromate passivation
treatment after quenching the galvanised steel sheets will be sprayed with a chrome
solution (3 kgcm2)
After galvanizing and chromating the steel sheets are cut to achieve the desired coil
size and weight and transported to the storage yard
The process flow diagram below (Figure 1) illustrates the main stages of the
galvanizing process and indicates the major inputs and outputs as well as the
resulting effluent and atmospheric emissions
Draft Environmenal Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-2
Figure 1 Process flow diagram for proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-3
212 Main inputs and outputs in operational phase
In view of the above the main inputs will be as follows
Steel coils 85 000 tonsyear
Zinc 870 tonsyear
Electricity 2500 kVA
Water 2000 m3month (of which 400 m3 will be potable water)
Liquid Natural Gas (LNG) 270 NM3hour
Sodium hydroxide (NaOH) 1000 m3year
Hydrochloric acid (HCl) 800 m3year
Chrome (Cr+3) 10 m3year
The main outputs will be
Galvanized steel 80 000 tonsyear
Scrap metal 20 tonsyear
General waste 65 tonsyear
Hazardous waste 2 m3month
Wastewater 012 Mlweek
Atmospheric emissions lt 5 ppm
213 Installations on site
The bulk of the operations involved in the galvanizing process occur along a
continuous galvanizing line (See Figure 2 below) which is the main piece of
machinery required for the proposed galvanising plant
Figure 2 Continuous Galvanizing Line
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-4
Water is one of the major inputs and is used throughout the galvanizing process notably
for rinsing and cooling purposes and as a mixing agent for the various chemical
solutions The plant will have a water treatment plant on site to treat the water used in
the various processes (approx 250 m3
of wastewater per week) The wastewater
treatment facility will be operated by a professional water treatment company as Casa
Steel does not have the required expertise in house to treat its process water Sulphuric
acid (H2SO4) is used as part of the treatment process to reduce caustic soda The
neutralised water is discharged to the sewer while any sludge is disposed of as
hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)
will be disposed of
Some critical areas of the galvanizing process such as the zinc pot require uninterrupted
power It is therefore proposed to install an LNG burner to maintain the zinc bath at a
temperature of between 450 and 460degC
22 LOCATION OF THE PROPOSED GALVANIZING PLANT
The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast
of Port Elizabeth in the Eastern Cape (Figure 3)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-5
Figure 3 Location of the proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-6
23 NEED AND DESIRABILITY
The profitability of the proposed project has been established by Casa Steel and a
pre-feasibility study has confirmed that the proposed project was feasible from a
technical and financial point of view The Coega IDZ is specifically designed to host
facilities such as a galvanizing plant and can provide the necessary infrastructure
and services to its investors It therefore constitutes a very suitable location for the
project
24 ALTERNATIVES IDENTIFIED
Zone 6 has been specifically earmarked for heavy ferrous metal industries and is
therefore a suitable location for the proposed galvanizing plant as such no site
alternatives have been provided for and assessed in this EIA However prior to the
commencement of the EIA process Casa Steel was presented with a number of
different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the
selection of the site were
(a) The dimensions of the land the site should be at least 200 m long and
50 m wide in order to accommodate the galvanizing line and adjacent lay
down area and additional land should be available next to the site for future
expansion
(b) The fiscal arrangements applying to the site the site should be located
within the future Custom Controlled Area (CCA) as the bulk of the
production output of the plant will be exported
The no-go alternative is assessed in this report
25 CONSTRUCTION ASPECTS
The construction phase of the project will take about 12 months and will essentially
consist of erecting a building to house the galvanizing line and other equipment and
preparing a concrete laydown area adjacent to the building
The CDC will provide an access point from the existing tarred road that will lead to
the site
Approximately 100 workers from the surrounding areas will be contracted for the
construction work
The requirements in terms of services during construction are listed below
Water 1000 m3month
Electricity 2500 kVA
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-7
The CDC will provide temporary services for the construction phase including a
conservancy tank for flush toilets Sewage infrastructure will only be provided for the
operational phase
26 OPERATION ASPECTS
Before the plant can become fully operational the equipment and machinery will be
tested for approximately 3 months The supplier will supervise these tests as part of
the transfer of know-how and training of staff on the plant
Casa Steel will start operating the plant at a reduced capacity (about 50 000
tonsyear) for a period of time (mostly determined by market aspects) before bringing
production to full capacity (80 000 tonsyear) This is done by operating the line for
longer hours
Approximately 50 to 60 people will be working on the plant Approximately 6-10 of
these will be unskilled 40-45 skilled and about 5 people in managerial positions
The requirements in terms of services during operation are as follows
Water 2000 m3month
Electricity 2500 kVA
Effluent discharge 24 m3day
The CDC has entered into agreements with the municipality to secure the provision
of services such as water and electricity to its tenants Tenants in the IDZ have their
own agreements with the NMBM for electricity while the agreements for water and
sewage are with the Facilities Unit of the CDC
Regarding discharge of wastewater to the sewer the municipality indicated that the
only requirement is that the water discharged complies with applicable municipal
discharge standards
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 3-1
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT
31 OBJECTIVES
The main objectives of the EIA phase are to
Assess the significance of the environmental issues and impacts identified in the
scoping phase focusing on key impacts
Recommend appropriate measures to mitigate negative impacts and enhance the
benefits and include them in the draft EMP
Undertake a public participation process that provides opportunities for all
interested and affected parties (IampAPs) to be involved
32 AUTHORITY CONSULTATION
The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental
Liaison Committeersquo (ELC) which comprises representatives of various authorities
including DEDEAT the Department of Environmental Affairs (DEA) and Department
of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the
Coega Development Corporation (CDC) and Transnet National Ports Authority
(TNPA) The ELC has been specifically formed to facilitate EIA applications in the
IDZ
Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to
the clearance of vegetation should be included in the application A formal request
was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the
application and all registered stakeholders were informed of the request in writing on
19 October 2011
33 PUBLIC PARTICIPATION PROCESS CONDUCTED
On-site notices were replaced by a notification displayed on the CDCrsquos digital notice
board at the business centre in Zone 1 of the IDZ The eNotice was placed on
13 April 2011 and will remain for the full duration of the EIA process
Registered stakeholders will be notified in writing of the availability of the draft EIA
report and EMP which will also be advertised in a local newspaper Stakeholders
including state departments and the public will have forty (40) days to comment on
the draft EIA report and EMP The draft EIA report and EMP will be sent by email
where possible and made available for download on the ILISO website
(wwwilisocom)
A summary of all issues and comments received during the stakeholder consultation
process as well as of correspondence in that regard will be captured in an Issues
and Responses Report that will form an Appendix to the EIA Report
The list of registered IampAPs is included in Appendix A
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 3-2
34 LEGISLATION AND GUIDELINES CONSIDERED
The following legislation and guidelines were considered in the preparation of this
report
National Environmental Management Act Act No 107 of 1998
NEMA EIA Regulations 2010
National Environmental Management Air Quality Act Act No 39 of 2004
National Environmental Management Waste Act Act No 59 of 2008
Hazardous Substances Act Act 15 of 1993
Occupational Health and Safety Act Act 85 of 1993
Hazardous Chemical Substances Regulations 1995 (GNR 1179)
Major Hazard Installation Regulations 2001 (GNR 692)
National Water Act Act 36 of 1998
National Heritage Resources Act Act 25 of 1999
DEAT Integrated Environmental Management Information Series 1-5 and 12-15
NEMA draft Implementation Guideline
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Public Participation (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Alternatives (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Draft Guideline for Determining the Scope of Specialist
Involvement in EIA Processes (2005)
IAIA guidelines
National air quality standard for thoracic particulates Government Gazette
No 32816
Listed activities and associated minimum standards identified in terms of section
21 of the National Environmental Management Air Quality Act Act No 39 of
2004 Government Notice 248 of 2009
Minimum Requirements for the Handling Classification and Disposal of
Hazardous Waste DWAF Waste Management Series (1998)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-1
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION
The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega
IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay
to the north of the N2 highway between Port Elizabeth and Grahamstown east of the
Coega River
The co-ordinates of the corners of the site are shown in Table 1
Table 1 Coordinates of site corners for the proposed galvanizing plant
Point Longitude Latitude
A 25deg411126E 33deg45587S
B 25deg411156E 33deg45499S
C 25deg411938E 33deg45131S
D 25deg412174E 33deg45481S
E 25deg412508E 33deg45979S
F 25deg412634E 33deg451160S
G 25deg411782E 33deg451560S
H 25deg411692E 33deg451428S
J 25deg411314E 33deg45868S
Figure 4 Zone layout in the Coega IDZ
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-2
Figure 5 Site location
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-3
42 SOCIO-ECONOMIC CHARACTERISTICS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the
NMBM There are no residents within the IDZ
As far as the broader NMBM and Eastern Cape Province are concerned the
following can be noted The NMBM is located within the Eastern Cape Province the
2nd largest Province in South Africa (3rd in terms of population) characterised by a
predominantly black population with low incomes and high levels of unemployment
(CES 2010)
The NMBM has a population of just above 11 million and covers an area of
1 950 km2 It is the main urban and industrial centre of the province and Port
Elizabeth in particular which forms part of the NMBM is the commercial capital of
the Eastern Cape 52 of the NMBM population is female and 37 is below the
age of 20 these two groups are particularly affected by unemployment
43 BIOPHYSICAL CHARACTERISTICS
431 Surface and ground water
No rivers occur in Zone 6 There is however a natural attenuation pond on the
southern most part of the site which will have to be avoided
The IDZ is underlain by calcrete sand and gravel deposits that overlie low
permeability clays These clays limit the vertical infiltration of rainwater and induce a
horizontal groundwater flow towards the Coega River channel which is the most
significant surface water feature in the Coega IDZ Consequently rapid run-off takes
place following precipitation (Jacobs 2008)
Groundwater levels at Coega are generally about 3 to 5 m below surface ie just
above the contact between the permeable sands and the underlying impermeable
clays The groundwater flow direction is to the southeast following the surface water
drainage direction (Jacobs 2008)
432 Climate and atmospheric conditions
Port Elizabeth has a warm temperate climate and the temperature ranges are not
extreme Exceptionally high temperatures may be experienced during berg wind
conditions which occur frequently during autumn and winter Extreme temperatures
also occur during summer with little accompanying wind
The wind regime for the area largely reflects the synoptic scale circulation with
dominant westerly and northwesterly flow fields representing the pre-frontal
conditions and south-westerly flow fields representing the frontal conditions The
south-easterly and south-westerly wind flow (land breeze) increases during daytime
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-4
conditions with westerly and north-westerly wind flow increasing during the night (sea
breeze)
The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of
Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15
km southwest) and Port Elizabeth (~23 km southwest)
An ambient air monitoring network has been established in the Coega IDZ which
consists of three monitors Saltworks Motherwell and Amsterdamplein Although
NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative
impacts due to the proposed Galvanising Plant is PM10 A maximum daily average
PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed
SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3
was exceeded on 17 days in 2007 and 26 days in 2008
Existing sources of emissions in the vicinity of the proposed galvanizing plant include
industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other
fugitive dust sources (von Gruenewaldt 2011b)
433 Geology and soils
Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel
and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly
limestone and conglomerate
434 Terrestrial ecology
This section draws from the EIA report compiled for the Agni Steel (formerly Afro-
Asia) steel processing facility which is adjacent to the proposed site for the
galvanizing plant (Jacobs 2008)
The area consists largely of grasses succulents and scrubby bush with alien
species making up the greater part of the more dense vegetation
Zone 6 falls within the inland vegetation and is characterised by a vegetation type
referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the
Coega IDZ and has been found to have three times the level of endemism of other
vegetation communities in the Coega IDZ Bontveld therefore has a high
conservation status Two Bontveld conservation areas have been identified within the
IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)
Bontveld that will be destroyed as a result of development in the IDZ will be given
conservation status in these two areas
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-5
Figure 6 Coega IDZ Open Space Management Plan (OSMP)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-6
Certain areas in the IDZ are invaded by alien plant species The most common
invader species is rooikrans (Acacia cyclops) which presently forms large
monospecific stands in areas throughout the Coega IDZ There are several other
aliens present that pose a threat to the flora of this area including the prickly pear
(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)
Loss of vegetation and alien plant invasion due to human activity has resulted in a
reduction in the diversity of terrestrial fauna
The majority of mammals present in the Coega IDZ are small or medium-sized Of
the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed
gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of
Algoa Bay however it is not considered threatened The gerbil is common in
foredune and dune thicket habitat in the Coega region and is therefore unlikely to
occur on the proposed site
A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird
species are resident or common to the area Most diversity occurs in the thicket
although the coastal area also supports specialised avifauna Two species of tern
the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well
as the Cape gannet (Morus capensis) and the African penguin (Spheniscus
demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne
caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant
(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser
flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns
are two of the most endangered coastal species in South Africa Other bird species
of conservation concern include the Whitefronted plover (Charadrius marginatus)
African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus
bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus
ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides
paradisea) Breeding pairs of Damara terns and African black oyster catchers have
been observed in the coastal dunes of the IDZ but should not be affected by
developments that fall outside the dune areas
The Eastern Cape supports nearly a third (approximately 133 species) of the reptile
species recorded in South Africa More than half of the Eastern Capersquos endemic
reptile species occur in the Algoa Bay area giving the region a high conservation
value A total of 63 reptile species are believed to occur within the Coega IDZ The
majority of these are found in Succulent Thicket and riverine habitats Only a few
reptile species occur in the coastal dunes and estuarine habitats More than a third of
the species are described as relatively tolerant of disturbed environments provided
that migration corridors of suitable habitat are maintained to link pristine habitats
Twenty two reptiles are of special concern including five endemic species (two of
which may also be endangered) four endangered sea turtles eight species listed
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-7
with CITES one rare species and four species at the periphery of their range
Fourteen of these species of special concern are confirmed as occurring on or within
2 km of the Coega IDZ
A total of 32 amphibian species and sub-species occur in the Eastern Cape
representing almost a third of the species recorded in South Africa However none of
the species are endemic or Red Data Book species Based on previous studies in the
area it is estimated that approximately 17 amphibian species occur within the Coega
IDZ Four species are listed as peripheral but none are threatened internationally
These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog
(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and
the bubbling kassina (Kassina senegalensis)
The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated
vegetation has not been extensively studied One grasshopper species Acrotylos
hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue
(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis
pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in
four localities in the Eastern Cape one of which is within the Coega IDZ The Coega
copper Aloeides clarki is endemic to this particular region of the Eastern Cape and
is currently known to occur in three localities two of which are in the Coega IDZ The
localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the
Coega IDZ and their distributions were taken into account when defining Coegarsquos
open space system and Development Framework Plan
435 Land use and topography
The land is currently undeveloped and earmarked for industrial development The
site is relatively flat ranging from an elevation of 66 masl on the northern-most
corner to 59 masl at the southern-most corner
436 Heritage and archaeological survey
Extensive studies have been undertaken in Zone 6 with respect to heritage aspects
Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a
2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond
2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is
currently being finalised
Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing
Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha
in extent and was located next to the R102 road to Motherwell Kaplan conducted
HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi
Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will
now be located in Zone 5)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-8
The various archaeological investigations reached similar observations and
conclusions Stone tools of various densities and types were found throughout the
zone The majority of the stone tools were mainly of Earlier and Middle Stone Age
and occasional Later Stone Age origins (Figure 4)
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble
gravels exposed by tracks in Zone 6 (Source Binneman 2010)
The stone tools which comprised of quartzite flakes chunks flaked pebblecobble
and cores were randomly distributed across the landscape and are in secondary
context There were no lsquoconcentrationsrsquo of tools observed which suggested any
spatial patterning or activity areas although these may be present or covered by soil
and vegetation
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 5-1
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED
The following environmental issues and potential impacts were identified in the
Scoping phase
51 AIR QUALITY
The galvanizing process generates atmospheric emissions with particulates and
hydrogen chloride representing the main pollutants of concern The plant is fitted with
air extraction as well as scrubber systems which are designed to retain the bulk of
pollutants and particles for each of the processes in such a way that less than 5 ppm
of gases and particles will be released into the atmosphere after the fume scrubber
Other sources of impact on air quality include emissions from the LNG burner as well
as emissions and dust from the transport of steel and other materials in trucks
Construction activities will also create dust and gas emissions due to the clearing of
groundcover tipping of material to storage pile levelling of area wind erosion from
storage piles vehicle and construction equipment activity and tailpipe emissions
from vehicles and construction equipment such as graders scrapers and dozers
Overall the air quality impact assessment (Gruenewaldt 2011b) found that
The predicted particulate oxides of nitrogen carbon monoxide and sulphur
dioxide concentrations are all below the National Ambient Air Quality Standards
for all averaging periods
The predicted off-site concentrations of hydrogen chloride are well below the
most stringent effect screening levels
No odour threshold exceedances for hydrogen chloride were predicted to occur
due to routine operations at the Steel Galvanising Plant The South Wales
Environmental Protection Authority stipulates that an odour unit of 20 is
acceptable for urban areas The odour unit would be lt10 directly off-site for
hydrogen chloride
Abnormal emissions can occur in exceptional circumstances Start-up will not
cause abnormal emissions as the scrubbers will be commissioned first and will be
functioning once the plant starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions would be emitted as a
building fugitive
The hourly hydrogen chloride ground level concentrations (directly offsite) were
predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based
on the emission limits as stipulated for listed activities for galvanising processes)
using a screen model which assumes worst case meteorological conditions The
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-2
health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming
abnormal emissions emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset conditions will still
be well within the health effect screening levels
Similarly the hourly particulate emissions from the building fugitives during upset
conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for
listed activities for galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly
off-site
Therefore if emissions are 5 times higher normal they will still be within health effect
screening levels and the daily PM10 NAAQS levels
In the case of a fire a cocktail of gases and particulates could be emitted and could
be over the recommended levels This situation will however be dealt with as an
emergency and normalised as quickly as is possible
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS
The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of
its heritage potential and there are no proposed protected geosites in Zone 6
Should any artefacts be discovered during construction procedures stipulated in the
draft EMP will apply
53 BIODIVERSITY AND CONSERVATION
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
In terms of terrestrial fauna the CDCrsquos open space management plan provides for
the preservation of certain corridors The destruction of certain habitats as a result of
the development will therefore not automatically result in the loss of certain species
54 WATER QUALITY
There is a natural attenuation pond on the southern most part of the site which will be
avoided
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through
spills or leaks
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-3
This risk can however be minimized if not avoided altogether The floor of the factory
will be designed as a bunded area to contain any spills and the entire process will be
contained Potential spills or leaks will therefore be contained and will not impact on
water resources Storm water is therefore considered clean water under normal
operational conditions An oil trap will be placed at the exit of the site to ensure that
no grease from the laydown area enters the stormwater system
Spills and leaks can occur during the handling or the transport of hazardous
substances Best practice guidelines will be followed to ensure that this risk is
adequately managed
Wastewater discharged to sewer will be treated to comply with municipal discharge
standards and is not expected to have an impact on the chemical characteristics of
the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be
discharged from the plant is small in relation to the total volume received at the
Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works
(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently
operated at 61 of its capacity which is approximately 80 Mℓday Thus the
0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore
not have any significant impact on the WWTW
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES
The plant will generate a relatively small amount of solid waste in the form of scrap
metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)
The scrap metal may be sold to other steel processing facilities such as Agni Steel
which will be located next to the plant or collected and disposed of with the rest of
the solid waste by a licensed service provider
As mentioned previously there will be a wastewater treatment plant on site which will
neutralise process water (012 Mlweek) in order to ensure it is of a standard
acceptable for discharge to sewer Waste in the form of sludge from the
neutralization or spent acid must be disposed of as a hazardous waste Solid waste
from the filters used for air quality control is also in this category These wastes can
usually be tested and then delisted which means that it can be placed in a general
purpose landfill
Hazardous effluent from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-
site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored
and removed on a monthly basis is limited to 10 m3
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-4
A number of substances classified as hazardous are used in the galvanizing process
(Table 2) and the transport and handling of these is subject to certain rules and
guidelines In particular the material safety data sheets (cf Appendix H) should be
referred to for inter alia hazards identification accidental release measures
handling and storage precautions exposure controlpersonal protection ecological
information and transport information The Hazardous Chemical Substances
Regulations 1995 should also be adhered to in respect of the transport and storage
of hazardous chemical substances
Table 2 Hazardous materials to be used on site
Major Input Materials
Substance
listed in the
SABS 0228
Group II
hazardous
substances
Volumes to be
stored on site at
any one time
Diesel radic 2000 litres
Liquid petroleum radic 20 000 liters
Sodium hydroxide (NaOH)
(used for degreasing) 8 radic 1000m
3
Hydrochloric acid (HCI)
(used for pickling) 8 radic 800m
3
Zinc (used for galvanising) - TBD
Trivalent chromium (CR+3
)
(used for chromating) 8 radic 10m
3
Sulphuric acid (H2SO4) (used for
treatment of waste water on site) 8 radic TBD
Ammonium Hydroxide (NH4OH) 8 radic TBD
TBD ndash To be determined
Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one
time) and is classified as a flammable substance Specification for flammable storage
facilities in accordance with the requirements of the Nelson Mandela Bay
Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for
quantities between 5000 and 20 000 liters the substance must be kept in a
flammable liquid store which complies with the requirements of a specification
obtainable from the Department Some of the requirements are
Flammable liquid and solid storage facilities are only permitted on the ground
floor
Decanting of flammable liquids and solids are not permitted within any building
Due to the fact that there are flammable materials on site a certificate may be
required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and
Emergency Services Department to confirm that facilities for flammable storage
are in accordance with their requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-5
Because of the permanent installation and high quantity of liquid petroleum on site
the Major Hazard Installation Regulations 2001 promulgated under the Occupational
Health and Safety Act No 85 of 1993 applies A written application for approval of
the installation is required to be submitted to the chief inspector Department of
Labour provincial director Department of Labour and NMBM prior to construction
In addition a risk assessment should be formulated covering all hazardous materials
together with an emergency preparedness and response plan
56 HEALTH AND SAFETY
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling instructions as well as occupational exposure limits
are indicated in the material safety data sheets of the various substances used
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as
provide site supervision including executing tests (individual test cold run and hot
run) during 3 months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the
EMP
In addition the emergency preparedness and response plan will cover the health and
safety aspects related to emergency situations
57 TRAFFIC
The volumes of traffic at the IDZ are currently relatively low and variable depending
on the different zones in the IDZ however these volumes will increase as more
developments are implemented
The construction phase of the Casa Steel development will take about 12 months
and will essentially consist of erecting a building to house the galvanizing line and
other equipment and preparing a concrete laydown area adjacent to the building
The traffic that would be generated during the construction phase can be expected to
be less than the traffic that would be generated by the Casa Steel development when
it is fully operational
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-6
In the operation phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and
from the Port of Ngqura
The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the
Casa Steel development would be off Ring Road 1 The other roads of significance
for the Casa Steel development are the N2 Neptune Road MR435 and MR450
Access to the port is given by Neptune Road Road Link NEP-03 has not yet been
built
Figure 8 Coega IDZ road network identification
(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-7
Figure 9 Coega IDZ road network
Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No
01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-8
The distribution of freight trips is fixed as the majority of trips will be made between
the Port of Ngqura and the Casa Steel site With regard to personnel trips there are
various points of origins (the surrounding residential areas) that could be used by
staff going to the Casa Steel site The distribution of personnel trips is based on
existing traffic count information and is shown in Figure 10
Figure 10 Trip distribution for freight and personnel trips
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The resultant expected Casa Steel traffic assignment is shown in Figure 11
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-9
Figure 11 Morning peak hour Casa Steel development traffic
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The traffic that is expected to be generated by the Casa Steel development is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low
and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)
Consultation has taken place with Transnet Port Authority (TPA) to establish the
impact of the galvanizing plant operations on traffic inside the port The additional
ships entering and exiting the port of Ngqura as a result of the proposed development
will have a negligible impact on port traffic and TPA indicated that it would be well
within the portrsquos capacity
58 NOISE
Noise is not foreseen to be a significant issue insofar as the noise levels inside the
plant and at the boundary of the site will not exceed the limits prescribed by the CDC
Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels
during the day and 60 decibels at night
Mitigation of noise impacts will be addressed in the design of the noise-emitting
components of the plant and their enclosures
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-10
59 SOCIO-ECONOMIC ASPECTS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of
NMBM There are no residents within the IDZ
The direct socio-economic impacts of the proposed project are thus limited to the
employment generated by the project during construction and operation Job creation
remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)
and the IDZ and Port of Ngqura are expected to become a significant catalyst to the
economic growth of the Municipality and the region with current investments at
Coega creating more jobs and stimulating the economy
In this context the proposed galvanizing plant will make a positive contribution
towards the achievement of these goals
There will be 50 to 60 employees during operation phase distributed as follows
Figure 12 Casa Steel organisation chart
Even though a large part of the inputs will be imported and the bulk of the production
output will be exported there will be some positive impacts for the economy of the
region and of South Africa in general Notably the requirements of the plant for
water electricity waste collection and disposal waste water treatment and transport
for example will create business for the various service providers and have an
indirect impact on employment and fiscal revenues as a result
From a visual impact point of view it can be anticipated that the landscape in the IDZ
will be significantly affected over time by developments related to the establishment
of the port and various industries
HEAD ( WORKS )
MGR ( COMM) MGR ( ADMNHR ) Manager marketing
MANAGER OPERATION MANAGER MANAGER MANAGER Q C
AC FIN PUR ampSTORE
PPC SH-GALV SH-tech
SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF
1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO
JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF
2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO
WORKERS WORKERS 7NOS
15 7
RAW MAT amp
DESP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 6-1
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
A description of the nature of the impact any specific legal requirements and the
stage (constructiondecommissioning or operation) will be given Impacts are
considered to be the same during construction and decommissioning The
significance of the potential impacts will be considered before and after identified
mitigation is implemented
The following criteria will be used to evaluate significance
Nature The nature of the impact will be classified as positive or negative and
direct or indirect
Extent and location Magnitude of the impact and is classified as
Local the impacted area is only at the site ndash the actual extent of the activity
Regional the impacted area extends to the surrounding immediate and
neighbouring properties
National the impact can be considered to be of national importance
Duration This measures the lifetime of the impact and is classified as
o Short term the impact will be for 0 ndash 3 years or only last for the period of
construction
o Medium term three to ten years
o Long term longer than 10 years or the impact will continue for the entire
operational lifetime of the project
o Permanent this applies to the impact that will remain after the operational
lifetime of the project
Intensity This is the degree to which the project affects or changes the
environment and is classified as
o Low the change is slight and often not noticeable and the natural functioning
of the environment is not affected
o Medium The environment is remarkably altered but still functions in a
modified way
o High Functioning of the affected environment is disturbed and can cease
Probability This is the likelihood or the chances that the impact will occur and
is classified as
o Low during the normal operation of the project no impacts are expected
o Medium the impact is likely to occur if extra care is not taken to mitigate
them
o High the environment will be affected irrespectively in some cases such
impact can be reduced
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 6-2
Confidence This is the level knowledgeinformation the environmental impact
practitioner or a specialist had in hisher judgement and is rated as
o Low the judgement is based on intuition and not on knowledge or
information
o Medium common sense and general knowledge informs the decision
o High Scientific and or proven information has been used to give such a
judgment
Significance Based on the above criteria the significance of issues will be
determined This is the importance of the impact in terms of physical extent and
time scale and is rated as
o Low the impacts are less important
o Medium the impacts are important and require attention mitigation is
required to reduce the negative impacts
o High the impacts are of great importance Mitigation is therefore crucial
Cumulative Impacts The possible cumulative impacts will also be considered
Mitigation Mitigation for significant issues is incorporated into the EMP for
construction
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 7-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS
71 IMPACTS DURING CONSTRUCTION
711 Air quality
Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris
handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine
particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural
operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks
and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)
Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Fugitive particulate emissions (dust)
related to construction activities Regional
Short
term Medium High High Medium Regional
Short
term Low High High Low
Construction vehicle gas emissions Regional Short
term Medium High High Medium Regional
Short
term Low High High Low
712 Heritage and archaeological resources
Naturedescription of impact excavation activities may impact on unidentified heritage resources
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-2
Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based
on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments
Heritage and archaeological
resources Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on unidentified heritage
resources Local
Short
term
Medium -
high Low High Low
713 Biodiversity and conservation
Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation
importance and cause soil contamination
Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species
Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan
and has compiled a list of protected species to be rescued (see draft EMP)
Biodiversity and conservation Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Loss of fauna and flora Local Perma
nent
Medium -
high High High High Local
Permanen
t Medium High High Medium
Soil contamination Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-3
714 Water related impacts
Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater
runoff spills and leaks Soil erosion
Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of
spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste
disposal Stormwater quality monitoring (see draft EMP)
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Soil erosion Local Short
term Medium Medium High Medium Local
Short
term Medium Low High Low
715 Waste management
Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed
Commentmitigation see draft EMP and waste management plan
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-4
Waste management Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Local
Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
716 Health and safety
Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Short
term
Medium -
high
Medium -
high High High Local
Short
term
Medium -
high Low High Low
717 Traffic
Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and
construction workers from surrounding areas and transport of equipment from the port
Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low
Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and
accurate estimates of quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-5
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Increased traffic on N2 and within the
IDZ Regional
Short
term Low High High Low
718 Noise
Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Short
term
Medium-
high High High Medium Local
Short
term Medium High High Medium
719 Socio-economic
Naturedescription of impact temporary employment will be created during the construction phase
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-6
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Temporary employment Regional Short
term Medium High High Medium
72 IMPACTS DURING OPERATION
721 Air quality
NatureDescription of impact gas and particulate emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning
Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local
sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and
veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute
to background fine particulate concentrations (von Gruenewaldt 2011b)
Assumptions and limitations Potential release of CR6+
As no emission factors are available for trivalent chromium processing the
potential impacts due to these activities could not be quantified
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Dust emitted from traffic on paved roads Regional Long Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-7
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
term
Hydrogen chloride emissions from
pickling process Local
Long
term Low High High Low
Particulate emissions (smoke) from
galvanizing process (due to the
volatilization of flux)
Local Long
term Low High High Low
Particulate oxides of nitrogen carbon
monoxide and sulphur dioxide emissions
from LNG burner
Local Long
term Low High High Low
Nuisance related to odour Local Long
term Low Low High Low
Abnormally high hydrogen chloride and
particulate emissions due to scrubber
malfunction
Local Short
term Medium Low High Medium
Gases (eg SOx NOx CO etc) and
smoke emitted in case of a fire Local
Short
term High Low High Medium
722 Water quality
NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks
Commentmitigation see draft EMP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-8
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Stormwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
723 Waste management and hazardous substances
NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous
waste both can affect environmental quality and human health
Commentmitigation see draft EMP and waste management plan
Waste management and hazardous
substances Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Regional
Long
term High
Medium -
high High High Regional Long term High Low High Low
Soilwaterair pollution due to improper
transport storage and handling of
hazardous substances
Regional Long
term High
Medium -
high High High Regional Long term High Low High Low
Health hazard Local Long
term High
Medium -
high High High Local Long term High Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-9
724 Health and safety
Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Long
term
Medium-
high
Medium-
high High High Local Long term
Medium-
high Low High Low
725 Traffic
Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on
the road network
Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak
hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road
network within Zone 6 of the IDZ (Iliso 2011)
Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)
Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of
quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-10
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on traffic and capacity of the N2 Regional Long
term Low High High Low
Impact on traffic and capacity of ring
road 1 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR435 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR450 Local
Long
term Low High High Low
Impact on traffic and capacity of
Neptune road Local
Long
term Low High High Low
726 Noise
Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Long
term Medium High High Medium Local Long term Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-11
727 Socio-economic
Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate
revenue for the municipality and the region as a whole
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Employment and economic growth Regional Short
term Medium High High Medium
73 COMPARATIVE ASSESSMENT OF IMPACTS
During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as
low during operation after mitigation
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 8-1
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
As a tenant operating in the IDZ Casa Steel will be required to comply with all
current and future CDC requirements as well as with the relevant conditions of
permits licences issued to CDC (eg Integrated Stormwater Masterplan for the
eastern side of the Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)
In particular the CDC has its own requirements regarding the monitoring of certain
aspects of the project such as the quality of the effluent and the noise levels These
have been incorporated into the EMP
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 9-1
9 ENVIRONMENTAL IMPACT STATEMENT
All predicted negative impacts can be mitigated to a low significance The only
exceptions are biodiversity as the construction of the plant will result in the
destruction of habitat and loss of fauna and flora and noise impacts inherent to
construction activities Mitigation measures have been included in the EMP for these
impacts and they have a medium significance post-mitigation
Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium to
long term similar impacts are likely to occur due to ongoing developments in the IDZ
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 10-1
10 CONCLUSION AND RECOMMENDATIONS
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as
other infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified
and assessed No fatal flaws have been identified
It is recommended that the project be approved subject to the conditions listed in
chapter 9 and adherence to the EMP requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 11-1
11 REFERENCES
Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ
Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants
Bennie JS (2010) The historical component (built environment) of the Heritage
Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port
Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report
compiled for Eastern Cape Heritage Consultants
Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater
Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay
Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage
Consultants
BKS (2006) Coega Industrial Development Zone Transport Study Volume 3
Demand Modelling Report Final Draft
Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I
Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6
Report compiled for SRK Consulting
Coastal amp Environmental Services (2010) Environmental Impact Assessment for the
Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone
Volume 3 Environmental Impact Assessment Report CES Grahamstown
Coega Development Corporation (2008) Industry Waste Management Plan -
Strategic Master Plan Report
Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants
Report No CDCSHE 03 8122
Department of Water Affairs and Forestry (1998) Waste Management Series
ldquoMinimum Requirements For The Handling Classification And Disposal Of
Hazardous Wasterdquo Second Edition
Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising
Plant in the Coega Industrial Development Zone
Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the
Coega Industrial Development Zone (IDZ) Specialist Water Study
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 11-2
Jacobs E (2008) Final Environmental Impact Report and Draft Environmental
Management Plan Proposed Steel Recycling and Processing Facility within the
Coega IDZ Report compiled for SRK Consulting
Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY
Galvanising Plant in the Coega Industrial Development Zone Waste Management
and Hazardous Substances Report compiled for ILISO Consulting
RSA National air quality standard for thoracic particulates (PM10) SA standards
(Government Gazette No 32816)
von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed
Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape
Report compiled for ILISO Consulting
von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel
Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report
compiled for ILISO Consulting
Additional sources
Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed
Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared
for Coastal Environmental Services
Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed
Kalagadi Manganese smelter in the Coega Industrial Development Zone Port
Elizabeth Eastern Cape Province Report prepared for Coastal Environmental
Services
Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia
steel recycling facility at the Coega Industrial Development Area Port Elizabeth
Prepared for SRK Consulting Port Elizabeth
APPENDIX A
LIST OF INTERESTED AND
AFFECTED PARTIES
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
DEDEARegional Manager
and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza
DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza
DEA Ocean and
CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza
DEA Ocean and
Coast
Oceanographer land-
based sources of
marine pollution
Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza
DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza
CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza
CDCEnvironmental
Project
Manager
Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza
TNPAPort of Ngqura
Environmental
Manager
Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet
NMBMEnvironmental
ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza
NMBMEnvironmental
ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza
DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza
DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza
WESSASenior Conservation
Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza
Zwartkops
ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700
hughlauegmailcom
zwartkopstrustiafricacom
SANParksNational Marine
CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza
Department Of
LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza
NMBM Air Quality
Division
Assistant
DirectorAir
Pollution and Noise
Templeton Titima 079 490 0574 Ttitimamandelametrogovza
NMBM Air Quality
DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza
NUMSARegional
RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
Department of
HealthNadiema
van der
Bergh083 378 2103
nadiemavanderberghimpiloecprovgov
za
DWA Chief Services
Officer
Joseph Jacobs 041 586 4884 jjacobsdwafgovza
EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza
NUMSecretary of union
officesZandile Xhentsa 043 743 6597 zxhentsanumorgza
DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza
Dynamic
CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom
EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza
Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza
UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom
lprincezago2uticom
Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza
Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza
Absa Mr Johann Steyn 082 3775820 johannstabsacoza
Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza
PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza
Universal
EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza
Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza
GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom
Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza
NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom
DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza
DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza
TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet
DWA Mr Landile Jack JackLdwagovza
DWA Ms Lizna Fourie FourieL4dwagovza
APPENDIX B
NOTICE OF ATMOSPHERIC
EMISSIONS LICENCE APPLICATION
AND ADVERTISEMENT
APPENDIX C
NOTICE OF COMMENT PERIOD FOR
DRAFT SCOPING REPORT
APPENDIX D
SUMMARY OF ISSUES RAISED AND
RESPONSES THERETO
April 2012
1
PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL
DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))
IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt
AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt
This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses
provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process
conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the
Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
2
IssueCommentQuestion Date
received Origin Response
1 Please provide more information with respect to the potential
dangers including the toxicity of the proposed project
07032011
By email
Wayne Poulton
(Bosun Brick
tenant at the
IDZ)
An Environmental Impact Assessment (EIA) was undertaken
which assessed the potential toxicity of the emissions and
effluent Mitigation measures were also recommended in the draft
Environmental Management Programme (EMP) to avoid
minimise or compensate any significant impacts The Draft
Environmental Impact Report and draft EMP were made available
to stakeholders for comment in March 2012
2 Do you have a Background Information Document (BID) or
similar that provides more information on the project
27032011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The BID was sent to all registered IampAPs on 4 May 2011
3 The RoD issued to the CDC on 632007 for the change in
land use for the remaining area of the Coega IDZ includes a
number of requirements with respect to
atmospheric emissions that should be considered in the
Atmospheric Emissions Licence (AEL) application such as
prohibiting and monitoring where possible visible emission
plumes to the atmosphere In particular the
recommendations on pp87-91 of the final revised Scoping
Report dated Nov 2006 must be implemented (clause 421)
04042011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
We have obtained copies of the documents referred to and ensure
that these requirements were taken into account in the
environmental assessment and AEL application
4 If the Port of Ngqura is used for import and export the scope
of the traffic impact assessment (TIA) should also include the
port
10052011
By email
Elliot
Motsoahole
(TNPA Port of
Ngqura)
The scope of the TIA was extended to include port related traffic
The TNPA at the Port of Ngqura was consulted and does not
have any objection to the project TNPA has indicated that the
development would require a minimum number of vessels per
year which would have minimal impact on the Port operations
However due notice would have to be given to the Port of Ngqura
before a vessel is scheduled to arrive so that the vessel can be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
3
IssueCommentQuestion Date
received Origin Response
accommodated at an available berth
5 Concerns with respect to potential stormwater pollution
draining into the Coega catchment and the port of Ngqura
The port needs to be dredged and heavy metals present a
risk in that regard
16052011
By
telephone
Andrew Lucas
(Department of
Water Affairs)
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination by effluent waste or
hazardousdangerous substances is very low
Thus no metals oils or other contaminants are expected to be
present in the stormwater
However stormwater pollution can occur in exceptional
circumstances such as accidents and emergencies The
emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
6 All steel sheets bathing unit must be under roof
7 The sludge out of the decreasing bath will be high in Na and
pH Therefore handling and disposal must be clarified up front
in this project
8 Per se the wastewater from decreasing bath will have high
ph and the component from the pickling unit will have low ph
Then it may be assumed that both streams will neutralize
each other Please then clarify proposed sewer discharge
with Nelson Mandela Bay Municipality up-front for acceptance
of influent as per the documented proposal
9 Pickling may result in dissolved metals How does your team
expect to deal with this As it is planned for discharge into
24052011
By email
Landile Jack
(Department of
Water Affairs)
All bathing units will be under roof
Effluent from the degreasing and pickling baths will be discharged
to the wastewater treatment plant The respectively alkaline and
acidic effluents will mix and neutralise each other in the
wastewater treatment plant Calcium or gypsum will be added if
required to complete the neutralisation process Effluent from the
treatment plant will be discharged to sewer Contact has been
made with the relevant officials and the Municipalityrsquos
requirements have been obtained The effluent discharged to
sewer will notably comply with the applicable discharge standards
Traces of metals (eg iron) may be present but will not exceed
prescribed thresholds The necessary authorisation will be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
4
IssueCommentQuestion Date
received Origin Response
sewer Clarity and acceptance needs to be agreed with
Nelson Mandela Bay Municipality Who owns the sewer
10 Quenching unit will results to Zinc particles How will this
affect sewer discharge This again must be dealt with within
the negotiations with the Municipality
11 Once all has been agreed with the Municipality and at the
same time due negotiations must be done with hazardous
waste courier and disposal facility to accept the hazardous
waste identified in all production lines
12 Of note is the low volume of the proposed WWTW facility ie
250 cubmweek And the no discharge of the quenching
water ie over-flow and cooling only Hence Zinc particles
generation
obtained from the municipality
The sludge from the treatment plant will be collected by a licensed
service provider and disposed of at a permitted site
The quenching bath will be periodically emptied (every 6 months)
and the water discharged will go to the water treatment plant Zinc
particles will settle in the sludge which will be disposed of at a
permitted site
Contact has been made with EnviroServ who manages the
Aloes II HH waste site regarding collection and disposal of
hazardous waste (See waste management report)
13 Investigate the potential effects of toxicity andor influence of
emissions waste and hazardous substances both in
terrestrial and marine fauna
14 With regards to water usage where is the plant going to
extract its waters used in galvanization andor waste
management process ie rainfall rivers or even from the
sea) and which avenues would be more environmental
friendly and effective
31052011
By email
A Bewana
(SANPARKS)
Emissions waste and hazardous substances are not expected to
affect terrestrial or marine ecosystems The air quality study
concluded that atmospheric emissions would not be harmful to
human health and by extension terrestrial fauna There are no
standards for air quality for defining faunal impacts therefore by
ensuring that standards for humans are complied with the impact
on fauna is deemed to be acceptable In this case the impact of
emissions on terrestrial and marine fauna are thus not significant
Solid and liquid wastes both general and hazardous as well as
hazardous substances will be stored handled and disposed of
appropriately to as not to cause harm to terrestrial or marine
fauna
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
5
IssueCommentQuestion Date
received Origin Response
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination and hence land-based
marine pollution by effluent waste or hazardousdangerous
substances is very low
The risk of emissions waste and hazardous substances to
terrestrial and marine fauna is thus very low
However pollution of terrestrial and marine ecosystems can occur
in exceptional circumstances such as accidents and emergencies
The emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
The CDC has an agreement with the NMBM to supply potable
water to the Coega IDZ Currently the infrastructure to supply
return effluent (RE) to the IDZ is not in place therefore Casa Steel
will be supplied with potable water up until such time as the
following 2 options of RE are available
1) Upgrading of the existing Fishwater Flats waste water
treatment works (between IDZ amp PE) including RE plant
and infrastructure to pipe RE to the IDZ (EIA for the
upgrade is underway)
2) Construction of a new waste water treatment works
including RE plant in Zone 9 of the Coega IDZ
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option should be investigated further between Agni and Casa The
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
6
IssueCommentQuestion Date
received Origin Response
CDC can facilitate discussions between the 2 investors
Compliance with CDC Permits amp Requirements
15 It should be made clear that tenants will be required to
comply with CDC requirements and the relevant conditions of
permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water
Licence for its Storm Water Systems on the
East Side of the Coega River that tenants will
need to take cognizance of The contents of the
ldquoIntegrated Stormwater Masterplan for the
eastern side of the Coega IDZ Oct 2010rdquo
especially the Table of best practice p53
onwards may need to be taken cognizance of
o CDC is developing an Operations
Environmental Management Plan that will place
certain obligations on tenants
16 Environmental audits and data collected during monitoring
(eg stack emissions stormwater) will need to be shared with
CDC
Air Emissions
17 Presumably permanent in stack monitoring will be required in
terms of AEL permit requirements
18 Abnormal operating conditions resulting in air emissions ndash I
could find nothing in the EIR to indicate under what
circumstances these could occur (eg start-up) potential
frequency and duration and the impact on ambient air quality
ndash these events usually result in the most problems wrt air
emissions
09042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
15 Compliance with the CDCrsquos Permits amp Requirements has
been included explicitly as a requirement in the EIR (p8-1) and
EMP (pp18 and 25) in the following terms
ldquoAs a tenant operating in the IDZ Casa Steel will be required to
comply with all current and future CDC requirements as well as
with the relevant conditions of permits licences issued to CDC
(eg Integrated Stormwater Masterplan for the eastern side of the
Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)rdquo
16 The need to communicate with the CDC on monitoring and
auditing activities was emphasised in Chapter 8 of the EMP The
following paragraphs were added
ldquoDuring construction the environmental officer will be responsible
for monitoring compliance with the EMP and authorisation
conditions and keeping records as required in the EMP andor
authorisation conditions
The ECO will conduct site inspections every two weeks audit the
records kept by the environmental officer and submit an
environmental compliance report every two months to the
authorities and the CDC (via the Environmental Monitoring
Committeersquos ECO)
During operation the health and safety officer will monitor
compliance with the EMP and the conditions of the Environmental
Authorisation Data collected during monitoring activities and any
environmental audits conducted will be shared with authorities
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
7
IssueCommentQuestion Date
received Origin Response
Water
19 Large volumes of (2000 m3mth) of water are required of
which only 400m3 needs to be potable The NMBM return
effluent system will provide non-potable water once it is
constructed What other water recycling initiatives can be
utilized to reduce potable water requirements (the ISWMP for
the eastern side of the Coega IDZ has some best practice
guidelines collecting rainwater from the roof etc)
General
20 There is no mention of how the CDC Architectural Guidelines
will be incorporated into the development (eg to prevent a
stark uniform warehouse type development)
21 Does NMBM have adequate fire services to cover this
development Apart from the large petroleum store are there
any other large fire hazards
22 Reports from the tenantrsquos ECO during construction and from
the SHE Officer during operations should be channeled to the
Coega Environmental Monitoring Committee This can be
directly or preferably via the EMCrsquos ECO (this will be while
the EMC and ECO are in place) A precedent has been set
for this in the Environmental Authorisations for Agni-Steel and
Kalagadi Manganese Smelter
23 All mitigation actions emanating from the EIR should be
summarized (preferably in a table) If compliance with them is
to be part of the Environmental Authorization from DEDEAT
then they (or the ones that DEDEAT deems to be applicable)
and the CDC (via the Environmental Monitoring Committeersquos
ECO)
The ECO (during construction) and the health and safety officer
(during operation) will report to the Coega Environmental
Monitoring Committee (EMC) via the EMCrsquos ECO (this will be
while the EMC and ECO are in place)rdquo
17 The draft EMP recommends regular monitoring of emissions
from the scrubbers and from the chromating process Additional
emissions monitoring requirements will be confirmed once the
AEL is issued Mention has been made in the EMP (pp11 and 19)
that all AEL conditions including monitoring and reporting
requirements should be adhered to
18 Abnormal emissions can occur in exceptional circumstances
Start-up will not cause abnormal emissions as the scrubbers
will be commissioned first and will be functioning once the plant
starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions
would be emitted as a building fugitive
The hourly hydrogen chloride ground level concentrations
(directly offsite) were predicted to be 239 microgmsup3 (based on the
emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits
as stipulated for listed activities for galvanising processes) using a
screen model which assumes worst case meteorological
conditions The health effect screening level for hourly HCl
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
8
IssueCommentQuestion Date
received Origin Response
should be attached to the EA as an Appendix (otherwise no
one knows about them or takes cognizance of them)
concentrations is 2100 microgmsup3 Assuming abnormal emissions
emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset
conditions will still be well within the health effect screening
levels
Similarly the hourly particulate emissions from the building
fugitives during upset conditions would amount to 293 microgmsup3
(based on the emission limits as stipulated for listed activities for
galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1
January 2015) directly off-site
Therefore if emissions are 5 times higher normal they will still be
within health effect screening levels and the daily PM10 NAAQS
levels
In the case of a fire a cocktail of gases and particulates could be
emitted and could be over the recommended levels This
situation will however be dealt with as an emergency and
normalised as quickly as is possible
The above has been added to the impact identificationdescription
and assessment sections of the EIR
19 The CDC has an agreement with the NMBM to supply
potable water to the Coega IDZ Currently the infrastructure to
supply return effluent to the IDZ is not in place therefore Casa
Steel will be supplied with potable water up until such time as the
infrastructure is in place
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
9
IssueCommentQuestion Date
received Origin Response
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option will be investigated further between Agni and Casa The
CDC has come forward to facilitate discussions between the two
investors
Other water recycling initiatives such as rainwater harvesting
have been considered but are not practical
20 The CDCrsquos Architectural and Landscape Design guidelines
contain requirements pertaining to such aspects as the height
orientation and mass and form of buildings as well as guidelines
for landscaping and signage in order to ensure an attractive
development and achieve an architectural integrity within the
Coega IDZ The plans for the proposed galvanizing plant will be
submitted to the Design Review Committee for approval as
required by the CDC
21 Casa Steel will be required to install fire hydrants according
to the NMBMrsquos standardsrequirements The CDC will provide
potable water (up until such time as return effluent is available)
and a connection to the boundary of the site which will be
connected to the fire hydrants The installation of the fire hydrants
will require approval by the Metrorsquos Fire Chief as was done for
Agni-Steel one of the investors in Zone 6
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
10
IssueCommentQuestion Date
received Origin Response
The Coega IDZ falls within the NMBM and therefore the rates and
taxes paid by the CDC covers the fire services for which the Metro
is responsible Currently the Metro has sufficient capacity to
provide fire services to the tenants within the IDZ This was
confirmed in discussion with the CDCrsquos Infrastructure
Development Unit It is however unknown at which point the
Metrorsquos Disaster Management Plan would not be able to
accommodate servicing tenants in the IDZ
The LNG burner is the only major fire hazard on the plant
22 See response to item 16 above
23 Key mitigation and management measures emanating from
the EIR were recapitulated in Chapter 9 of the EIR to form part of
the conditions attached to the Environmental Authorization from
DEDEAT All mitigation measures recommended as a result of the
impact assessment are presented in a table in the draft EMP
which is appended to the EIR (Appendix J)
24 Hydrogen chloride is one of the main emissions There are no
ambient air quality guidelines for HCl and the EIR says
concentrations will be well within health parameters
However the main problem with HCl is its corrosive effect -
there is absolutely no mention of this in the draft EIR nor air
specialist report
There needs to be some sort of comment assessment as to
whether HCl emissions are likely to impact on for example
the adjacent Agni-Steel Plant wrt corrosion - their factory
structure will be made of steel
11042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The atmospheric corrosion of metals is a complex process with
both the extent of deterioration and the mechanisms varying
considerably depending on the metal Depending on the way
pollutants are transported from the atmosphere to the corroding
surface two types of deposition processes are recognized in
atmospheric corrosion ndash dry deposition and wet deposition Wet
deposition refers to precipitation whereas dry deposition refers to
the remaining processes including gas phase deposition and
particle deposition The most important pollutants acting as
corrosive agents are sulphur and nitrogen compounds including
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
11
IssueCommentQuestion Date
received Origin Response
The EIR specialist rpt suggests monitoring HCl at ground
level on the property boundary and this is supported in case
there are complaints from neighbours
secondary pollutants and particulates Pollutants can contribute to
corrosivity individually however there may be a synergistic effect
when more than one of these pollutants is present in the
environment being affected In the field of atmospheric corrosion
sulphur dioxide is the single most investigated gaseous pollutant
and the quantification of the direct contribution of sulphur dioxide
to the corrosion process of metallic materials is comparatively well
understood (Tidblad amp Kucera 1998)
Very little work has reported on the effect of HCl on the
degradation of materials in the environment with no local dose-
response thresholds developed for corrosion occurring due to HCl
exposures This is probably because HCl which is present
outdoors in markedly reduced concentrations when compared
with SO2 has not been considered to contribute to significant
degradation of materials (Syed 2006) For this reason the
incremental corrosion due to HCl from the Coega Galvanising
Plant cannot be quantified
25 It is unacceptable for ILISO to be using CDC maps (see
figure 9 ndash pg5-6) without these maps being referenced
accordingly particularly when it appears that a CDC map has
been used and then overlaid with features by an unknown
author (ie CASA steel site Port (where the boundaries
depicted are incorrect) and a North legend which is out of
keeping with the overall cartographic intent of the original
work
26 Figure 10 is not referenced appropriately and I believe that I
commented previously in respect to references to roads not
12042012
By email
Graham Taylor
(Spatial
Development
Manager -
Infrastructure
Development
CDC)
This has been rectified in the final version of the report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
12
IssueCommentQuestion Date
received Origin Response
yet built As a result Figure 10 is confusing and clarity needs
to be provided in terms of referencing In addition the Port
shape is irregular and similar to the comment above
27 I acknowledge the emergency preparedness and response
plan but please confirm that this includes pro-active routine
monitoring of storm water leaving your premises to verify that
your assumptions of clean storm water are correct
13042012
By post
Andrew Lucas
(Director
WRampU
Department of
Water Affairs)
Pro-active routine monitoring of stormwater leaving the premises
will be undertaken This has been explicitly emphasised in
chapter 8 of the draft EMP
28 Will portablechemical toilets be used during construction
29 What provisions have been made for storm water drainage
during construction
18042012
By
telephone
Department of
Water Affairs
Port Elizabeth
Chemical toilets will be used during construction
The Casa Steel site will be located at the corner of two roads
drainage of stormwater from the site will take place through the
roadsrsquo drainage system
From Lea September [mailtoleailisocom]
Sent 11 March 2011 0935 AM
To Wayne Poulton
Cc Terry Baker
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Wayne
An Environmental Impact Assessment (EIA) will be undertaken for this project during the
next 10 to 12 months
We foresee that some of the key environmental impacts of the project will be in terms of air
quality water quality waste and hazardous substances
At this stage I am not able to give you any details regarding the potential toxicity of the
emissions andor effluent However specialist studies will be conducted as part of the EIA
that will determine the key impacts of the project Mitigation measures will also be identified
to avoid minimise or compensate any significant impacts
You are registered on the stakeholder database and you will be kept informed of progress in
the EIA process you will notably get the opportunity to access the reports produced and
provide any feedback on them
Please feel free to contact me should you need any further information
Best regards
Lea September
From Wayne Poulton [mailtowaynepbosuncoza]
Sent 07 March 2011 1257 PM
To Lea September
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
Please can you provide me with some more information as to the potential dangers including
the toxicity of this
Kind regards
Wayne
From Lea September [mailtoleailisocom]
Sent 04 March 2011 1123
To Lea September
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 March 2011 0745 AM
To Paul Martin
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 05 April 2011 0847 AM
To Paul Martin
Cc Terry Baker Renee von Gruenewaldt
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Thank you Paul for this information
I have downloaded a copy of the RoD and Scoping report you referred to and will make sure
these requirements are taken into account in the environmental assessment
Best regards
Lea September
From Paul Martin [mailtopmartinaxxesscoza]
Sent 04 April 2011 0955 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Further to my comments on 27311
Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in
the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega
IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised
scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions
including prohibiting and monitoring where possible visible emission plumes to the atmosphere
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Paul Martin
Sent Monday March 28 2011 745 AM
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 10 May 2011 0327 PM
To ElliotMotsoaholetransnetnet
Cc Terry Baker
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Mr Motsoahole
Thank you for your input on this issue
The Port of Ngqura will indeed be used for import and export At the moment the scope of
the traffic impact assessment only covers road traffic I have however relayed the matter to
our traffic specialist and we will consider this issue in the finalization of the Scoping Report I
will keep you informed of any developments in that regard
I trust this is acceptable to you
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]
Sent 10 May 2011 0855 AM
To Lea September
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
It has been noted that Casa Steel will source steel coils from various markets internationally and
in South Africa and the bulk of the plantrsquos production output will be exported to African countries
However there is no mention of logistic requirements
Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will
be used the scope of traffic impact assessment should also include the port
Regards
From Lea September [mailtoleailisocom]
Sent 04 May 2011 0747 AM
To Lea September
Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
Please find attached a letter announcing the EIA process underway for the proposed 80 000
tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as
a Background Information Document (BID) outlining the details of the project
Please contact me should you require any further information on this project
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
Elliot Motsoahole
Manager - Environment
Transnet National Ports Authority
Port of Nqqura
Port Control Building Klub Road Port Elizabeth 6212
PO Box 612054 Bluewater Bay 6212
+27 41 507 8450
+27 86 674 7729
Cell +27 83 542 5619
E-mail Elliotmotsoaholetransnetnet
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
DISCLAIMER The information contained in this communication is subject to copyright and
intended only for the use of leailisocom Unauthorised use disclosure or copying is
strictly prohibited Should a virus infection occur as a result of this communication the sender
will not be liable If you have received this communication in error please notify
elliotmotsoaholetransnetnet
From Lea September [mailtoleailisocom]
Sent 25 May 2011 1147 AM
To Jack Landile (ELS)
Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi
Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Landile
Thank you for your input
Contact has been made with the relevant Municipal Directorate and we will follow up with
them to obtain clarifications on all these issues
I have added both Lizna and yourself on the database and will keep you updated on
progress on this project
Best regards
Lea September
From Jack Landile (ELS) [mailtoJackLdwagovza]
Sent 24 May 2011 0524 PM
To Fourie Lizna (ELS)
Cc Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Hi Lizna
I missed you on this sorry
I linked Pieter twice Instead
Regards
Landile
From Jack Landile (ELS)
Sent 24 May 2011 0445 PM
To leailisocom
Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Lea
The e-mail you sent to Mr Kooverji dated 19 May 2011 refer
Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are
All steel sheets bathing unit must be under roof
The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project
Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal
Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer
Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality
Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines
Of note is the low volume of the proposed WWTW facility ie 250 cubmweek
And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles
generation
Regards
Landile
From Lea September [mailtoleailisocom]
Sent 19 May 2011 0947 AM
To Lea September
Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Stakeholder
Please find attached the remaining appendices to the draft Scoping report for the proposed
80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 June 2011 0411 PM
To Aphiwe Bewana
Subject RE Proposed 80 000 TPY Galvanizing plant in Coega
Dear Mr Bewana
Thank you for your input and apologies for the late reply
We have taken note of your comments and are will be taking them forward in the EIA phase
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Aphiwe Bewana [mailtoaphiwebewanagmailcom]
Sent 31 May 2011 1205 PM
To Lea September
Subject Re Proposed 80 000 TPY Galvanizing plant in Coega
Comment
Re Proposed 80 000 TPY Galvanizing plant in Coega
As SANParks we would like the EIA phase to investigate the potential effects of toxicity
andor influence of emissions waste and hazardous substances both in terrestrial and
marine fauna In the draft scoping report reference has been made with regards to the
terrestrial fauna but there is no attention to potential effects to marine fauna
Equally with regards to water usage where is the plant going to extract its waters used in
galvanization andor waste management process ie rainfall rivers or even from the sea)
and which avenues would be more environmental friendly and effective
Regards
Aphiwe Bewana
Marine Planner
South African National Parks
POBox 76693
NMMU
Port Elizabeth
6031
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 06 July 2011 1031 AM
To Lea September
Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Hi Lea
Irsquove reviewed the Final Scoping Report Herewith a few comments
1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the
Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a
revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the
NMBLP Please include only those in the IDZ as part of your IAP list
Regards
Andrea
From Lea September [mailtoleailisocom]
Sent Wednesday July 06 2011 859 AM
To Lea Septemberrsquo
Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Dear Stakeholder
The final scoping report for the above-mentioned project (attached) is available for comment
until 27 July 2011
The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic
commentaryrdquo tab
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 09 April 2012 1159 AM
To Lea September
Subject Comments on Galvanising Plant EIR Coega IDZ
Lea
Attached are my comments on the Draft EIR for the Coega IDZ galvanising
plant
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
Email attachment
COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ
Dr Paul Martin PO Box 61029
Bluewater Bay 6212 Tel 041 4665698
Email pmartinaxxesscoza
Compliance with CDC Permits amp Requirements
It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of
o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants
Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC
Air Emissions
Presumably permanent in stack monitoring will be required in terms of AEL permit requirements
Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions
Water
Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)
General
There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)
Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards
Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter
All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 11 April 2012 1245 PM
To Lea September
Subject Fw Comments on Galvanising Plant EIR Coega IDZ
Lea
One other comment on that I have on the Galvanising Plant Draft EIR
Hydrogen chloride is one of the main emissions There are no ambient air
quality guidelines for HCl and the EIR says concentrations will be well
within health parameters
However the main problem with HCl is its corrosive effect - there is
absolutely no mention of this in the draft EIR nor air specialist report
There needs to be some sort of comment assessment as to whether HCl
emissions are likely to impact on for example the adjacent Agni-Steel
Plant wrt corrosion - their factory structure will be made of steel
The EIR specialist rpt suggests monitoring HCl at ground level on the
property boundary and this is supported in case there are complaints from
neighbours
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Paul Martin ltpmartinaxxesscozagt
To Lea September ltleailisocomgt
Sent Monday April 09 2012 1158 AM
Subject Comments on Galvanising Plant EIR Coega IDZ
gt Lea
gt
gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising
gt plant
gt
gt
gt Dr Paul Martin
gt PO Box 61029
gt Bluewater Bay 6212
gt Tel 041 4665698
gt Cell 0732524111
gt email pmartinaxxesscoza
gt
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 12 April 2012 1139 AM
To Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Hi Lea
Hope yoursquore keeping well
I have requested comments from my colleagues and the CDC Casa team on the Draft EIR
Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report
Regards
Andrea
From Graham Taylor
Sent Thursday April 12 2012 838 AM
To Andrea Von Holdt Firhana Sam
Cc Johan Fourie Maria van Zyl Melikhaya Sihawu
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Andrea Firhana
Firhana if you could please ensure that the co-ordinates provided in the EIR correspond
with our records (pages 4-1 amp 4-2)
My comments are as follows
It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work
Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above
Regards
Graham Taylor
Spatial Development Manager - Infrastructure Development
Mobile 0832283055
Office 0414030454
Facsimile 0865185033
Email GrahamTaylorcoegacoza
Website wwwcoegacom
right PLACE | right TIME | right CHOICE
This email and all contents are subject to the following disclaimer
httpwwwcoegacomemaildisclaimerhtml
From Lea September [mailtoleailisocom]
Sent 04 May 2012 0411 PM
To Andrea Von Holdt
Cc Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Dear Andrea
We have taken note of the comments from the GIS Unit These issues have been rectified in
the final version of the EIR
Please can you forward to the relevant persons at the GIS Unit
Thank you
Best regards
Lea September
APPENDIX E
BACKGROUND INFORMATION
DOCUMENT
APPENDIX F
AIR QUALITY IMPACT ASSESSMENT
APPENDIX G
TRAFFIC IMPACT ASSESSMENT
APPENDIX H
WASTE MANAGEMENT AND HAZARDOUS
SUBSTANCES SPECIALIST STUDY
APPENDIX I
WATER QUALITY SPECIALIST STUDY
APPENDIX J
ENVIRONMENTAL MANAGEMENT
PROGRAMME
PROPOSED 80 000 TPY GALVANIZING PLANT IN THE
COEGA INDUSTRIAL DEVELOPMENT ZONE (IDZ)
DEDEA Reference ECm1LN2M11-24
Report Title Draft Environmental Impact Assessment Report
Authors Lea September Martin van Veelen Terry Baker
ILISO project reference no 1000196
Status of report Final v10
First issue April 2012
Final issue
Prepared by Submitted to
ILISO Consulting (Pty) Ltd Eastern Cape Department of Economic
P O Box 68735 Development and Environmental Affairs
Highveld Contact Mr Jeff Govender
0169 Private Bag X 5001
Greenacres 6057
Contact Lea September On behalf of
Tel 012 685 0900 Casa Steel Trading (Pty) Ltd
Fax 012 665 1886 Contact Mrs Leoncie Mukundente Director
Cell 082 455 1157 Tel 041 379 4623
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 i
PROPOSED 80 000 TPY GALVANIZING PLANT IN THE
COEGA INDUSTRIAL DEVELOPMENT ZONE
FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT
TABLE OF CONTENTS
ACRONYMS IV
EXECUTIVE SUMMARY V
1 INTRODUCTION 1-1
11 BACKGROUND 1-1
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS 1-1 13 PURPOSE OF THIS REPORT 1-2
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) 1-2
15 PROJECT TEAM 1-3
16 STRUCTURE OF THIS REPORT 1-4
2 DESCRIPTION OF THE PROPOSED PROJECT 2-1
21 TECHNICAL ASPECTS 2-1
211 The galvanizing process 2-1
212 Main inputs and outputs in operational phase 2-3
213 Installations on site 2-3
22 LOCATION OF THE PROPOSED GALVANIZING PLANT 2-4
23 NEED AND DESIRABILITY 2-6
24 ALTERNATIVES IDENTIFIED 2-6
25 CONSTRUCTION ASPECTS 2-6
26 OPERATION ASPECTS 2-7
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT 3-1
31 OBJECTIVES 3-1
32 AUTHORITY CONSULTATION 3-1
33 PUBLIC PARTICIPATION PROCESS CONDUCTED 3-1
34 LEGISLATION AND GUIDELINES CONSIDERED 3-2
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT 4-1
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION 4-1
42 SOCIO-ECONOMIC CHARACTERISTICS 4-3
43 BIOPHYSICAL CHARACTERISTICS 4-3
431 Surface and ground water 4-3
432 Climate and atmospheric conditions 4-3
433 Geology and soils 4-4
434 Terrestrial ecology 4-4
435 Land use and topography 4-7
436 Heritage and archaeological survey 4-7
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED 5-1
51 AIR QUALITY 5-1
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 ii
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS 5-2
53 BIODIVERSITY AND CONSERVATION 5-2
54 WATER QUALITY 5-2 55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES 5-3
56 HEALTH AND SAFETY 5-5
57 TRAFFIC 5-5
58 NOISE 5-9
59 SOCIO-ECONOMIC ASPECTS 5-10
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY 6-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS 7-1
71 IMPACTS DURING CONSTRUCTION 7-1
711 Air quality 7-1
712 Heritage and archaeological resources 7-1
713 Biodiversity and conservation 7-2
714 Water related impacts 7-3
715 Waste management 7-3
716 Health and safety 7-4
717 Traffic 7-4
718 Noise 7-5
719 Socio-economic 7-5
72 IMPACTS DURING OPERATION 7-6
721 Air quality 7-6
722 Water quality 7-7
723 Waste management and hazardous substances 7-8
724 Health and safety 7-9
725 Traffic 7-9
726 Noise 7-10
727 Socio-economic 7-11
73 COMPARATIVE ASSESSMENT OF IMPACTS 7-11
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME 8-1
9 ENVIRONMENTAL IMPACT STATEMENT 9-1
10 CONCLUSION AND RECOMMENDATIONS 10-1
11 REFERENCES 11-1
LIST OF FIGURES
Figure 1 Process flow diagram for proposed galvanizing plant 2-2
Figure 2 Continuous Galvanizing Line 2-3
Figure 3 Location of the proposed galvanizing plant 2-5
Figure 4 Zone layout in the Coega IDZ 4-1
Figure 5 Site location 4-2
Figure 6 Coega IDZ Open Space Management Plan (OSMP) 4-5
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble gravels
exposed by tracks in Zone 6 (Source Binneman 2010) 4-8
Figure 8 Coega IDZ road network layout (Adapted from BKS 2006) 5-6
Figure 9 Coega IDZ road network 5-7
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 iii
Figure 10 Trip distribution for freight and personnel trips 5-8
Figure 11 Morning peak hour Casa Steel development traffic 5-9
Figure 12 Casa Steel organisation chart 5-10
LIST OF TABLES
Table 1 Coordinates of site corners for the proposed galvanizing plant 4-1
Table 2 Hazardous materials to be used on site 5-4
APPENDICES
APPENDIX A List of registered stakeholders
APPENDIX B Notice of AEL application and advertisements
APPENDIX C Notice of comment period for draft scoping report
APPENDIX D Summary of issues raised and responses thereto
APPENDIX E Background Information Document
APPENDIX F Air Quality Impact Assessment
APPENDIX G Traffic Impact Assessment
APPENDIX H Waste Management and Hazardous Substances specialist study
APPENDIX I Water Quality Specialist Study
APPENDIX J Environmental Management Programme (EMP)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 iv
ACRONYMS
AEL Atmospheric Emissions Licence
BID Background Information Document
CCA Custom Controlled Area
CDC Coega Development Corporation
DEA Department of Environmental Affairs
DEDEAT Department of Economic Development Environmental Affairs and Tourism
DWA Department of Water Affairs
EAP Environmental Assessment Practitioner
EIA Environmental Impact Assessment
ELC Environmental Liaison Committee
EMP Environmental Management Programme
GN Government Notice
IampAPs Interested and Affected Parties
IDZ Industrial Development Zone
LNG Liquid natural gas
masl Meters above sea level
MSDS Material Safety Data sheet
NEMA National Environmental Management Act
NEMBA National Environment Management Biodiversity Act (No10 of 2004)
NMBM Nelson Mandela Bay Municipality
OSMP Open Space Management Plan
PoS Plan of Study
SAHRA South African Heritage Resources Agency
TNPA Transnet National Ports Authority
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 v
EXECUTIVE SUMMARY
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone
(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province
Galvanizing consists of coating steel with zinc in order to protect it from corrosion An
Environmental Impact Assessment (EIA) is required as the proposed project involves several
activities listed in terms of Section 24 of the National Environmental Management Act
(NEMA) 107 of 1998 as amended and requires an environmental authorisation The
project also involves activities listed in terms of the National Environmental Management Air
Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008
which respectively require an Atmospheric Emissions Licence and a Waste Management
Licence
The Scoping and Environmental Impact Assessment process underway covers all aspects of
the project and informs all three applications
Scoping was the first phase of investigations and aimed to inter alia identify potential key
environmental issues and impacts to be addressed in the EIA phase
The following environmental issues and potential impacts identified in the Scoping Phase
were investigated in the EIA
Air quality
The galvanizing process generates atmospheric emissions which are regulated in terms
of the National Environmental Management Air Quality Act and appropriate measures
are required in order to adhere to the applicable standards Other sources of impact on
air quality include emissions from the LNG burner emissions and dust from the transport
of steel and other materials in trucks as well as dust and gas emissions related to
construction activities Mitigation measures recommended in the EMP will ensure that air
quality impacts are kept to a minimum and compliance with emissions standards is
maintained
Biodiversity and conservation
Certain types of vegetation in the IDZ are of high conservation importance Protected
species will be rescued as per the CDCrsquos requirements
Water quality
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through spills
or leaks This risk can however be minimized if not avoided altogether through design
choices (bunded areas) and the adherence to best practice guidelines for the handling or
the transport of hazardous substances and waste
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vi
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
Waste management and hazardous substances
The plant will generate a relatively small amount of solid waste which will be re-used
recycled or disposed of in accordance with the EMP recommendations
There will be a wastewater treatment plant on site which will neutralise process water
(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer
Hazardous waste from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site
at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and
removed on a monthly basis is limited to 10 m3
A number of substances classified as hazardous are used in the galvanizing process and
the transport and handling of these is subject to certain rules and guidelines
In addition the permanent storage of a high quantity of liquid petroleum on site (20 000
litres at any one time) is subject to certain specifications and requires approval from the
municipality
Health and safety
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling of the various substances used will be done in
accordance with applicable instructions (cf material safety data sheets)
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as provide
site supervision including executing tests (individual test cold run and hot run) during 3
months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the EMP
Traffic
In the operational phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and from
the Port of Ngqura
The traffic expected to be generated during construction as well as operation is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low and
the total traffic generated by Casa Steel is also relatively low
The impact on port traffic is also negligible and well within the portrsquos capacity
Socio-economic aspects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vii
The proposed galvanizing plant will make a positive contribution by creating jobs during
construction and operation and generating business for the various service providers
Fatal flaws
No fatal flaws have been identified
The significance of these potential key environmental impacts were assessed in the EIA
phase and the findings of this phase of investigations are presented in this report
The main findings of the EIA are as follows
During construction impacts post-mitigation are low with the exception of noise and
biodiversity as the construction of the plant will result in the destruction of habitat
and loss of fauna and flora and noise impacts inherent to construction activities
Mitigation measures have been included in the EMP for these impacts and they have
a medium significance post-mitigation
All impacts were assessed as low during operation after mitigation
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium
to long term similar impacts are likely to occur due to ongoing developments in the
IDZ
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
The CDC has its own requirements regarding the monitoring of certain aspects of the
project such as the quality of the effluent and the noise levels These have been
incorporated into the EMP Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as other
infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified and
assessed No fatal flaws have been identified
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 viii
It is recommended that the project be approved subject to the conditions listed above
and adherence to the EMP recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-1
1 INTRODUCTION
11 BACKGROUND
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)
Nelson Mandela Bay Municipality Eastern Cape Province
The demand for galvanised steel products is high in South Africa and Africa and is
expected to increase in the foreseeable future From an economic point of view the
proposed project has therefore been found to be viable
Casa Steel will source the steel coils from various markets internationally and in
South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is
destined to be exported mainly to African countries
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
An Environmental Impact Assessment (EIA) is required as the proposed project
involves several activities listed in terms of Section 24 of the National Environmental
Management Act (NEMA) No 107 of 1998 as amended and requires an
environmental authorisation
The following listed activities requiring environmental authorisation have been
identified
Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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
Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped
land to industrial use greater than 1 ha but less than 20 ha in size outside an
urban area
Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any
process or activity requiring a license in terms of national or provincial legislation
governing the generation or release of emissions
Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5
hectares or more of vegetation where 75 or more of the vegetative cover
constitutes indigenous vegetation except where such removal of vegetation is
required for
(i) purposes of agriculture or afforestation inside areas identified in
spatial instruments adopted by the competent authority for
agriculture or afforestation purposes
(ii) the undertaking of a process or activity included in the list of waste
management activities published in terms of section 19 of the
National Environmental Management Waste Act 2008 (Act No 59
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-2
of 2008) in which case the activity is regarded to be excluded from
this list
(iii) the undertaking of a linear activity falling below the thresholds in
Notice 544 of 2010
Hot dip galvanizing is a listed activity in terms of section 21 of the National
Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires
an Atmospheric Emissions Licence (AEL)
In addition the treatment of wastewater with an annual throughput capacity of more
than 2000 m3 is a listed activity in terms of the National Environmental Management
Waste Act 59 of 2008 and requires a waste management licence
ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental
Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact
Assessment process in terms of section 24 of NEMA for the construction and
operation of the proposed galvanizing plant The EIA process covers all aspects of
the project and informs all three applications (for environmental authorisation waste
management licence and AEL)
13 PURPOSE OF THIS REPORT
This report builds on the scoping report submitted to the Eastern Cape Department of
Economic Development and Environmental Affairs (DEDEA) and the Nelson
Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It
describes the proposed project and presents the findings of the second phase of
investigations (EIA phase)
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP)
The EIA was managed by Ms Terry Baker a certified Environmental Assessment
Practitioner with 20 years of working experience She has a MA in Environmental
Management and specialises in Environmental Impact Assessments and Project
Management She has been involved in a variety of different types of EIAs including
for water supply projects dams transmission lines roads and airports in South
Africa Botswana Uganda Lesotho and Mozambique She has been involved in
water resource management and public participation programmes on a number of
projects Terry has also been involved in the use of Geographic Information Systems
environmental status quo reports water quality assessments socio-economic and
institutional development projects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-3
15 PROJECT TEAM
In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen
(water quality specialist) and Lea September (EAP) with specialist input from Renee
von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous
substances) and Seniel Pillay (Traffic Impact Assessor)
The Business Unit Head of the ILISO Environmental Management Discipline Group
Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is
a Fellow of the South African Institution of Civil Engineers a member of the South
African Society of Aquatic Scientists of the Environmental Scientific Association of
the International Water Association of the Water Institute of South Africa and of the
Vaal River Catchment Association He is a certified Environmental Assessment
Practitioner with 30 years experience who specialises in project management
environmental impact assessments and water resource planning He specifically has
extensive experience in water quality especially water quality management water
quality monitoring and water quality assessment Martin has experience in managing
projects that involve multi-disciplinary teams and public consultation and
participation in South Africa and abroad
Lea September is an Environmental Assessment Practitioner with a Masters degree
in Environmental Management She has experience in impact assessment and
environmental management and has been responsible for drafting impact
assessment reports and Environmental Management Programmes and conducting
public participation processes as well as high level environmental screenings for a
variety of projects in the energy water transport and industrial sectors
Renee von Gruenewaldt has nine-years experience in the field of air pollution
impact assessment and air quality management Prior to becoming involved in air
quality consultation she was part of the Highveld Boundary Layer Wind Research
Group based at the University of Pretoria Since joining Environmental Management
Services (the company now Airshed Planning Professionals) she has undertaken
numerous air pollution impact studies and has provided extensive guidance to both
industry and government on air quality management practices
Pieter Smuts graduated as a Civil Engineer and became involved in the field of
municipal engineering and infrastructure construction He has specialized during the
last twelve years in solid waste management He has completed waste management
plans feasibility studies and final designs of waste management facilities in South
Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and
the review of the Mavoco hazardous waste landfill design in Maputo Mozambique
and completed a study on hazardous waste (textile factory sludge) management in
Maseru Lesotho
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-4
Seniel Pillay is a transportation engineer with over 16 years experience in
transportation planning and traffic engineering He has been involved in a wide
range of projects ranging from developing the Transport Operations Plan for the
FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System
for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller
traffic impact assessments for inter alia road improvement schemes Of particular
relevance to this project his experience includes Heavy Goods Vehicle Study for
eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact
Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash
Preliminary Transportation Assessment
16 STRUCTURE OF THIS REPORT
The proposed project and the alternatives considered are described in Chapter 2
Chapter 3 details the approach adopted for the EIA phase
The biophysical and socio-economic environment affected by the activity is described
in Chapter 4
The environmental impacts identified are discussed in Chapter 5
The EIA methodology is described in Chapter 6 and Chapter 7 presents the results
of the impact assessment
The environmental impact statement is presented in Chapter 8
Finally Chapter 9 spell out the conclusions and recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-1
2 DESCRIPTION OF THE PROPOSED PROJECT
21 TECHNICAL ASPECTS
211 The galvanizing process
Galvanizing consists of coating steel with zinc in order to protect it from corrosion
Before steel strips can be galvanized they undergo a pre-treatment in order to
ensure that the steel sheets are free from any surface oxides as they enter the
molten zinc coating Bath This is done by removing the oil from the steel sheets (in
the degreasing unit) and then removing the rust from the surface of the sheet (in the
pickling unit)
The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The
melting zinc on the strip surface will be cooled and solidified through air cooling in the
cooling tower
Finally the galvanised steel sheets are dipped into a water quenching tank in order to
further cool the sheets from about 150degC to 40degC
It is possible to make galvanised steel more durable by chromating it Approximately
50 of the galvanised steel production output will receive chromate passivation
treatment after quenching the galvanised steel sheets will be sprayed with a chrome
solution (3 kgcm2)
After galvanizing and chromating the steel sheets are cut to achieve the desired coil
size and weight and transported to the storage yard
The process flow diagram below (Figure 1) illustrates the main stages of the
galvanizing process and indicates the major inputs and outputs as well as the
resulting effluent and atmospheric emissions
Draft Environmenal Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-2
Figure 1 Process flow diagram for proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-3
212 Main inputs and outputs in operational phase
In view of the above the main inputs will be as follows
Steel coils 85 000 tonsyear
Zinc 870 tonsyear
Electricity 2500 kVA
Water 2000 m3month (of which 400 m3 will be potable water)
Liquid Natural Gas (LNG) 270 NM3hour
Sodium hydroxide (NaOH) 1000 m3year
Hydrochloric acid (HCl) 800 m3year
Chrome (Cr+3) 10 m3year
The main outputs will be
Galvanized steel 80 000 tonsyear
Scrap metal 20 tonsyear
General waste 65 tonsyear
Hazardous waste 2 m3month
Wastewater 012 Mlweek
Atmospheric emissions lt 5 ppm
213 Installations on site
The bulk of the operations involved in the galvanizing process occur along a
continuous galvanizing line (See Figure 2 below) which is the main piece of
machinery required for the proposed galvanising plant
Figure 2 Continuous Galvanizing Line
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-4
Water is one of the major inputs and is used throughout the galvanizing process notably
for rinsing and cooling purposes and as a mixing agent for the various chemical
solutions The plant will have a water treatment plant on site to treat the water used in
the various processes (approx 250 m3
of wastewater per week) The wastewater
treatment facility will be operated by a professional water treatment company as Casa
Steel does not have the required expertise in house to treat its process water Sulphuric
acid (H2SO4) is used as part of the treatment process to reduce caustic soda The
neutralised water is discharged to the sewer while any sludge is disposed of as
hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)
will be disposed of
Some critical areas of the galvanizing process such as the zinc pot require uninterrupted
power It is therefore proposed to install an LNG burner to maintain the zinc bath at a
temperature of between 450 and 460degC
22 LOCATION OF THE PROPOSED GALVANIZING PLANT
The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast
of Port Elizabeth in the Eastern Cape (Figure 3)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-5
Figure 3 Location of the proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-6
23 NEED AND DESIRABILITY
The profitability of the proposed project has been established by Casa Steel and a
pre-feasibility study has confirmed that the proposed project was feasible from a
technical and financial point of view The Coega IDZ is specifically designed to host
facilities such as a galvanizing plant and can provide the necessary infrastructure
and services to its investors It therefore constitutes a very suitable location for the
project
24 ALTERNATIVES IDENTIFIED
Zone 6 has been specifically earmarked for heavy ferrous metal industries and is
therefore a suitable location for the proposed galvanizing plant as such no site
alternatives have been provided for and assessed in this EIA However prior to the
commencement of the EIA process Casa Steel was presented with a number of
different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the
selection of the site were
(a) The dimensions of the land the site should be at least 200 m long and
50 m wide in order to accommodate the galvanizing line and adjacent lay
down area and additional land should be available next to the site for future
expansion
(b) The fiscal arrangements applying to the site the site should be located
within the future Custom Controlled Area (CCA) as the bulk of the
production output of the plant will be exported
The no-go alternative is assessed in this report
25 CONSTRUCTION ASPECTS
The construction phase of the project will take about 12 months and will essentially
consist of erecting a building to house the galvanizing line and other equipment and
preparing a concrete laydown area adjacent to the building
The CDC will provide an access point from the existing tarred road that will lead to
the site
Approximately 100 workers from the surrounding areas will be contracted for the
construction work
The requirements in terms of services during construction are listed below
Water 1000 m3month
Electricity 2500 kVA
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-7
The CDC will provide temporary services for the construction phase including a
conservancy tank for flush toilets Sewage infrastructure will only be provided for the
operational phase
26 OPERATION ASPECTS
Before the plant can become fully operational the equipment and machinery will be
tested for approximately 3 months The supplier will supervise these tests as part of
the transfer of know-how and training of staff on the plant
Casa Steel will start operating the plant at a reduced capacity (about 50 000
tonsyear) for a period of time (mostly determined by market aspects) before bringing
production to full capacity (80 000 tonsyear) This is done by operating the line for
longer hours
Approximately 50 to 60 people will be working on the plant Approximately 6-10 of
these will be unskilled 40-45 skilled and about 5 people in managerial positions
The requirements in terms of services during operation are as follows
Water 2000 m3month
Electricity 2500 kVA
Effluent discharge 24 m3day
The CDC has entered into agreements with the municipality to secure the provision
of services such as water and electricity to its tenants Tenants in the IDZ have their
own agreements with the NMBM for electricity while the agreements for water and
sewage are with the Facilities Unit of the CDC
Regarding discharge of wastewater to the sewer the municipality indicated that the
only requirement is that the water discharged complies with applicable municipal
discharge standards
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 3-1
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT
31 OBJECTIVES
The main objectives of the EIA phase are to
Assess the significance of the environmental issues and impacts identified in the
scoping phase focusing on key impacts
Recommend appropriate measures to mitigate negative impacts and enhance the
benefits and include them in the draft EMP
Undertake a public participation process that provides opportunities for all
interested and affected parties (IampAPs) to be involved
32 AUTHORITY CONSULTATION
The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental
Liaison Committeersquo (ELC) which comprises representatives of various authorities
including DEDEAT the Department of Environmental Affairs (DEA) and Department
of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the
Coega Development Corporation (CDC) and Transnet National Ports Authority
(TNPA) The ELC has been specifically formed to facilitate EIA applications in the
IDZ
Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to
the clearance of vegetation should be included in the application A formal request
was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the
application and all registered stakeholders were informed of the request in writing on
19 October 2011
33 PUBLIC PARTICIPATION PROCESS CONDUCTED
On-site notices were replaced by a notification displayed on the CDCrsquos digital notice
board at the business centre in Zone 1 of the IDZ The eNotice was placed on
13 April 2011 and will remain for the full duration of the EIA process
Registered stakeholders will be notified in writing of the availability of the draft EIA
report and EMP which will also be advertised in a local newspaper Stakeholders
including state departments and the public will have forty (40) days to comment on
the draft EIA report and EMP The draft EIA report and EMP will be sent by email
where possible and made available for download on the ILISO website
(wwwilisocom)
A summary of all issues and comments received during the stakeholder consultation
process as well as of correspondence in that regard will be captured in an Issues
and Responses Report that will form an Appendix to the EIA Report
The list of registered IampAPs is included in Appendix A
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 3-2
34 LEGISLATION AND GUIDELINES CONSIDERED
The following legislation and guidelines were considered in the preparation of this
report
National Environmental Management Act Act No 107 of 1998
NEMA EIA Regulations 2010
National Environmental Management Air Quality Act Act No 39 of 2004
National Environmental Management Waste Act Act No 59 of 2008
Hazardous Substances Act Act 15 of 1993
Occupational Health and Safety Act Act 85 of 1993
Hazardous Chemical Substances Regulations 1995 (GNR 1179)
Major Hazard Installation Regulations 2001 (GNR 692)
National Water Act Act 36 of 1998
National Heritage Resources Act Act 25 of 1999
DEAT Integrated Environmental Management Information Series 1-5 and 12-15
NEMA draft Implementation Guideline
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Public Participation (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Alternatives (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Draft Guideline for Determining the Scope of Specialist
Involvement in EIA Processes (2005)
IAIA guidelines
National air quality standard for thoracic particulates Government Gazette
No 32816
Listed activities and associated minimum standards identified in terms of section
21 of the National Environmental Management Air Quality Act Act No 39 of
2004 Government Notice 248 of 2009
Minimum Requirements for the Handling Classification and Disposal of
Hazardous Waste DWAF Waste Management Series (1998)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-1
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION
The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega
IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay
to the north of the N2 highway between Port Elizabeth and Grahamstown east of the
Coega River
The co-ordinates of the corners of the site are shown in Table 1
Table 1 Coordinates of site corners for the proposed galvanizing plant
Point Longitude Latitude
A 25deg411126E 33deg45587S
B 25deg411156E 33deg45499S
C 25deg411938E 33deg45131S
D 25deg412174E 33deg45481S
E 25deg412508E 33deg45979S
F 25deg412634E 33deg451160S
G 25deg411782E 33deg451560S
H 25deg411692E 33deg451428S
J 25deg411314E 33deg45868S
Figure 4 Zone layout in the Coega IDZ
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-2
Figure 5 Site location
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-3
42 SOCIO-ECONOMIC CHARACTERISTICS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the
NMBM There are no residents within the IDZ
As far as the broader NMBM and Eastern Cape Province are concerned the
following can be noted The NMBM is located within the Eastern Cape Province the
2nd largest Province in South Africa (3rd in terms of population) characterised by a
predominantly black population with low incomes and high levels of unemployment
(CES 2010)
The NMBM has a population of just above 11 million and covers an area of
1 950 km2 It is the main urban and industrial centre of the province and Port
Elizabeth in particular which forms part of the NMBM is the commercial capital of
the Eastern Cape 52 of the NMBM population is female and 37 is below the
age of 20 these two groups are particularly affected by unemployment
43 BIOPHYSICAL CHARACTERISTICS
431 Surface and ground water
No rivers occur in Zone 6 There is however a natural attenuation pond on the
southern most part of the site which will have to be avoided
The IDZ is underlain by calcrete sand and gravel deposits that overlie low
permeability clays These clays limit the vertical infiltration of rainwater and induce a
horizontal groundwater flow towards the Coega River channel which is the most
significant surface water feature in the Coega IDZ Consequently rapid run-off takes
place following precipitation (Jacobs 2008)
Groundwater levels at Coega are generally about 3 to 5 m below surface ie just
above the contact between the permeable sands and the underlying impermeable
clays The groundwater flow direction is to the southeast following the surface water
drainage direction (Jacobs 2008)
432 Climate and atmospheric conditions
Port Elizabeth has a warm temperate climate and the temperature ranges are not
extreme Exceptionally high temperatures may be experienced during berg wind
conditions which occur frequently during autumn and winter Extreme temperatures
also occur during summer with little accompanying wind
The wind regime for the area largely reflects the synoptic scale circulation with
dominant westerly and northwesterly flow fields representing the pre-frontal
conditions and south-westerly flow fields representing the frontal conditions The
south-easterly and south-westerly wind flow (land breeze) increases during daytime
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-4
conditions with westerly and north-westerly wind flow increasing during the night (sea
breeze)
The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of
Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15
km southwest) and Port Elizabeth (~23 km southwest)
An ambient air monitoring network has been established in the Coega IDZ which
consists of three monitors Saltworks Motherwell and Amsterdamplein Although
NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative
impacts due to the proposed Galvanising Plant is PM10 A maximum daily average
PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed
SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3
was exceeded on 17 days in 2007 and 26 days in 2008
Existing sources of emissions in the vicinity of the proposed galvanizing plant include
industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other
fugitive dust sources (von Gruenewaldt 2011b)
433 Geology and soils
Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel
and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly
limestone and conglomerate
434 Terrestrial ecology
This section draws from the EIA report compiled for the Agni Steel (formerly Afro-
Asia) steel processing facility which is adjacent to the proposed site for the
galvanizing plant (Jacobs 2008)
The area consists largely of grasses succulents and scrubby bush with alien
species making up the greater part of the more dense vegetation
Zone 6 falls within the inland vegetation and is characterised by a vegetation type
referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the
Coega IDZ and has been found to have three times the level of endemism of other
vegetation communities in the Coega IDZ Bontveld therefore has a high
conservation status Two Bontveld conservation areas have been identified within the
IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)
Bontveld that will be destroyed as a result of development in the IDZ will be given
conservation status in these two areas
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-5
Figure 6 Coega IDZ Open Space Management Plan (OSMP)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-6
Certain areas in the IDZ are invaded by alien plant species The most common
invader species is rooikrans (Acacia cyclops) which presently forms large
monospecific stands in areas throughout the Coega IDZ There are several other
aliens present that pose a threat to the flora of this area including the prickly pear
(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)
Loss of vegetation and alien plant invasion due to human activity has resulted in a
reduction in the diversity of terrestrial fauna
The majority of mammals present in the Coega IDZ are small or medium-sized Of
the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed
gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of
Algoa Bay however it is not considered threatened The gerbil is common in
foredune and dune thicket habitat in the Coega region and is therefore unlikely to
occur on the proposed site
A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird
species are resident or common to the area Most diversity occurs in the thicket
although the coastal area also supports specialised avifauna Two species of tern
the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well
as the Cape gannet (Morus capensis) and the African penguin (Spheniscus
demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne
caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant
(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser
flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns
are two of the most endangered coastal species in South Africa Other bird species
of conservation concern include the Whitefronted plover (Charadrius marginatus)
African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus
bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus
ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides
paradisea) Breeding pairs of Damara terns and African black oyster catchers have
been observed in the coastal dunes of the IDZ but should not be affected by
developments that fall outside the dune areas
The Eastern Cape supports nearly a third (approximately 133 species) of the reptile
species recorded in South Africa More than half of the Eastern Capersquos endemic
reptile species occur in the Algoa Bay area giving the region a high conservation
value A total of 63 reptile species are believed to occur within the Coega IDZ The
majority of these are found in Succulent Thicket and riverine habitats Only a few
reptile species occur in the coastal dunes and estuarine habitats More than a third of
the species are described as relatively tolerant of disturbed environments provided
that migration corridors of suitable habitat are maintained to link pristine habitats
Twenty two reptiles are of special concern including five endemic species (two of
which may also be endangered) four endangered sea turtles eight species listed
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-7
with CITES one rare species and four species at the periphery of their range
Fourteen of these species of special concern are confirmed as occurring on or within
2 km of the Coega IDZ
A total of 32 amphibian species and sub-species occur in the Eastern Cape
representing almost a third of the species recorded in South Africa However none of
the species are endemic or Red Data Book species Based on previous studies in the
area it is estimated that approximately 17 amphibian species occur within the Coega
IDZ Four species are listed as peripheral but none are threatened internationally
These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog
(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and
the bubbling kassina (Kassina senegalensis)
The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated
vegetation has not been extensively studied One grasshopper species Acrotylos
hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue
(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis
pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in
four localities in the Eastern Cape one of which is within the Coega IDZ The Coega
copper Aloeides clarki is endemic to this particular region of the Eastern Cape and
is currently known to occur in three localities two of which are in the Coega IDZ The
localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the
Coega IDZ and their distributions were taken into account when defining Coegarsquos
open space system and Development Framework Plan
435 Land use and topography
The land is currently undeveloped and earmarked for industrial development The
site is relatively flat ranging from an elevation of 66 masl on the northern-most
corner to 59 masl at the southern-most corner
436 Heritage and archaeological survey
Extensive studies have been undertaken in Zone 6 with respect to heritage aspects
Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a
2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond
2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is
currently being finalised
Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing
Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha
in extent and was located next to the R102 road to Motherwell Kaplan conducted
HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi
Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will
now be located in Zone 5)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-8
The various archaeological investigations reached similar observations and
conclusions Stone tools of various densities and types were found throughout the
zone The majority of the stone tools were mainly of Earlier and Middle Stone Age
and occasional Later Stone Age origins (Figure 4)
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble
gravels exposed by tracks in Zone 6 (Source Binneman 2010)
The stone tools which comprised of quartzite flakes chunks flaked pebblecobble
and cores were randomly distributed across the landscape and are in secondary
context There were no lsquoconcentrationsrsquo of tools observed which suggested any
spatial patterning or activity areas although these may be present or covered by soil
and vegetation
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 5-1
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED
The following environmental issues and potential impacts were identified in the
Scoping phase
51 AIR QUALITY
The galvanizing process generates atmospheric emissions with particulates and
hydrogen chloride representing the main pollutants of concern The plant is fitted with
air extraction as well as scrubber systems which are designed to retain the bulk of
pollutants and particles for each of the processes in such a way that less than 5 ppm
of gases and particles will be released into the atmosphere after the fume scrubber
Other sources of impact on air quality include emissions from the LNG burner as well
as emissions and dust from the transport of steel and other materials in trucks
Construction activities will also create dust and gas emissions due to the clearing of
groundcover tipping of material to storage pile levelling of area wind erosion from
storage piles vehicle and construction equipment activity and tailpipe emissions
from vehicles and construction equipment such as graders scrapers and dozers
Overall the air quality impact assessment (Gruenewaldt 2011b) found that
The predicted particulate oxides of nitrogen carbon monoxide and sulphur
dioxide concentrations are all below the National Ambient Air Quality Standards
for all averaging periods
The predicted off-site concentrations of hydrogen chloride are well below the
most stringent effect screening levels
No odour threshold exceedances for hydrogen chloride were predicted to occur
due to routine operations at the Steel Galvanising Plant The South Wales
Environmental Protection Authority stipulates that an odour unit of 20 is
acceptable for urban areas The odour unit would be lt10 directly off-site for
hydrogen chloride
Abnormal emissions can occur in exceptional circumstances Start-up will not
cause abnormal emissions as the scrubbers will be commissioned first and will be
functioning once the plant starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions would be emitted as a
building fugitive
The hourly hydrogen chloride ground level concentrations (directly offsite) were
predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based
on the emission limits as stipulated for listed activities for galvanising processes)
using a screen model which assumes worst case meteorological conditions The
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-2
health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming
abnormal emissions emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset conditions will still
be well within the health effect screening levels
Similarly the hourly particulate emissions from the building fugitives during upset
conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for
listed activities for galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly
off-site
Therefore if emissions are 5 times higher normal they will still be within health effect
screening levels and the daily PM10 NAAQS levels
In the case of a fire a cocktail of gases and particulates could be emitted and could
be over the recommended levels This situation will however be dealt with as an
emergency and normalised as quickly as is possible
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS
The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of
its heritage potential and there are no proposed protected geosites in Zone 6
Should any artefacts be discovered during construction procedures stipulated in the
draft EMP will apply
53 BIODIVERSITY AND CONSERVATION
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
In terms of terrestrial fauna the CDCrsquos open space management plan provides for
the preservation of certain corridors The destruction of certain habitats as a result of
the development will therefore not automatically result in the loss of certain species
54 WATER QUALITY
There is a natural attenuation pond on the southern most part of the site which will be
avoided
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through
spills or leaks
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-3
This risk can however be minimized if not avoided altogether The floor of the factory
will be designed as a bunded area to contain any spills and the entire process will be
contained Potential spills or leaks will therefore be contained and will not impact on
water resources Storm water is therefore considered clean water under normal
operational conditions An oil trap will be placed at the exit of the site to ensure that
no grease from the laydown area enters the stormwater system
Spills and leaks can occur during the handling or the transport of hazardous
substances Best practice guidelines will be followed to ensure that this risk is
adequately managed
Wastewater discharged to sewer will be treated to comply with municipal discharge
standards and is not expected to have an impact on the chemical characteristics of
the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be
discharged from the plant is small in relation to the total volume received at the
Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works
(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently
operated at 61 of its capacity which is approximately 80 Mℓday Thus the
0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore
not have any significant impact on the WWTW
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES
The plant will generate a relatively small amount of solid waste in the form of scrap
metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)
The scrap metal may be sold to other steel processing facilities such as Agni Steel
which will be located next to the plant or collected and disposed of with the rest of
the solid waste by a licensed service provider
As mentioned previously there will be a wastewater treatment plant on site which will
neutralise process water (012 Mlweek) in order to ensure it is of a standard
acceptable for discharge to sewer Waste in the form of sludge from the
neutralization or spent acid must be disposed of as a hazardous waste Solid waste
from the filters used for air quality control is also in this category These wastes can
usually be tested and then delisted which means that it can be placed in a general
purpose landfill
Hazardous effluent from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-
site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored
and removed on a monthly basis is limited to 10 m3
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-4
A number of substances classified as hazardous are used in the galvanizing process
(Table 2) and the transport and handling of these is subject to certain rules and
guidelines In particular the material safety data sheets (cf Appendix H) should be
referred to for inter alia hazards identification accidental release measures
handling and storage precautions exposure controlpersonal protection ecological
information and transport information The Hazardous Chemical Substances
Regulations 1995 should also be adhered to in respect of the transport and storage
of hazardous chemical substances
Table 2 Hazardous materials to be used on site
Major Input Materials
Substance
listed in the
SABS 0228
Group II
hazardous
substances
Volumes to be
stored on site at
any one time
Diesel radic 2000 litres
Liquid petroleum radic 20 000 liters
Sodium hydroxide (NaOH)
(used for degreasing) 8 radic 1000m
3
Hydrochloric acid (HCI)
(used for pickling) 8 radic 800m
3
Zinc (used for galvanising) - TBD
Trivalent chromium (CR+3
)
(used for chromating) 8 radic 10m
3
Sulphuric acid (H2SO4) (used for
treatment of waste water on site) 8 radic TBD
Ammonium Hydroxide (NH4OH) 8 radic TBD
TBD ndash To be determined
Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one
time) and is classified as a flammable substance Specification for flammable storage
facilities in accordance with the requirements of the Nelson Mandela Bay
Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for
quantities between 5000 and 20 000 liters the substance must be kept in a
flammable liquid store which complies with the requirements of a specification
obtainable from the Department Some of the requirements are
Flammable liquid and solid storage facilities are only permitted on the ground
floor
Decanting of flammable liquids and solids are not permitted within any building
Due to the fact that there are flammable materials on site a certificate may be
required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and
Emergency Services Department to confirm that facilities for flammable storage
are in accordance with their requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-5
Because of the permanent installation and high quantity of liquid petroleum on site
the Major Hazard Installation Regulations 2001 promulgated under the Occupational
Health and Safety Act No 85 of 1993 applies A written application for approval of
the installation is required to be submitted to the chief inspector Department of
Labour provincial director Department of Labour and NMBM prior to construction
In addition a risk assessment should be formulated covering all hazardous materials
together with an emergency preparedness and response plan
56 HEALTH AND SAFETY
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling instructions as well as occupational exposure limits
are indicated in the material safety data sheets of the various substances used
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as
provide site supervision including executing tests (individual test cold run and hot
run) during 3 months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the
EMP
In addition the emergency preparedness and response plan will cover the health and
safety aspects related to emergency situations
57 TRAFFIC
The volumes of traffic at the IDZ are currently relatively low and variable depending
on the different zones in the IDZ however these volumes will increase as more
developments are implemented
The construction phase of the Casa Steel development will take about 12 months
and will essentially consist of erecting a building to house the galvanizing line and
other equipment and preparing a concrete laydown area adjacent to the building
The traffic that would be generated during the construction phase can be expected to
be less than the traffic that would be generated by the Casa Steel development when
it is fully operational
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-6
In the operation phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and
from the Port of Ngqura
The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the
Casa Steel development would be off Ring Road 1 The other roads of significance
for the Casa Steel development are the N2 Neptune Road MR435 and MR450
Access to the port is given by Neptune Road Road Link NEP-03 has not yet been
built
Figure 8 Coega IDZ road network identification
(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-7
Figure 9 Coega IDZ road network
Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No
01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-8
The distribution of freight trips is fixed as the majority of trips will be made between
the Port of Ngqura and the Casa Steel site With regard to personnel trips there are
various points of origins (the surrounding residential areas) that could be used by
staff going to the Casa Steel site The distribution of personnel trips is based on
existing traffic count information and is shown in Figure 10
Figure 10 Trip distribution for freight and personnel trips
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The resultant expected Casa Steel traffic assignment is shown in Figure 11
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-9
Figure 11 Morning peak hour Casa Steel development traffic
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The traffic that is expected to be generated by the Casa Steel development is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low
and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)
Consultation has taken place with Transnet Port Authority (TPA) to establish the
impact of the galvanizing plant operations on traffic inside the port The additional
ships entering and exiting the port of Ngqura as a result of the proposed development
will have a negligible impact on port traffic and TPA indicated that it would be well
within the portrsquos capacity
58 NOISE
Noise is not foreseen to be a significant issue insofar as the noise levels inside the
plant and at the boundary of the site will not exceed the limits prescribed by the CDC
Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels
during the day and 60 decibels at night
Mitigation of noise impacts will be addressed in the design of the noise-emitting
components of the plant and their enclosures
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-10
59 SOCIO-ECONOMIC ASPECTS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of
NMBM There are no residents within the IDZ
The direct socio-economic impacts of the proposed project are thus limited to the
employment generated by the project during construction and operation Job creation
remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)
and the IDZ and Port of Ngqura are expected to become a significant catalyst to the
economic growth of the Municipality and the region with current investments at
Coega creating more jobs and stimulating the economy
In this context the proposed galvanizing plant will make a positive contribution
towards the achievement of these goals
There will be 50 to 60 employees during operation phase distributed as follows
Figure 12 Casa Steel organisation chart
Even though a large part of the inputs will be imported and the bulk of the production
output will be exported there will be some positive impacts for the economy of the
region and of South Africa in general Notably the requirements of the plant for
water electricity waste collection and disposal waste water treatment and transport
for example will create business for the various service providers and have an
indirect impact on employment and fiscal revenues as a result
From a visual impact point of view it can be anticipated that the landscape in the IDZ
will be significantly affected over time by developments related to the establishment
of the port and various industries
HEAD ( WORKS )
MGR ( COMM) MGR ( ADMNHR ) Manager marketing
MANAGER OPERATION MANAGER MANAGER MANAGER Q C
AC FIN PUR ampSTORE
PPC SH-GALV SH-tech
SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF
1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO
JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF
2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO
WORKERS WORKERS 7NOS
15 7
RAW MAT amp
DESP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 6-1
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
A description of the nature of the impact any specific legal requirements and the
stage (constructiondecommissioning or operation) will be given Impacts are
considered to be the same during construction and decommissioning The
significance of the potential impacts will be considered before and after identified
mitigation is implemented
The following criteria will be used to evaluate significance
Nature The nature of the impact will be classified as positive or negative and
direct or indirect
Extent and location Magnitude of the impact and is classified as
Local the impacted area is only at the site ndash the actual extent of the activity
Regional the impacted area extends to the surrounding immediate and
neighbouring properties
National the impact can be considered to be of national importance
Duration This measures the lifetime of the impact and is classified as
o Short term the impact will be for 0 ndash 3 years or only last for the period of
construction
o Medium term three to ten years
o Long term longer than 10 years or the impact will continue for the entire
operational lifetime of the project
o Permanent this applies to the impact that will remain after the operational
lifetime of the project
Intensity This is the degree to which the project affects or changes the
environment and is classified as
o Low the change is slight and often not noticeable and the natural functioning
of the environment is not affected
o Medium The environment is remarkably altered but still functions in a
modified way
o High Functioning of the affected environment is disturbed and can cease
Probability This is the likelihood or the chances that the impact will occur and
is classified as
o Low during the normal operation of the project no impacts are expected
o Medium the impact is likely to occur if extra care is not taken to mitigate
them
o High the environment will be affected irrespectively in some cases such
impact can be reduced
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 6-2
Confidence This is the level knowledgeinformation the environmental impact
practitioner or a specialist had in hisher judgement and is rated as
o Low the judgement is based on intuition and not on knowledge or
information
o Medium common sense and general knowledge informs the decision
o High Scientific and or proven information has been used to give such a
judgment
Significance Based on the above criteria the significance of issues will be
determined This is the importance of the impact in terms of physical extent and
time scale and is rated as
o Low the impacts are less important
o Medium the impacts are important and require attention mitigation is
required to reduce the negative impacts
o High the impacts are of great importance Mitigation is therefore crucial
Cumulative Impacts The possible cumulative impacts will also be considered
Mitigation Mitigation for significant issues is incorporated into the EMP for
construction
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 7-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS
71 IMPACTS DURING CONSTRUCTION
711 Air quality
Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris
handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine
particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural
operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks
and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)
Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Fugitive particulate emissions (dust)
related to construction activities Regional
Short
term Medium High High Medium Regional
Short
term Low High High Low
Construction vehicle gas emissions Regional Short
term Medium High High Medium Regional
Short
term Low High High Low
712 Heritage and archaeological resources
Naturedescription of impact excavation activities may impact on unidentified heritage resources
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-2
Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based
on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments
Heritage and archaeological
resources Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on unidentified heritage
resources Local
Short
term
Medium -
high Low High Low
713 Biodiversity and conservation
Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation
importance and cause soil contamination
Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species
Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan
and has compiled a list of protected species to be rescued (see draft EMP)
Biodiversity and conservation Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Loss of fauna and flora Local Perma
nent
Medium -
high High High High Local
Permanen
t Medium High High Medium
Soil contamination Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-3
714 Water related impacts
Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater
runoff spills and leaks Soil erosion
Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of
spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste
disposal Stormwater quality monitoring (see draft EMP)
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Soil erosion Local Short
term Medium Medium High Medium Local
Short
term Medium Low High Low
715 Waste management
Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed
Commentmitigation see draft EMP and waste management plan
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-4
Waste management Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Local
Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
716 Health and safety
Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Short
term
Medium -
high
Medium -
high High High Local
Short
term
Medium -
high Low High Low
717 Traffic
Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and
construction workers from surrounding areas and transport of equipment from the port
Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low
Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and
accurate estimates of quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-5
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Increased traffic on N2 and within the
IDZ Regional
Short
term Low High High Low
718 Noise
Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Short
term
Medium-
high High High Medium Local
Short
term Medium High High Medium
719 Socio-economic
Naturedescription of impact temporary employment will be created during the construction phase
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-6
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Temporary employment Regional Short
term Medium High High Medium
72 IMPACTS DURING OPERATION
721 Air quality
NatureDescription of impact gas and particulate emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning
Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local
sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and
veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute
to background fine particulate concentrations (von Gruenewaldt 2011b)
Assumptions and limitations Potential release of CR6+
As no emission factors are available for trivalent chromium processing the
potential impacts due to these activities could not be quantified
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Dust emitted from traffic on paved roads Regional Long Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-7
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
term
Hydrogen chloride emissions from
pickling process Local
Long
term Low High High Low
Particulate emissions (smoke) from
galvanizing process (due to the
volatilization of flux)
Local Long
term Low High High Low
Particulate oxides of nitrogen carbon
monoxide and sulphur dioxide emissions
from LNG burner
Local Long
term Low High High Low
Nuisance related to odour Local Long
term Low Low High Low
Abnormally high hydrogen chloride and
particulate emissions due to scrubber
malfunction
Local Short
term Medium Low High Medium
Gases (eg SOx NOx CO etc) and
smoke emitted in case of a fire Local
Short
term High Low High Medium
722 Water quality
NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks
Commentmitigation see draft EMP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-8
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Stormwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
723 Waste management and hazardous substances
NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous
waste both can affect environmental quality and human health
Commentmitigation see draft EMP and waste management plan
Waste management and hazardous
substances Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Regional
Long
term High
Medium -
high High High Regional Long term High Low High Low
Soilwaterair pollution due to improper
transport storage and handling of
hazardous substances
Regional Long
term High
Medium -
high High High Regional Long term High Low High Low
Health hazard Local Long
term High
Medium -
high High High Local Long term High Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-9
724 Health and safety
Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Long
term
Medium-
high
Medium-
high High High Local Long term
Medium-
high Low High Low
725 Traffic
Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on
the road network
Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak
hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road
network within Zone 6 of the IDZ (Iliso 2011)
Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)
Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of
quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-10
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on traffic and capacity of the N2 Regional Long
term Low High High Low
Impact on traffic and capacity of ring
road 1 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR435 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR450 Local
Long
term Low High High Low
Impact on traffic and capacity of
Neptune road Local
Long
term Low High High Low
726 Noise
Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Long
term Medium High High Medium Local Long term Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-11
727 Socio-economic
Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate
revenue for the municipality and the region as a whole
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Employment and economic growth Regional Short
term Medium High High Medium
73 COMPARATIVE ASSESSMENT OF IMPACTS
During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as
low during operation after mitigation
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 8-1
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
As a tenant operating in the IDZ Casa Steel will be required to comply with all
current and future CDC requirements as well as with the relevant conditions of
permits licences issued to CDC (eg Integrated Stormwater Masterplan for the
eastern side of the Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)
In particular the CDC has its own requirements regarding the monitoring of certain
aspects of the project such as the quality of the effluent and the noise levels These
have been incorporated into the EMP
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 9-1
9 ENVIRONMENTAL IMPACT STATEMENT
All predicted negative impacts can be mitigated to a low significance The only
exceptions are biodiversity as the construction of the plant will result in the
destruction of habitat and loss of fauna and flora and noise impacts inherent to
construction activities Mitigation measures have been included in the EMP for these
impacts and they have a medium significance post-mitigation
Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium to
long term similar impacts are likely to occur due to ongoing developments in the IDZ
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 10-1
10 CONCLUSION AND RECOMMENDATIONS
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as
other infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified
and assessed No fatal flaws have been identified
It is recommended that the project be approved subject to the conditions listed in
chapter 9 and adherence to the EMP requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 11-1
11 REFERENCES
Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ
Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants
Bennie JS (2010) The historical component (built environment) of the Heritage
Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port
Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report
compiled for Eastern Cape Heritage Consultants
Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater
Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay
Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage
Consultants
BKS (2006) Coega Industrial Development Zone Transport Study Volume 3
Demand Modelling Report Final Draft
Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I
Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6
Report compiled for SRK Consulting
Coastal amp Environmental Services (2010) Environmental Impact Assessment for the
Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone
Volume 3 Environmental Impact Assessment Report CES Grahamstown
Coega Development Corporation (2008) Industry Waste Management Plan -
Strategic Master Plan Report
Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants
Report No CDCSHE 03 8122
Department of Water Affairs and Forestry (1998) Waste Management Series
ldquoMinimum Requirements For The Handling Classification And Disposal Of
Hazardous Wasterdquo Second Edition
Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising
Plant in the Coega Industrial Development Zone
Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the
Coega Industrial Development Zone (IDZ) Specialist Water Study
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 11-2
Jacobs E (2008) Final Environmental Impact Report and Draft Environmental
Management Plan Proposed Steel Recycling and Processing Facility within the
Coega IDZ Report compiled for SRK Consulting
Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY
Galvanising Plant in the Coega Industrial Development Zone Waste Management
and Hazardous Substances Report compiled for ILISO Consulting
RSA National air quality standard for thoracic particulates (PM10) SA standards
(Government Gazette No 32816)
von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed
Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape
Report compiled for ILISO Consulting
von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel
Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report
compiled for ILISO Consulting
Additional sources
Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed
Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared
for Coastal Environmental Services
Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed
Kalagadi Manganese smelter in the Coega Industrial Development Zone Port
Elizabeth Eastern Cape Province Report prepared for Coastal Environmental
Services
Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia
steel recycling facility at the Coega Industrial Development Area Port Elizabeth
Prepared for SRK Consulting Port Elizabeth
APPENDIX A
LIST OF INTERESTED AND
AFFECTED PARTIES
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
DEDEARegional Manager
and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza
DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza
DEA Ocean and
CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza
DEA Ocean and
Coast
Oceanographer land-
based sources of
marine pollution
Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza
DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza
CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza
CDCEnvironmental
Project
Manager
Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza
TNPAPort of Ngqura
Environmental
Manager
Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet
NMBMEnvironmental
ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza
NMBMEnvironmental
ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza
DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza
DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza
WESSASenior Conservation
Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza
Zwartkops
ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700
hughlauegmailcom
zwartkopstrustiafricacom
SANParksNational Marine
CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza
Department Of
LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza
NMBM Air Quality
Division
Assistant
DirectorAir
Pollution and Noise
Templeton Titima 079 490 0574 Ttitimamandelametrogovza
NMBM Air Quality
DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza
NUMSARegional
RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
Department of
HealthNadiema
van der
Bergh083 378 2103
nadiemavanderberghimpiloecprovgov
za
DWA Chief Services
Officer
Joseph Jacobs 041 586 4884 jjacobsdwafgovza
EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza
NUMSecretary of union
officesZandile Xhentsa 043 743 6597 zxhentsanumorgza
DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza
Dynamic
CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom
EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza
Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza
UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom
lprincezago2uticom
Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza
Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza
Absa Mr Johann Steyn 082 3775820 johannstabsacoza
Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza
PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza
Universal
EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza
Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza
GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom
Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza
NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom
DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza
DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza
TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet
DWA Mr Landile Jack JackLdwagovza
DWA Ms Lizna Fourie FourieL4dwagovza
APPENDIX B
NOTICE OF ATMOSPHERIC
EMISSIONS LICENCE APPLICATION
AND ADVERTISEMENT
APPENDIX C
NOTICE OF COMMENT PERIOD FOR
DRAFT SCOPING REPORT
APPENDIX D
SUMMARY OF ISSUES RAISED AND
RESPONSES THERETO
April 2012
1
PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL
DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))
IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt
AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt
This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses
provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process
conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the
Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
2
IssueCommentQuestion Date
received Origin Response
1 Please provide more information with respect to the potential
dangers including the toxicity of the proposed project
07032011
By email
Wayne Poulton
(Bosun Brick
tenant at the
IDZ)
An Environmental Impact Assessment (EIA) was undertaken
which assessed the potential toxicity of the emissions and
effluent Mitigation measures were also recommended in the draft
Environmental Management Programme (EMP) to avoid
minimise or compensate any significant impacts The Draft
Environmental Impact Report and draft EMP were made available
to stakeholders for comment in March 2012
2 Do you have a Background Information Document (BID) or
similar that provides more information on the project
27032011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The BID was sent to all registered IampAPs on 4 May 2011
3 The RoD issued to the CDC on 632007 for the change in
land use for the remaining area of the Coega IDZ includes a
number of requirements with respect to
atmospheric emissions that should be considered in the
Atmospheric Emissions Licence (AEL) application such as
prohibiting and monitoring where possible visible emission
plumes to the atmosphere In particular the
recommendations on pp87-91 of the final revised Scoping
Report dated Nov 2006 must be implemented (clause 421)
04042011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
We have obtained copies of the documents referred to and ensure
that these requirements were taken into account in the
environmental assessment and AEL application
4 If the Port of Ngqura is used for import and export the scope
of the traffic impact assessment (TIA) should also include the
port
10052011
By email
Elliot
Motsoahole
(TNPA Port of
Ngqura)
The scope of the TIA was extended to include port related traffic
The TNPA at the Port of Ngqura was consulted and does not
have any objection to the project TNPA has indicated that the
development would require a minimum number of vessels per
year which would have minimal impact on the Port operations
However due notice would have to be given to the Port of Ngqura
before a vessel is scheduled to arrive so that the vessel can be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
3
IssueCommentQuestion Date
received Origin Response
accommodated at an available berth
5 Concerns with respect to potential stormwater pollution
draining into the Coega catchment and the port of Ngqura
The port needs to be dredged and heavy metals present a
risk in that regard
16052011
By
telephone
Andrew Lucas
(Department of
Water Affairs)
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination by effluent waste or
hazardousdangerous substances is very low
Thus no metals oils or other contaminants are expected to be
present in the stormwater
However stormwater pollution can occur in exceptional
circumstances such as accidents and emergencies The
emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
6 All steel sheets bathing unit must be under roof
7 The sludge out of the decreasing bath will be high in Na and
pH Therefore handling and disposal must be clarified up front
in this project
8 Per se the wastewater from decreasing bath will have high
ph and the component from the pickling unit will have low ph
Then it may be assumed that both streams will neutralize
each other Please then clarify proposed sewer discharge
with Nelson Mandela Bay Municipality up-front for acceptance
of influent as per the documented proposal
9 Pickling may result in dissolved metals How does your team
expect to deal with this As it is planned for discharge into
24052011
By email
Landile Jack
(Department of
Water Affairs)
All bathing units will be under roof
Effluent from the degreasing and pickling baths will be discharged
to the wastewater treatment plant The respectively alkaline and
acidic effluents will mix and neutralise each other in the
wastewater treatment plant Calcium or gypsum will be added if
required to complete the neutralisation process Effluent from the
treatment plant will be discharged to sewer Contact has been
made with the relevant officials and the Municipalityrsquos
requirements have been obtained The effluent discharged to
sewer will notably comply with the applicable discharge standards
Traces of metals (eg iron) may be present but will not exceed
prescribed thresholds The necessary authorisation will be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
4
IssueCommentQuestion Date
received Origin Response
sewer Clarity and acceptance needs to be agreed with
Nelson Mandela Bay Municipality Who owns the sewer
10 Quenching unit will results to Zinc particles How will this
affect sewer discharge This again must be dealt with within
the negotiations with the Municipality
11 Once all has been agreed with the Municipality and at the
same time due negotiations must be done with hazardous
waste courier and disposal facility to accept the hazardous
waste identified in all production lines
12 Of note is the low volume of the proposed WWTW facility ie
250 cubmweek And the no discharge of the quenching
water ie over-flow and cooling only Hence Zinc particles
generation
obtained from the municipality
The sludge from the treatment plant will be collected by a licensed
service provider and disposed of at a permitted site
The quenching bath will be periodically emptied (every 6 months)
and the water discharged will go to the water treatment plant Zinc
particles will settle in the sludge which will be disposed of at a
permitted site
Contact has been made with EnviroServ who manages the
Aloes II HH waste site regarding collection and disposal of
hazardous waste (See waste management report)
13 Investigate the potential effects of toxicity andor influence of
emissions waste and hazardous substances both in
terrestrial and marine fauna
14 With regards to water usage where is the plant going to
extract its waters used in galvanization andor waste
management process ie rainfall rivers or even from the
sea) and which avenues would be more environmental
friendly and effective
31052011
By email
A Bewana
(SANPARKS)
Emissions waste and hazardous substances are not expected to
affect terrestrial or marine ecosystems The air quality study
concluded that atmospheric emissions would not be harmful to
human health and by extension terrestrial fauna There are no
standards for air quality for defining faunal impacts therefore by
ensuring that standards for humans are complied with the impact
on fauna is deemed to be acceptable In this case the impact of
emissions on terrestrial and marine fauna are thus not significant
Solid and liquid wastes both general and hazardous as well as
hazardous substances will be stored handled and disposed of
appropriately to as not to cause harm to terrestrial or marine
fauna
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
5
IssueCommentQuestion Date
received Origin Response
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination and hence land-based
marine pollution by effluent waste or hazardousdangerous
substances is very low
The risk of emissions waste and hazardous substances to
terrestrial and marine fauna is thus very low
However pollution of terrestrial and marine ecosystems can occur
in exceptional circumstances such as accidents and emergencies
The emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
The CDC has an agreement with the NMBM to supply potable
water to the Coega IDZ Currently the infrastructure to supply
return effluent (RE) to the IDZ is not in place therefore Casa Steel
will be supplied with potable water up until such time as the
following 2 options of RE are available
1) Upgrading of the existing Fishwater Flats waste water
treatment works (between IDZ amp PE) including RE plant
and infrastructure to pipe RE to the IDZ (EIA for the
upgrade is underway)
2) Construction of a new waste water treatment works
including RE plant in Zone 9 of the Coega IDZ
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option should be investigated further between Agni and Casa The
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
6
IssueCommentQuestion Date
received Origin Response
CDC can facilitate discussions between the 2 investors
Compliance with CDC Permits amp Requirements
15 It should be made clear that tenants will be required to
comply with CDC requirements and the relevant conditions of
permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water
Licence for its Storm Water Systems on the
East Side of the Coega River that tenants will
need to take cognizance of The contents of the
ldquoIntegrated Stormwater Masterplan for the
eastern side of the Coega IDZ Oct 2010rdquo
especially the Table of best practice p53
onwards may need to be taken cognizance of
o CDC is developing an Operations
Environmental Management Plan that will place
certain obligations on tenants
16 Environmental audits and data collected during monitoring
(eg stack emissions stormwater) will need to be shared with
CDC
Air Emissions
17 Presumably permanent in stack monitoring will be required in
terms of AEL permit requirements
18 Abnormal operating conditions resulting in air emissions ndash I
could find nothing in the EIR to indicate under what
circumstances these could occur (eg start-up) potential
frequency and duration and the impact on ambient air quality
ndash these events usually result in the most problems wrt air
emissions
09042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
15 Compliance with the CDCrsquos Permits amp Requirements has
been included explicitly as a requirement in the EIR (p8-1) and
EMP (pp18 and 25) in the following terms
ldquoAs a tenant operating in the IDZ Casa Steel will be required to
comply with all current and future CDC requirements as well as
with the relevant conditions of permits licences issued to CDC
(eg Integrated Stormwater Masterplan for the eastern side of the
Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)rdquo
16 The need to communicate with the CDC on monitoring and
auditing activities was emphasised in Chapter 8 of the EMP The
following paragraphs were added
ldquoDuring construction the environmental officer will be responsible
for monitoring compliance with the EMP and authorisation
conditions and keeping records as required in the EMP andor
authorisation conditions
The ECO will conduct site inspections every two weeks audit the
records kept by the environmental officer and submit an
environmental compliance report every two months to the
authorities and the CDC (via the Environmental Monitoring
Committeersquos ECO)
During operation the health and safety officer will monitor
compliance with the EMP and the conditions of the Environmental
Authorisation Data collected during monitoring activities and any
environmental audits conducted will be shared with authorities
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
7
IssueCommentQuestion Date
received Origin Response
Water
19 Large volumes of (2000 m3mth) of water are required of
which only 400m3 needs to be potable The NMBM return
effluent system will provide non-potable water once it is
constructed What other water recycling initiatives can be
utilized to reduce potable water requirements (the ISWMP for
the eastern side of the Coega IDZ has some best practice
guidelines collecting rainwater from the roof etc)
General
20 There is no mention of how the CDC Architectural Guidelines
will be incorporated into the development (eg to prevent a
stark uniform warehouse type development)
21 Does NMBM have adequate fire services to cover this
development Apart from the large petroleum store are there
any other large fire hazards
22 Reports from the tenantrsquos ECO during construction and from
the SHE Officer during operations should be channeled to the
Coega Environmental Monitoring Committee This can be
directly or preferably via the EMCrsquos ECO (this will be while
the EMC and ECO are in place) A precedent has been set
for this in the Environmental Authorisations for Agni-Steel and
Kalagadi Manganese Smelter
23 All mitigation actions emanating from the EIR should be
summarized (preferably in a table) If compliance with them is
to be part of the Environmental Authorization from DEDEAT
then they (or the ones that DEDEAT deems to be applicable)
and the CDC (via the Environmental Monitoring Committeersquos
ECO)
The ECO (during construction) and the health and safety officer
(during operation) will report to the Coega Environmental
Monitoring Committee (EMC) via the EMCrsquos ECO (this will be
while the EMC and ECO are in place)rdquo
17 The draft EMP recommends regular monitoring of emissions
from the scrubbers and from the chromating process Additional
emissions monitoring requirements will be confirmed once the
AEL is issued Mention has been made in the EMP (pp11 and 19)
that all AEL conditions including monitoring and reporting
requirements should be adhered to
18 Abnormal emissions can occur in exceptional circumstances
Start-up will not cause abnormal emissions as the scrubbers
will be commissioned first and will be functioning once the plant
starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions
would be emitted as a building fugitive
The hourly hydrogen chloride ground level concentrations
(directly offsite) were predicted to be 239 microgmsup3 (based on the
emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits
as stipulated for listed activities for galvanising processes) using a
screen model which assumes worst case meteorological
conditions The health effect screening level for hourly HCl
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
8
IssueCommentQuestion Date
received Origin Response
should be attached to the EA as an Appendix (otherwise no
one knows about them or takes cognizance of them)
concentrations is 2100 microgmsup3 Assuming abnormal emissions
emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset
conditions will still be well within the health effect screening
levels
Similarly the hourly particulate emissions from the building
fugitives during upset conditions would amount to 293 microgmsup3
(based on the emission limits as stipulated for listed activities for
galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1
January 2015) directly off-site
Therefore if emissions are 5 times higher normal they will still be
within health effect screening levels and the daily PM10 NAAQS
levels
In the case of a fire a cocktail of gases and particulates could be
emitted and could be over the recommended levels This
situation will however be dealt with as an emergency and
normalised as quickly as is possible
The above has been added to the impact identificationdescription
and assessment sections of the EIR
19 The CDC has an agreement with the NMBM to supply
potable water to the Coega IDZ Currently the infrastructure to
supply return effluent to the IDZ is not in place therefore Casa
Steel will be supplied with potable water up until such time as the
infrastructure is in place
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
9
IssueCommentQuestion Date
received Origin Response
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option will be investigated further between Agni and Casa The
CDC has come forward to facilitate discussions between the two
investors
Other water recycling initiatives such as rainwater harvesting
have been considered but are not practical
20 The CDCrsquos Architectural and Landscape Design guidelines
contain requirements pertaining to such aspects as the height
orientation and mass and form of buildings as well as guidelines
for landscaping and signage in order to ensure an attractive
development and achieve an architectural integrity within the
Coega IDZ The plans for the proposed galvanizing plant will be
submitted to the Design Review Committee for approval as
required by the CDC
21 Casa Steel will be required to install fire hydrants according
to the NMBMrsquos standardsrequirements The CDC will provide
potable water (up until such time as return effluent is available)
and a connection to the boundary of the site which will be
connected to the fire hydrants The installation of the fire hydrants
will require approval by the Metrorsquos Fire Chief as was done for
Agni-Steel one of the investors in Zone 6
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
10
IssueCommentQuestion Date
received Origin Response
The Coega IDZ falls within the NMBM and therefore the rates and
taxes paid by the CDC covers the fire services for which the Metro
is responsible Currently the Metro has sufficient capacity to
provide fire services to the tenants within the IDZ This was
confirmed in discussion with the CDCrsquos Infrastructure
Development Unit It is however unknown at which point the
Metrorsquos Disaster Management Plan would not be able to
accommodate servicing tenants in the IDZ
The LNG burner is the only major fire hazard on the plant
22 See response to item 16 above
23 Key mitigation and management measures emanating from
the EIR were recapitulated in Chapter 9 of the EIR to form part of
the conditions attached to the Environmental Authorization from
DEDEAT All mitigation measures recommended as a result of the
impact assessment are presented in a table in the draft EMP
which is appended to the EIR (Appendix J)
24 Hydrogen chloride is one of the main emissions There are no
ambient air quality guidelines for HCl and the EIR says
concentrations will be well within health parameters
However the main problem with HCl is its corrosive effect -
there is absolutely no mention of this in the draft EIR nor air
specialist report
There needs to be some sort of comment assessment as to
whether HCl emissions are likely to impact on for example
the adjacent Agni-Steel Plant wrt corrosion - their factory
structure will be made of steel
11042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The atmospheric corrosion of metals is a complex process with
both the extent of deterioration and the mechanisms varying
considerably depending on the metal Depending on the way
pollutants are transported from the atmosphere to the corroding
surface two types of deposition processes are recognized in
atmospheric corrosion ndash dry deposition and wet deposition Wet
deposition refers to precipitation whereas dry deposition refers to
the remaining processes including gas phase deposition and
particle deposition The most important pollutants acting as
corrosive agents are sulphur and nitrogen compounds including
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
11
IssueCommentQuestion Date
received Origin Response
The EIR specialist rpt suggests monitoring HCl at ground
level on the property boundary and this is supported in case
there are complaints from neighbours
secondary pollutants and particulates Pollutants can contribute to
corrosivity individually however there may be a synergistic effect
when more than one of these pollutants is present in the
environment being affected In the field of atmospheric corrosion
sulphur dioxide is the single most investigated gaseous pollutant
and the quantification of the direct contribution of sulphur dioxide
to the corrosion process of metallic materials is comparatively well
understood (Tidblad amp Kucera 1998)
Very little work has reported on the effect of HCl on the
degradation of materials in the environment with no local dose-
response thresholds developed for corrosion occurring due to HCl
exposures This is probably because HCl which is present
outdoors in markedly reduced concentrations when compared
with SO2 has not been considered to contribute to significant
degradation of materials (Syed 2006) For this reason the
incremental corrosion due to HCl from the Coega Galvanising
Plant cannot be quantified
25 It is unacceptable for ILISO to be using CDC maps (see
figure 9 ndash pg5-6) without these maps being referenced
accordingly particularly when it appears that a CDC map has
been used and then overlaid with features by an unknown
author (ie CASA steel site Port (where the boundaries
depicted are incorrect) and a North legend which is out of
keeping with the overall cartographic intent of the original
work
26 Figure 10 is not referenced appropriately and I believe that I
commented previously in respect to references to roads not
12042012
By email
Graham Taylor
(Spatial
Development
Manager -
Infrastructure
Development
CDC)
This has been rectified in the final version of the report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
12
IssueCommentQuestion Date
received Origin Response
yet built As a result Figure 10 is confusing and clarity needs
to be provided in terms of referencing In addition the Port
shape is irregular and similar to the comment above
27 I acknowledge the emergency preparedness and response
plan but please confirm that this includes pro-active routine
monitoring of storm water leaving your premises to verify that
your assumptions of clean storm water are correct
13042012
By post
Andrew Lucas
(Director
WRampU
Department of
Water Affairs)
Pro-active routine monitoring of stormwater leaving the premises
will be undertaken This has been explicitly emphasised in
chapter 8 of the draft EMP
28 Will portablechemical toilets be used during construction
29 What provisions have been made for storm water drainage
during construction
18042012
By
telephone
Department of
Water Affairs
Port Elizabeth
Chemical toilets will be used during construction
The Casa Steel site will be located at the corner of two roads
drainage of stormwater from the site will take place through the
roadsrsquo drainage system
From Lea September [mailtoleailisocom]
Sent 11 March 2011 0935 AM
To Wayne Poulton
Cc Terry Baker
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Wayne
An Environmental Impact Assessment (EIA) will be undertaken for this project during the
next 10 to 12 months
We foresee that some of the key environmental impacts of the project will be in terms of air
quality water quality waste and hazardous substances
At this stage I am not able to give you any details regarding the potential toxicity of the
emissions andor effluent However specialist studies will be conducted as part of the EIA
that will determine the key impacts of the project Mitigation measures will also be identified
to avoid minimise or compensate any significant impacts
You are registered on the stakeholder database and you will be kept informed of progress in
the EIA process you will notably get the opportunity to access the reports produced and
provide any feedback on them
Please feel free to contact me should you need any further information
Best regards
Lea September
From Wayne Poulton [mailtowaynepbosuncoza]
Sent 07 March 2011 1257 PM
To Lea September
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
Please can you provide me with some more information as to the potential dangers including
the toxicity of this
Kind regards
Wayne
From Lea September [mailtoleailisocom]
Sent 04 March 2011 1123
To Lea September
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 March 2011 0745 AM
To Paul Martin
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 05 April 2011 0847 AM
To Paul Martin
Cc Terry Baker Renee von Gruenewaldt
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Thank you Paul for this information
I have downloaded a copy of the RoD and Scoping report you referred to and will make sure
these requirements are taken into account in the environmental assessment
Best regards
Lea September
From Paul Martin [mailtopmartinaxxesscoza]
Sent 04 April 2011 0955 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Further to my comments on 27311
Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in
the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega
IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised
scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions
including prohibiting and monitoring where possible visible emission plumes to the atmosphere
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Paul Martin
Sent Monday March 28 2011 745 AM
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 10 May 2011 0327 PM
To ElliotMotsoaholetransnetnet
Cc Terry Baker
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Mr Motsoahole
Thank you for your input on this issue
The Port of Ngqura will indeed be used for import and export At the moment the scope of
the traffic impact assessment only covers road traffic I have however relayed the matter to
our traffic specialist and we will consider this issue in the finalization of the Scoping Report I
will keep you informed of any developments in that regard
I trust this is acceptable to you
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]
Sent 10 May 2011 0855 AM
To Lea September
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
It has been noted that Casa Steel will source steel coils from various markets internationally and
in South Africa and the bulk of the plantrsquos production output will be exported to African countries
However there is no mention of logistic requirements
Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will
be used the scope of traffic impact assessment should also include the port
Regards
From Lea September [mailtoleailisocom]
Sent 04 May 2011 0747 AM
To Lea September
Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
Please find attached a letter announcing the EIA process underway for the proposed 80 000
tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as
a Background Information Document (BID) outlining the details of the project
Please contact me should you require any further information on this project
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
Elliot Motsoahole
Manager - Environment
Transnet National Ports Authority
Port of Nqqura
Port Control Building Klub Road Port Elizabeth 6212
PO Box 612054 Bluewater Bay 6212
+27 41 507 8450
+27 86 674 7729
Cell +27 83 542 5619
E-mail Elliotmotsoaholetransnetnet
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
DISCLAIMER The information contained in this communication is subject to copyright and
intended only for the use of leailisocom Unauthorised use disclosure or copying is
strictly prohibited Should a virus infection occur as a result of this communication the sender
will not be liable If you have received this communication in error please notify
elliotmotsoaholetransnetnet
From Lea September [mailtoleailisocom]
Sent 25 May 2011 1147 AM
To Jack Landile (ELS)
Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi
Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Landile
Thank you for your input
Contact has been made with the relevant Municipal Directorate and we will follow up with
them to obtain clarifications on all these issues
I have added both Lizna and yourself on the database and will keep you updated on
progress on this project
Best regards
Lea September
From Jack Landile (ELS) [mailtoJackLdwagovza]
Sent 24 May 2011 0524 PM
To Fourie Lizna (ELS)
Cc Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Hi Lizna
I missed you on this sorry
I linked Pieter twice Instead
Regards
Landile
From Jack Landile (ELS)
Sent 24 May 2011 0445 PM
To leailisocom
Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Lea
The e-mail you sent to Mr Kooverji dated 19 May 2011 refer
Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are
All steel sheets bathing unit must be under roof
The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project
Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal
Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer
Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality
Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines
Of note is the low volume of the proposed WWTW facility ie 250 cubmweek
And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles
generation
Regards
Landile
From Lea September [mailtoleailisocom]
Sent 19 May 2011 0947 AM
To Lea September
Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Stakeholder
Please find attached the remaining appendices to the draft Scoping report for the proposed
80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 June 2011 0411 PM
To Aphiwe Bewana
Subject RE Proposed 80 000 TPY Galvanizing plant in Coega
Dear Mr Bewana
Thank you for your input and apologies for the late reply
We have taken note of your comments and are will be taking them forward in the EIA phase
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Aphiwe Bewana [mailtoaphiwebewanagmailcom]
Sent 31 May 2011 1205 PM
To Lea September
Subject Re Proposed 80 000 TPY Galvanizing plant in Coega
Comment
Re Proposed 80 000 TPY Galvanizing plant in Coega
As SANParks we would like the EIA phase to investigate the potential effects of toxicity
andor influence of emissions waste and hazardous substances both in terrestrial and
marine fauna In the draft scoping report reference has been made with regards to the
terrestrial fauna but there is no attention to potential effects to marine fauna
Equally with regards to water usage where is the plant going to extract its waters used in
galvanization andor waste management process ie rainfall rivers or even from the sea)
and which avenues would be more environmental friendly and effective
Regards
Aphiwe Bewana
Marine Planner
South African National Parks
POBox 76693
NMMU
Port Elizabeth
6031
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 06 July 2011 1031 AM
To Lea September
Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Hi Lea
Irsquove reviewed the Final Scoping Report Herewith a few comments
1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the
Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a
revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the
NMBLP Please include only those in the IDZ as part of your IAP list
Regards
Andrea
From Lea September [mailtoleailisocom]
Sent Wednesday July 06 2011 859 AM
To Lea Septemberrsquo
Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Dear Stakeholder
The final scoping report for the above-mentioned project (attached) is available for comment
until 27 July 2011
The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic
commentaryrdquo tab
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 09 April 2012 1159 AM
To Lea September
Subject Comments on Galvanising Plant EIR Coega IDZ
Lea
Attached are my comments on the Draft EIR for the Coega IDZ galvanising
plant
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
Email attachment
COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ
Dr Paul Martin PO Box 61029
Bluewater Bay 6212 Tel 041 4665698
Email pmartinaxxesscoza
Compliance with CDC Permits amp Requirements
It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of
o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants
Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC
Air Emissions
Presumably permanent in stack monitoring will be required in terms of AEL permit requirements
Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions
Water
Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)
General
There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)
Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards
Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter
All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 11 April 2012 1245 PM
To Lea September
Subject Fw Comments on Galvanising Plant EIR Coega IDZ
Lea
One other comment on that I have on the Galvanising Plant Draft EIR
Hydrogen chloride is one of the main emissions There are no ambient air
quality guidelines for HCl and the EIR says concentrations will be well
within health parameters
However the main problem with HCl is its corrosive effect - there is
absolutely no mention of this in the draft EIR nor air specialist report
There needs to be some sort of comment assessment as to whether HCl
emissions are likely to impact on for example the adjacent Agni-Steel
Plant wrt corrosion - their factory structure will be made of steel
The EIR specialist rpt suggests monitoring HCl at ground level on the
property boundary and this is supported in case there are complaints from
neighbours
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Paul Martin ltpmartinaxxesscozagt
To Lea September ltleailisocomgt
Sent Monday April 09 2012 1158 AM
Subject Comments on Galvanising Plant EIR Coega IDZ
gt Lea
gt
gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising
gt plant
gt
gt
gt Dr Paul Martin
gt PO Box 61029
gt Bluewater Bay 6212
gt Tel 041 4665698
gt Cell 0732524111
gt email pmartinaxxesscoza
gt
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 12 April 2012 1139 AM
To Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Hi Lea
Hope yoursquore keeping well
I have requested comments from my colleagues and the CDC Casa team on the Draft EIR
Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report
Regards
Andrea
From Graham Taylor
Sent Thursday April 12 2012 838 AM
To Andrea Von Holdt Firhana Sam
Cc Johan Fourie Maria van Zyl Melikhaya Sihawu
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Andrea Firhana
Firhana if you could please ensure that the co-ordinates provided in the EIR correspond
with our records (pages 4-1 amp 4-2)
My comments are as follows
It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work
Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above
Regards
Graham Taylor
Spatial Development Manager - Infrastructure Development
Mobile 0832283055
Office 0414030454
Facsimile 0865185033
Email GrahamTaylorcoegacoza
Website wwwcoegacom
right PLACE | right TIME | right CHOICE
This email and all contents are subject to the following disclaimer
httpwwwcoegacomemaildisclaimerhtml
From Lea September [mailtoleailisocom]
Sent 04 May 2012 0411 PM
To Andrea Von Holdt
Cc Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Dear Andrea
We have taken note of the comments from the GIS Unit These issues have been rectified in
the final version of the EIR
Please can you forward to the relevant persons at the GIS Unit
Thank you
Best regards
Lea September
APPENDIX E
BACKGROUND INFORMATION
DOCUMENT
APPENDIX F
AIR QUALITY IMPACT ASSESSMENT
APPENDIX G
TRAFFIC IMPACT ASSESSMENT
APPENDIX H
WASTE MANAGEMENT AND HAZARDOUS
SUBSTANCES SPECIALIST STUDY
APPENDIX I
WATER QUALITY SPECIALIST STUDY
APPENDIX J
ENVIRONMENTAL MANAGEMENT
PROGRAMME
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 i
PROPOSED 80 000 TPY GALVANIZING PLANT IN THE
COEGA INDUSTRIAL DEVELOPMENT ZONE
FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT
TABLE OF CONTENTS
ACRONYMS IV
EXECUTIVE SUMMARY V
1 INTRODUCTION 1-1
11 BACKGROUND 1-1
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS 1-1 13 PURPOSE OF THIS REPORT 1-2
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) 1-2
15 PROJECT TEAM 1-3
16 STRUCTURE OF THIS REPORT 1-4
2 DESCRIPTION OF THE PROPOSED PROJECT 2-1
21 TECHNICAL ASPECTS 2-1
211 The galvanizing process 2-1
212 Main inputs and outputs in operational phase 2-3
213 Installations on site 2-3
22 LOCATION OF THE PROPOSED GALVANIZING PLANT 2-4
23 NEED AND DESIRABILITY 2-6
24 ALTERNATIVES IDENTIFIED 2-6
25 CONSTRUCTION ASPECTS 2-6
26 OPERATION ASPECTS 2-7
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT 3-1
31 OBJECTIVES 3-1
32 AUTHORITY CONSULTATION 3-1
33 PUBLIC PARTICIPATION PROCESS CONDUCTED 3-1
34 LEGISLATION AND GUIDELINES CONSIDERED 3-2
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT 4-1
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION 4-1
42 SOCIO-ECONOMIC CHARACTERISTICS 4-3
43 BIOPHYSICAL CHARACTERISTICS 4-3
431 Surface and ground water 4-3
432 Climate and atmospheric conditions 4-3
433 Geology and soils 4-4
434 Terrestrial ecology 4-4
435 Land use and topography 4-7
436 Heritage and archaeological survey 4-7
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED 5-1
51 AIR QUALITY 5-1
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 ii
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS 5-2
53 BIODIVERSITY AND CONSERVATION 5-2
54 WATER QUALITY 5-2 55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES 5-3
56 HEALTH AND SAFETY 5-5
57 TRAFFIC 5-5
58 NOISE 5-9
59 SOCIO-ECONOMIC ASPECTS 5-10
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY 6-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS 7-1
71 IMPACTS DURING CONSTRUCTION 7-1
711 Air quality 7-1
712 Heritage and archaeological resources 7-1
713 Biodiversity and conservation 7-2
714 Water related impacts 7-3
715 Waste management 7-3
716 Health and safety 7-4
717 Traffic 7-4
718 Noise 7-5
719 Socio-economic 7-5
72 IMPACTS DURING OPERATION 7-6
721 Air quality 7-6
722 Water quality 7-7
723 Waste management and hazardous substances 7-8
724 Health and safety 7-9
725 Traffic 7-9
726 Noise 7-10
727 Socio-economic 7-11
73 COMPARATIVE ASSESSMENT OF IMPACTS 7-11
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME 8-1
9 ENVIRONMENTAL IMPACT STATEMENT 9-1
10 CONCLUSION AND RECOMMENDATIONS 10-1
11 REFERENCES 11-1
LIST OF FIGURES
Figure 1 Process flow diagram for proposed galvanizing plant 2-2
Figure 2 Continuous Galvanizing Line 2-3
Figure 3 Location of the proposed galvanizing plant 2-5
Figure 4 Zone layout in the Coega IDZ 4-1
Figure 5 Site location 4-2
Figure 6 Coega IDZ Open Space Management Plan (OSMP) 4-5
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble gravels
exposed by tracks in Zone 6 (Source Binneman 2010) 4-8
Figure 8 Coega IDZ road network layout (Adapted from BKS 2006) 5-6
Figure 9 Coega IDZ road network 5-7
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 iii
Figure 10 Trip distribution for freight and personnel trips 5-8
Figure 11 Morning peak hour Casa Steel development traffic 5-9
Figure 12 Casa Steel organisation chart 5-10
LIST OF TABLES
Table 1 Coordinates of site corners for the proposed galvanizing plant 4-1
Table 2 Hazardous materials to be used on site 5-4
APPENDICES
APPENDIX A List of registered stakeholders
APPENDIX B Notice of AEL application and advertisements
APPENDIX C Notice of comment period for draft scoping report
APPENDIX D Summary of issues raised and responses thereto
APPENDIX E Background Information Document
APPENDIX F Air Quality Impact Assessment
APPENDIX G Traffic Impact Assessment
APPENDIX H Waste Management and Hazardous Substances specialist study
APPENDIX I Water Quality Specialist Study
APPENDIX J Environmental Management Programme (EMP)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 iv
ACRONYMS
AEL Atmospheric Emissions Licence
BID Background Information Document
CCA Custom Controlled Area
CDC Coega Development Corporation
DEA Department of Environmental Affairs
DEDEAT Department of Economic Development Environmental Affairs and Tourism
DWA Department of Water Affairs
EAP Environmental Assessment Practitioner
EIA Environmental Impact Assessment
ELC Environmental Liaison Committee
EMP Environmental Management Programme
GN Government Notice
IampAPs Interested and Affected Parties
IDZ Industrial Development Zone
LNG Liquid natural gas
masl Meters above sea level
MSDS Material Safety Data sheet
NEMA National Environmental Management Act
NEMBA National Environment Management Biodiversity Act (No10 of 2004)
NMBM Nelson Mandela Bay Municipality
OSMP Open Space Management Plan
PoS Plan of Study
SAHRA South African Heritage Resources Agency
TNPA Transnet National Ports Authority
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 v
EXECUTIVE SUMMARY
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone
(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province
Galvanizing consists of coating steel with zinc in order to protect it from corrosion An
Environmental Impact Assessment (EIA) is required as the proposed project involves several
activities listed in terms of Section 24 of the National Environmental Management Act
(NEMA) 107 of 1998 as amended and requires an environmental authorisation The
project also involves activities listed in terms of the National Environmental Management Air
Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008
which respectively require an Atmospheric Emissions Licence and a Waste Management
Licence
The Scoping and Environmental Impact Assessment process underway covers all aspects of
the project and informs all three applications
Scoping was the first phase of investigations and aimed to inter alia identify potential key
environmental issues and impacts to be addressed in the EIA phase
The following environmental issues and potential impacts identified in the Scoping Phase
were investigated in the EIA
Air quality
The galvanizing process generates atmospheric emissions which are regulated in terms
of the National Environmental Management Air Quality Act and appropriate measures
are required in order to adhere to the applicable standards Other sources of impact on
air quality include emissions from the LNG burner emissions and dust from the transport
of steel and other materials in trucks as well as dust and gas emissions related to
construction activities Mitigation measures recommended in the EMP will ensure that air
quality impacts are kept to a minimum and compliance with emissions standards is
maintained
Biodiversity and conservation
Certain types of vegetation in the IDZ are of high conservation importance Protected
species will be rescued as per the CDCrsquos requirements
Water quality
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through spills
or leaks This risk can however be minimized if not avoided altogether through design
choices (bunded areas) and the adherence to best practice guidelines for the handling or
the transport of hazardous substances and waste
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vi
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
Waste management and hazardous substances
The plant will generate a relatively small amount of solid waste which will be re-used
recycled or disposed of in accordance with the EMP recommendations
There will be a wastewater treatment plant on site which will neutralise process water
(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer
Hazardous waste from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site
at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and
removed on a monthly basis is limited to 10 m3
A number of substances classified as hazardous are used in the galvanizing process and
the transport and handling of these is subject to certain rules and guidelines
In addition the permanent storage of a high quantity of liquid petroleum on site (20 000
litres at any one time) is subject to certain specifications and requires approval from the
municipality
Health and safety
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling of the various substances used will be done in
accordance with applicable instructions (cf material safety data sheets)
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as provide
site supervision including executing tests (individual test cold run and hot run) during 3
months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the EMP
Traffic
In the operational phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and from
the Port of Ngqura
The traffic expected to be generated during construction as well as operation is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low and
the total traffic generated by Casa Steel is also relatively low
The impact on port traffic is also negligible and well within the portrsquos capacity
Socio-economic aspects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vii
The proposed galvanizing plant will make a positive contribution by creating jobs during
construction and operation and generating business for the various service providers
Fatal flaws
No fatal flaws have been identified
The significance of these potential key environmental impacts were assessed in the EIA
phase and the findings of this phase of investigations are presented in this report
The main findings of the EIA are as follows
During construction impacts post-mitigation are low with the exception of noise and
biodiversity as the construction of the plant will result in the destruction of habitat
and loss of fauna and flora and noise impacts inherent to construction activities
Mitigation measures have been included in the EMP for these impacts and they have
a medium significance post-mitigation
All impacts were assessed as low during operation after mitigation
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium
to long term similar impacts are likely to occur due to ongoing developments in the
IDZ
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
The CDC has its own requirements regarding the monitoring of certain aspects of the
project such as the quality of the effluent and the noise levels These have been
incorporated into the EMP Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as other
infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified and
assessed No fatal flaws have been identified
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 viii
It is recommended that the project be approved subject to the conditions listed above
and adherence to the EMP recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-1
1 INTRODUCTION
11 BACKGROUND
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)
Nelson Mandela Bay Municipality Eastern Cape Province
The demand for galvanised steel products is high in South Africa and Africa and is
expected to increase in the foreseeable future From an economic point of view the
proposed project has therefore been found to be viable
Casa Steel will source the steel coils from various markets internationally and in
South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is
destined to be exported mainly to African countries
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
An Environmental Impact Assessment (EIA) is required as the proposed project
involves several activities listed in terms of Section 24 of the National Environmental
Management Act (NEMA) No 107 of 1998 as amended and requires an
environmental authorisation
The following listed activities requiring environmental authorisation have been
identified
Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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
Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped
land to industrial use greater than 1 ha but less than 20 ha in size outside an
urban area
Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any
process or activity requiring a license in terms of national or provincial legislation
governing the generation or release of emissions
Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5
hectares or more of vegetation where 75 or more of the vegetative cover
constitutes indigenous vegetation except where such removal of vegetation is
required for
(i) purposes of agriculture or afforestation inside areas identified in
spatial instruments adopted by the competent authority for
agriculture or afforestation purposes
(ii) the undertaking of a process or activity included in the list of waste
management activities published in terms of section 19 of the
National Environmental Management Waste Act 2008 (Act No 59
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-2
of 2008) in which case the activity is regarded to be excluded from
this list
(iii) the undertaking of a linear activity falling below the thresholds in
Notice 544 of 2010
Hot dip galvanizing is a listed activity in terms of section 21 of the National
Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires
an Atmospheric Emissions Licence (AEL)
In addition the treatment of wastewater with an annual throughput capacity of more
than 2000 m3 is a listed activity in terms of the National Environmental Management
Waste Act 59 of 2008 and requires a waste management licence
ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental
Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact
Assessment process in terms of section 24 of NEMA for the construction and
operation of the proposed galvanizing plant The EIA process covers all aspects of
the project and informs all three applications (for environmental authorisation waste
management licence and AEL)
13 PURPOSE OF THIS REPORT
This report builds on the scoping report submitted to the Eastern Cape Department of
Economic Development and Environmental Affairs (DEDEA) and the Nelson
Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It
describes the proposed project and presents the findings of the second phase of
investigations (EIA phase)
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP)
The EIA was managed by Ms Terry Baker a certified Environmental Assessment
Practitioner with 20 years of working experience She has a MA in Environmental
Management and specialises in Environmental Impact Assessments and Project
Management She has been involved in a variety of different types of EIAs including
for water supply projects dams transmission lines roads and airports in South
Africa Botswana Uganda Lesotho and Mozambique She has been involved in
water resource management and public participation programmes on a number of
projects Terry has also been involved in the use of Geographic Information Systems
environmental status quo reports water quality assessments socio-economic and
institutional development projects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-3
15 PROJECT TEAM
In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen
(water quality specialist) and Lea September (EAP) with specialist input from Renee
von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous
substances) and Seniel Pillay (Traffic Impact Assessor)
The Business Unit Head of the ILISO Environmental Management Discipline Group
Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is
a Fellow of the South African Institution of Civil Engineers a member of the South
African Society of Aquatic Scientists of the Environmental Scientific Association of
the International Water Association of the Water Institute of South Africa and of the
Vaal River Catchment Association He is a certified Environmental Assessment
Practitioner with 30 years experience who specialises in project management
environmental impact assessments and water resource planning He specifically has
extensive experience in water quality especially water quality management water
quality monitoring and water quality assessment Martin has experience in managing
projects that involve multi-disciplinary teams and public consultation and
participation in South Africa and abroad
Lea September is an Environmental Assessment Practitioner with a Masters degree
in Environmental Management She has experience in impact assessment and
environmental management and has been responsible for drafting impact
assessment reports and Environmental Management Programmes and conducting
public participation processes as well as high level environmental screenings for a
variety of projects in the energy water transport and industrial sectors
Renee von Gruenewaldt has nine-years experience in the field of air pollution
impact assessment and air quality management Prior to becoming involved in air
quality consultation she was part of the Highveld Boundary Layer Wind Research
Group based at the University of Pretoria Since joining Environmental Management
Services (the company now Airshed Planning Professionals) she has undertaken
numerous air pollution impact studies and has provided extensive guidance to both
industry and government on air quality management practices
Pieter Smuts graduated as a Civil Engineer and became involved in the field of
municipal engineering and infrastructure construction He has specialized during the
last twelve years in solid waste management He has completed waste management
plans feasibility studies and final designs of waste management facilities in South
Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and
the review of the Mavoco hazardous waste landfill design in Maputo Mozambique
and completed a study on hazardous waste (textile factory sludge) management in
Maseru Lesotho
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-4
Seniel Pillay is a transportation engineer with over 16 years experience in
transportation planning and traffic engineering He has been involved in a wide
range of projects ranging from developing the Transport Operations Plan for the
FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System
for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller
traffic impact assessments for inter alia road improvement schemes Of particular
relevance to this project his experience includes Heavy Goods Vehicle Study for
eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact
Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash
Preliminary Transportation Assessment
16 STRUCTURE OF THIS REPORT
The proposed project and the alternatives considered are described in Chapter 2
Chapter 3 details the approach adopted for the EIA phase
The biophysical and socio-economic environment affected by the activity is described
in Chapter 4
The environmental impacts identified are discussed in Chapter 5
The EIA methodology is described in Chapter 6 and Chapter 7 presents the results
of the impact assessment
The environmental impact statement is presented in Chapter 8
Finally Chapter 9 spell out the conclusions and recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-1
2 DESCRIPTION OF THE PROPOSED PROJECT
21 TECHNICAL ASPECTS
211 The galvanizing process
Galvanizing consists of coating steel with zinc in order to protect it from corrosion
Before steel strips can be galvanized they undergo a pre-treatment in order to
ensure that the steel sheets are free from any surface oxides as they enter the
molten zinc coating Bath This is done by removing the oil from the steel sheets (in
the degreasing unit) and then removing the rust from the surface of the sheet (in the
pickling unit)
The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The
melting zinc on the strip surface will be cooled and solidified through air cooling in the
cooling tower
Finally the galvanised steel sheets are dipped into a water quenching tank in order to
further cool the sheets from about 150degC to 40degC
It is possible to make galvanised steel more durable by chromating it Approximately
50 of the galvanised steel production output will receive chromate passivation
treatment after quenching the galvanised steel sheets will be sprayed with a chrome
solution (3 kgcm2)
After galvanizing and chromating the steel sheets are cut to achieve the desired coil
size and weight and transported to the storage yard
The process flow diagram below (Figure 1) illustrates the main stages of the
galvanizing process and indicates the major inputs and outputs as well as the
resulting effluent and atmospheric emissions
Draft Environmenal Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-2
Figure 1 Process flow diagram for proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-3
212 Main inputs and outputs in operational phase
In view of the above the main inputs will be as follows
Steel coils 85 000 tonsyear
Zinc 870 tonsyear
Electricity 2500 kVA
Water 2000 m3month (of which 400 m3 will be potable water)
Liquid Natural Gas (LNG) 270 NM3hour
Sodium hydroxide (NaOH) 1000 m3year
Hydrochloric acid (HCl) 800 m3year
Chrome (Cr+3) 10 m3year
The main outputs will be
Galvanized steel 80 000 tonsyear
Scrap metal 20 tonsyear
General waste 65 tonsyear
Hazardous waste 2 m3month
Wastewater 012 Mlweek
Atmospheric emissions lt 5 ppm
213 Installations on site
The bulk of the operations involved in the galvanizing process occur along a
continuous galvanizing line (See Figure 2 below) which is the main piece of
machinery required for the proposed galvanising plant
Figure 2 Continuous Galvanizing Line
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-4
Water is one of the major inputs and is used throughout the galvanizing process notably
for rinsing and cooling purposes and as a mixing agent for the various chemical
solutions The plant will have a water treatment plant on site to treat the water used in
the various processes (approx 250 m3
of wastewater per week) The wastewater
treatment facility will be operated by a professional water treatment company as Casa
Steel does not have the required expertise in house to treat its process water Sulphuric
acid (H2SO4) is used as part of the treatment process to reduce caustic soda The
neutralised water is discharged to the sewer while any sludge is disposed of as
hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)
will be disposed of
Some critical areas of the galvanizing process such as the zinc pot require uninterrupted
power It is therefore proposed to install an LNG burner to maintain the zinc bath at a
temperature of between 450 and 460degC
22 LOCATION OF THE PROPOSED GALVANIZING PLANT
The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast
of Port Elizabeth in the Eastern Cape (Figure 3)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-5
Figure 3 Location of the proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-6
23 NEED AND DESIRABILITY
The profitability of the proposed project has been established by Casa Steel and a
pre-feasibility study has confirmed that the proposed project was feasible from a
technical and financial point of view The Coega IDZ is specifically designed to host
facilities such as a galvanizing plant and can provide the necessary infrastructure
and services to its investors It therefore constitutes a very suitable location for the
project
24 ALTERNATIVES IDENTIFIED
Zone 6 has been specifically earmarked for heavy ferrous metal industries and is
therefore a suitable location for the proposed galvanizing plant as such no site
alternatives have been provided for and assessed in this EIA However prior to the
commencement of the EIA process Casa Steel was presented with a number of
different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the
selection of the site were
(a) The dimensions of the land the site should be at least 200 m long and
50 m wide in order to accommodate the galvanizing line and adjacent lay
down area and additional land should be available next to the site for future
expansion
(b) The fiscal arrangements applying to the site the site should be located
within the future Custom Controlled Area (CCA) as the bulk of the
production output of the plant will be exported
The no-go alternative is assessed in this report
25 CONSTRUCTION ASPECTS
The construction phase of the project will take about 12 months and will essentially
consist of erecting a building to house the galvanizing line and other equipment and
preparing a concrete laydown area adjacent to the building
The CDC will provide an access point from the existing tarred road that will lead to
the site
Approximately 100 workers from the surrounding areas will be contracted for the
construction work
The requirements in terms of services during construction are listed below
Water 1000 m3month
Electricity 2500 kVA
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-7
The CDC will provide temporary services for the construction phase including a
conservancy tank for flush toilets Sewage infrastructure will only be provided for the
operational phase
26 OPERATION ASPECTS
Before the plant can become fully operational the equipment and machinery will be
tested for approximately 3 months The supplier will supervise these tests as part of
the transfer of know-how and training of staff on the plant
Casa Steel will start operating the plant at a reduced capacity (about 50 000
tonsyear) for a period of time (mostly determined by market aspects) before bringing
production to full capacity (80 000 tonsyear) This is done by operating the line for
longer hours
Approximately 50 to 60 people will be working on the plant Approximately 6-10 of
these will be unskilled 40-45 skilled and about 5 people in managerial positions
The requirements in terms of services during operation are as follows
Water 2000 m3month
Electricity 2500 kVA
Effluent discharge 24 m3day
The CDC has entered into agreements with the municipality to secure the provision
of services such as water and electricity to its tenants Tenants in the IDZ have their
own agreements with the NMBM for electricity while the agreements for water and
sewage are with the Facilities Unit of the CDC
Regarding discharge of wastewater to the sewer the municipality indicated that the
only requirement is that the water discharged complies with applicable municipal
discharge standards
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 3-1
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT
31 OBJECTIVES
The main objectives of the EIA phase are to
Assess the significance of the environmental issues and impacts identified in the
scoping phase focusing on key impacts
Recommend appropriate measures to mitigate negative impacts and enhance the
benefits and include them in the draft EMP
Undertake a public participation process that provides opportunities for all
interested and affected parties (IampAPs) to be involved
32 AUTHORITY CONSULTATION
The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental
Liaison Committeersquo (ELC) which comprises representatives of various authorities
including DEDEAT the Department of Environmental Affairs (DEA) and Department
of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the
Coega Development Corporation (CDC) and Transnet National Ports Authority
(TNPA) The ELC has been specifically formed to facilitate EIA applications in the
IDZ
Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to
the clearance of vegetation should be included in the application A formal request
was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the
application and all registered stakeholders were informed of the request in writing on
19 October 2011
33 PUBLIC PARTICIPATION PROCESS CONDUCTED
On-site notices were replaced by a notification displayed on the CDCrsquos digital notice
board at the business centre in Zone 1 of the IDZ The eNotice was placed on
13 April 2011 and will remain for the full duration of the EIA process
Registered stakeholders will be notified in writing of the availability of the draft EIA
report and EMP which will also be advertised in a local newspaper Stakeholders
including state departments and the public will have forty (40) days to comment on
the draft EIA report and EMP The draft EIA report and EMP will be sent by email
where possible and made available for download on the ILISO website
(wwwilisocom)
A summary of all issues and comments received during the stakeholder consultation
process as well as of correspondence in that regard will be captured in an Issues
and Responses Report that will form an Appendix to the EIA Report
The list of registered IampAPs is included in Appendix A
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 3-2
34 LEGISLATION AND GUIDELINES CONSIDERED
The following legislation and guidelines were considered in the preparation of this
report
National Environmental Management Act Act No 107 of 1998
NEMA EIA Regulations 2010
National Environmental Management Air Quality Act Act No 39 of 2004
National Environmental Management Waste Act Act No 59 of 2008
Hazardous Substances Act Act 15 of 1993
Occupational Health and Safety Act Act 85 of 1993
Hazardous Chemical Substances Regulations 1995 (GNR 1179)
Major Hazard Installation Regulations 2001 (GNR 692)
National Water Act Act 36 of 1998
National Heritage Resources Act Act 25 of 1999
DEAT Integrated Environmental Management Information Series 1-5 and 12-15
NEMA draft Implementation Guideline
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Public Participation (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Alternatives (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Draft Guideline for Determining the Scope of Specialist
Involvement in EIA Processes (2005)
IAIA guidelines
National air quality standard for thoracic particulates Government Gazette
No 32816
Listed activities and associated minimum standards identified in terms of section
21 of the National Environmental Management Air Quality Act Act No 39 of
2004 Government Notice 248 of 2009
Minimum Requirements for the Handling Classification and Disposal of
Hazardous Waste DWAF Waste Management Series (1998)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-1
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION
The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega
IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay
to the north of the N2 highway between Port Elizabeth and Grahamstown east of the
Coega River
The co-ordinates of the corners of the site are shown in Table 1
Table 1 Coordinates of site corners for the proposed galvanizing plant
Point Longitude Latitude
A 25deg411126E 33deg45587S
B 25deg411156E 33deg45499S
C 25deg411938E 33deg45131S
D 25deg412174E 33deg45481S
E 25deg412508E 33deg45979S
F 25deg412634E 33deg451160S
G 25deg411782E 33deg451560S
H 25deg411692E 33deg451428S
J 25deg411314E 33deg45868S
Figure 4 Zone layout in the Coega IDZ
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-2
Figure 5 Site location
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-3
42 SOCIO-ECONOMIC CHARACTERISTICS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the
NMBM There are no residents within the IDZ
As far as the broader NMBM and Eastern Cape Province are concerned the
following can be noted The NMBM is located within the Eastern Cape Province the
2nd largest Province in South Africa (3rd in terms of population) characterised by a
predominantly black population with low incomes and high levels of unemployment
(CES 2010)
The NMBM has a population of just above 11 million and covers an area of
1 950 km2 It is the main urban and industrial centre of the province and Port
Elizabeth in particular which forms part of the NMBM is the commercial capital of
the Eastern Cape 52 of the NMBM population is female and 37 is below the
age of 20 these two groups are particularly affected by unemployment
43 BIOPHYSICAL CHARACTERISTICS
431 Surface and ground water
No rivers occur in Zone 6 There is however a natural attenuation pond on the
southern most part of the site which will have to be avoided
The IDZ is underlain by calcrete sand and gravel deposits that overlie low
permeability clays These clays limit the vertical infiltration of rainwater and induce a
horizontal groundwater flow towards the Coega River channel which is the most
significant surface water feature in the Coega IDZ Consequently rapid run-off takes
place following precipitation (Jacobs 2008)
Groundwater levels at Coega are generally about 3 to 5 m below surface ie just
above the contact between the permeable sands and the underlying impermeable
clays The groundwater flow direction is to the southeast following the surface water
drainage direction (Jacobs 2008)
432 Climate and atmospheric conditions
Port Elizabeth has a warm temperate climate and the temperature ranges are not
extreme Exceptionally high temperatures may be experienced during berg wind
conditions which occur frequently during autumn and winter Extreme temperatures
also occur during summer with little accompanying wind
The wind regime for the area largely reflects the synoptic scale circulation with
dominant westerly and northwesterly flow fields representing the pre-frontal
conditions and south-westerly flow fields representing the frontal conditions The
south-easterly and south-westerly wind flow (land breeze) increases during daytime
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-4
conditions with westerly and north-westerly wind flow increasing during the night (sea
breeze)
The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of
Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15
km southwest) and Port Elizabeth (~23 km southwest)
An ambient air monitoring network has been established in the Coega IDZ which
consists of three monitors Saltworks Motherwell and Amsterdamplein Although
NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative
impacts due to the proposed Galvanising Plant is PM10 A maximum daily average
PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed
SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3
was exceeded on 17 days in 2007 and 26 days in 2008
Existing sources of emissions in the vicinity of the proposed galvanizing plant include
industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other
fugitive dust sources (von Gruenewaldt 2011b)
433 Geology and soils
Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel
and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly
limestone and conglomerate
434 Terrestrial ecology
This section draws from the EIA report compiled for the Agni Steel (formerly Afro-
Asia) steel processing facility which is adjacent to the proposed site for the
galvanizing plant (Jacobs 2008)
The area consists largely of grasses succulents and scrubby bush with alien
species making up the greater part of the more dense vegetation
Zone 6 falls within the inland vegetation and is characterised by a vegetation type
referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the
Coega IDZ and has been found to have three times the level of endemism of other
vegetation communities in the Coega IDZ Bontveld therefore has a high
conservation status Two Bontveld conservation areas have been identified within the
IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)
Bontveld that will be destroyed as a result of development in the IDZ will be given
conservation status in these two areas
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-5
Figure 6 Coega IDZ Open Space Management Plan (OSMP)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-6
Certain areas in the IDZ are invaded by alien plant species The most common
invader species is rooikrans (Acacia cyclops) which presently forms large
monospecific stands in areas throughout the Coega IDZ There are several other
aliens present that pose a threat to the flora of this area including the prickly pear
(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)
Loss of vegetation and alien plant invasion due to human activity has resulted in a
reduction in the diversity of terrestrial fauna
The majority of mammals present in the Coega IDZ are small or medium-sized Of
the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed
gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of
Algoa Bay however it is not considered threatened The gerbil is common in
foredune and dune thicket habitat in the Coega region and is therefore unlikely to
occur on the proposed site
A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird
species are resident or common to the area Most diversity occurs in the thicket
although the coastal area also supports specialised avifauna Two species of tern
the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well
as the Cape gannet (Morus capensis) and the African penguin (Spheniscus
demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne
caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant
(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser
flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns
are two of the most endangered coastal species in South Africa Other bird species
of conservation concern include the Whitefronted plover (Charadrius marginatus)
African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus
bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus
ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides
paradisea) Breeding pairs of Damara terns and African black oyster catchers have
been observed in the coastal dunes of the IDZ but should not be affected by
developments that fall outside the dune areas
The Eastern Cape supports nearly a third (approximately 133 species) of the reptile
species recorded in South Africa More than half of the Eastern Capersquos endemic
reptile species occur in the Algoa Bay area giving the region a high conservation
value A total of 63 reptile species are believed to occur within the Coega IDZ The
majority of these are found in Succulent Thicket and riverine habitats Only a few
reptile species occur in the coastal dunes and estuarine habitats More than a third of
the species are described as relatively tolerant of disturbed environments provided
that migration corridors of suitable habitat are maintained to link pristine habitats
Twenty two reptiles are of special concern including five endemic species (two of
which may also be endangered) four endangered sea turtles eight species listed
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-7
with CITES one rare species and four species at the periphery of their range
Fourteen of these species of special concern are confirmed as occurring on or within
2 km of the Coega IDZ
A total of 32 amphibian species and sub-species occur in the Eastern Cape
representing almost a third of the species recorded in South Africa However none of
the species are endemic or Red Data Book species Based on previous studies in the
area it is estimated that approximately 17 amphibian species occur within the Coega
IDZ Four species are listed as peripheral but none are threatened internationally
These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog
(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and
the bubbling kassina (Kassina senegalensis)
The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated
vegetation has not been extensively studied One grasshopper species Acrotylos
hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue
(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis
pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in
four localities in the Eastern Cape one of which is within the Coega IDZ The Coega
copper Aloeides clarki is endemic to this particular region of the Eastern Cape and
is currently known to occur in three localities two of which are in the Coega IDZ The
localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the
Coega IDZ and their distributions were taken into account when defining Coegarsquos
open space system and Development Framework Plan
435 Land use and topography
The land is currently undeveloped and earmarked for industrial development The
site is relatively flat ranging from an elevation of 66 masl on the northern-most
corner to 59 masl at the southern-most corner
436 Heritage and archaeological survey
Extensive studies have been undertaken in Zone 6 with respect to heritage aspects
Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a
2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond
2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is
currently being finalised
Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing
Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha
in extent and was located next to the R102 road to Motherwell Kaplan conducted
HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi
Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will
now be located in Zone 5)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-8
The various archaeological investigations reached similar observations and
conclusions Stone tools of various densities and types were found throughout the
zone The majority of the stone tools were mainly of Earlier and Middle Stone Age
and occasional Later Stone Age origins (Figure 4)
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble
gravels exposed by tracks in Zone 6 (Source Binneman 2010)
The stone tools which comprised of quartzite flakes chunks flaked pebblecobble
and cores were randomly distributed across the landscape and are in secondary
context There were no lsquoconcentrationsrsquo of tools observed which suggested any
spatial patterning or activity areas although these may be present or covered by soil
and vegetation
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 5-1
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED
The following environmental issues and potential impacts were identified in the
Scoping phase
51 AIR QUALITY
The galvanizing process generates atmospheric emissions with particulates and
hydrogen chloride representing the main pollutants of concern The plant is fitted with
air extraction as well as scrubber systems which are designed to retain the bulk of
pollutants and particles for each of the processes in such a way that less than 5 ppm
of gases and particles will be released into the atmosphere after the fume scrubber
Other sources of impact on air quality include emissions from the LNG burner as well
as emissions and dust from the transport of steel and other materials in trucks
Construction activities will also create dust and gas emissions due to the clearing of
groundcover tipping of material to storage pile levelling of area wind erosion from
storage piles vehicle and construction equipment activity and tailpipe emissions
from vehicles and construction equipment such as graders scrapers and dozers
Overall the air quality impact assessment (Gruenewaldt 2011b) found that
The predicted particulate oxides of nitrogen carbon monoxide and sulphur
dioxide concentrations are all below the National Ambient Air Quality Standards
for all averaging periods
The predicted off-site concentrations of hydrogen chloride are well below the
most stringent effect screening levels
No odour threshold exceedances for hydrogen chloride were predicted to occur
due to routine operations at the Steel Galvanising Plant The South Wales
Environmental Protection Authority stipulates that an odour unit of 20 is
acceptable for urban areas The odour unit would be lt10 directly off-site for
hydrogen chloride
Abnormal emissions can occur in exceptional circumstances Start-up will not
cause abnormal emissions as the scrubbers will be commissioned first and will be
functioning once the plant starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions would be emitted as a
building fugitive
The hourly hydrogen chloride ground level concentrations (directly offsite) were
predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based
on the emission limits as stipulated for listed activities for galvanising processes)
using a screen model which assumes worst case meteorological conditions The
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-2
health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming
abnormal emissions emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset conditions will still
be well within the health effect screening levels
Similarly the hourly particulate emissions from the building fugitives during upset
conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for
listed activities for galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly
off-site
Therefore if emissions are 5 times higher normal they will still be within health effect
screening levels and the daily PM10 NAAQS levels
In the case of a fire a cocktail of gases and particulates could be emitted and could
be over the recommended levels This situation will however be dealt with as an
emergency and normalised as quickly as is possible
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS
The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of
its heritage potential and there are no proposed protected geosites in Zone 6
Should any artefacts be discovered during construction procedures stipulated in the
draft EMP will apply
53 BIODIVERSITY AND CONSERVATION
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
In terms of terrestrial fauna the CDCrsquos open space management plan provides for
the preservation of certain corridors The destruction of certain habitats as a result of
the development will therefore not automatically result in the loss of certain species
54 WATER QUALITY
There is a natural attenuation pond on the southern most part of the site which will be
avoided
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through
spills or leaks
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-3
This risk can however be minimized if not avoided altogether The floor of the factory
will be designed as a bunded area to contain any spills and the entire process will be
contained Potential spills or leaks will therefore be contained and will not impact on
water resources Storm water is therefore considered clean water under normal
operational conditions An oil trap will be placed at the exit of the site to ensure that
no grease from the laydown area enters the stormwater system
Spills and leaks can occur during the handling or the transport of hazardous
substances Best practice guidelines will be followed to ensure that this risk is
adequately managed
Wastewater discharged to sewer will be treated to comply with municipal discharge
standards and is not expected to have an impact on the chemical characteristics of
the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be
discharged from the plant is small in relation to the total volume received at the
Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works
(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently
operated at 61 of its capacity which is approximately 80 Mℓday Thus the
0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore
not have any significant impact on the WWTW
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES
The plant will generate a relatively small amount of solid waste in the form of scrap
metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)
The scrap metal may be sold to other steel processing facilities such as Agni Steel
which will be located next to the plant or collected and disposed of with the rest of
the solid waste by a licensed service provider
As mentioned previously there will be a wastewater treatment plant on site which will
neutralise process water (012 Mlweek) in order to ensure it is of a standard
acceptable for discharge to sewer Waste in the form of sludge from the
neutralization or spent acid must be disposed of as a hazardous waste Solid waste
from the filters used for air quality control is also in this category These wastes can
usually be tested and then delisted which means that it can be placed in a general
purpose landfill
Hazardous effluent from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-
site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored
and removed on a monthly basis is limited to 10 m3
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-4
A number of substances classified as hazardous are used in the galvanizing process
(Table 2) and the transport and handling of these is subject to certain rules and
guidelines In particular the material safety data sheets (cf Appendix H) should be
referred to for inter alia hazards identification accidental release measures
handling and storage precautions exposure controlpersonal protection ecological
information and transport information The Hazardous Chemical Substances
Regulations 1995 should also be adhered to in respect of the transport and storage
of hazardous chemical substances
Table 2 Hazardous materials to be used on site
Major Input Materials
Substance
listed in the
SABS 0228
Group II
hazardous
substances
Volumes to be
stored on site at
any one time
Diesel radic 2000 litres
Liquid petroleum radic 20 000 liters
Sodium hydroxide (NaOH)
(used for degreasing) 8 radic 1000m
3
Hydrochloric acid (HCI)
(used for pickling) 8 radic 800m
3
Zinc (used for galvanising) - TBD
Trivalent chromium (CR+3
)
(used for chromating) 8 radic 10m
3
Sulphuric acid (H2SO4) (used for
treatment of waste water on site) 8 radic TBD
Ammonium Hydroxide (NH4OH) 8 radic TBD
TBD ndash To be determined
Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one
time) and is classified as a flammable substance Specification for flammable storage
facilities in accordance with the requirements of the Nelson Mandela Bay
Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for
quantities between 5000 and 20 000 liters the substance must be kept in a
flammable liquid store which complies with the requirements of a specification
obtainable from the Department Some of the requirements are
Flammable liquid and solid storage facilities are only permitted on the ground
floor
Decanting of flammable liquids and solids are not permitted within any building
Due to the fact that there are flammable materials on site a certificate may be
required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and
Emergency Services Department to confirm that facilities for flammable storage
are in accordance with their requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-5
Because of the permanent installation and high quantity of liquid petroleum on site
the Major Hazard Installation Regulations 2001 promulgated under the Occupational
Health and Safety Act No 85 of 1993 applies A written application for approval of
the installation is required to be submitted to the chief inspector Department of
Labour provincial director Department of Labour and NMBM prior to construction
In addition a risk assessment should be formulated covering all hazardous materials
together with an emergency preparedness and response plan
56 HEALTH AND SAFETY
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling instructions as well as occupational exposure limits
are indicated in the material safety data sheets of the various substances used
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as
provide site supervision including executing tests (individual test cold run and hot
run) during 3 months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the
EMP
In addition the emergency preparedness and response plan will cover the health and
safety aspects related to emergency situations
57 TRAFFIC
The volumes of traffic at the IDZ are currently relatively low and variable depending
on the different zones in the IDZ however these volumes will increase as more
developments are implemented
The construction phase of the Casa Steel development will take about 12 months
and will essentially consist of erecting a building to house the galvanizing line and
other equipment and preparing a concrete laydown area adjacent to the building
The traffic that would be generated during the construction phase can be expected to
be less than the traffic that would be generated by the Casa Steel development when
it is fully operational
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-6
In the operation phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and
from the Port of Ngqura
The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the
Casa Steel development would be off Ring Road 1 The other roads of significance
for the Casa Steel development are the N2 Neptune Road MR435 and MR450
Access to the port is given by Neptune Road Road Link NEP-03 has not yet been
built
Figure 8 Coega IDZ road network identification
(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-7
Figure 9 Coega IDZ road network
Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No
01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-8
The distribution of freight trips is fixed as the majority of trips will be made between
the Port of Ngqura and the Casa Steel site With regard to personnel trips there are
various points of origins (the surrounding residential areas) that could be used by
staff going to the Casa Steel site The distribution of personnel trips is based on
existing traffic count information and is shown in Figure 10
Figure 10 Trip distribution for freight and personnel trips
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The resultant expected Casa Steel traffic assignment is shown in Figure 11
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-9
Figure 11 Morning peak hour Casa Steel development traffic
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The traffic that is expected to be generated by the Casa Steel development is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low
and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)
Consultation has taken place with Transnet Port Authority (TPA) to establish the
impact of the galvanizing plant operations on traffic inside the port The additional
ships entering and exiting the port of Ngqura as a result of the proposed development
will have a negligible impact on port traffic and TPA indicated that it would be well
within the portrsquos capacity
58 NOISE
Noise is not foreseen to be a significant issue insofar as the noise levels inside the
plant and at the boundary of the site will not exceed the limits prescribed by the CDC
Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels
during the day and 60 decibels at night
Mitigation of noise impacts will be addressed in the design of the noise-emitting
components of the plant and their enclosures
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-10
59 SOCIO-ECONOMIC ASPECTS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of
NMBM There are no residents within the IDZ
The direct socio-economic impacts of the proposed project are thus limited to the
employment generated by the project during construction and operation Job creation
remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)
and the IDZ and Port of Ngqura are expected to become a significant catalyst to the
economic growth of the Municipality and the region with current investments at
Coega creating more jobs and stimulating the economy
In this context the proposed galvanizing plant will make a positive contribution
towards the achievement of these goals
There will be 50 to 60 employees during operation phase distributed as follows
Figure 12 Casa Steel organisation chart
Even though a large part of the inputs will be imported and the bulk of the production
output will be exported there will be some positive impacts for the economy of the
region and of South Africa in general Notably the requirements of the plant for
water electricity waste collection and disposal waste water treatment and transport
for example will create business for the various service providers and have an
indirect impact on employment and fiscal revenues as a result
From a visual impact point of view it can be anticipated that the landscape in the IDZ
will be significantly affected over time by developments related to the establishment
of the port and various industries
HEAD ( WORKS )
MGR ( COMM) MGR ( ADMNHR ) Manager marketing
MANAGER OPERATION MANAGER MANAGER MANAGER Q C
AC FIN PUR ampSTORE
PPC SH-GALV SH-tech
SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF
1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO
JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF
2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO
WORKERS WORKERS 7NOS
15 7
RAW MAT amp
DESP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 6-1
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
A description of the nature of the impact any specific legal requirements and the
stage (constructiondecommissioning or operation) will be given Impacts are
considered to be the same during construction and decommissioning The
significance of the potential impacts will be considered before and after identified
mitigation is implemented
The following criteria will be used to evaluate significance
Nature The nature of the impact will be classified as positive or negative and
direct or indirect
Extent and location Magnitude of the impact and is classified as
Local the impacted area is only at the site ndash the actual extent of the activity
Regional the impacted area extends to the surrounding immediate and
neighbouring properties
National the impact can be considered to be of national importance
Duration This measures the lifetime of the impact and is classified as
o Short term the impact will be for 0 ndash 3 years or only last for the period of
construction
o Medium term three to ten years
o Long term longer than 10 years or the impact will continue for the entire
operational lifetime of the project
o Permanent this applies to the impact that will remain after the operational
lifetime of the project
Intensity This is the degree to which the project affects or changes the
environment and is classified as
o Low the change is slight and often not noticeable and the natural functioning
of the environment is not affected
o Medium The environment is remarkably altered but still functions in a
modified way
o High Functioning of the affected environment is disturbed and can cease
Probability This is the likelihood or the chances that the impact will occur and
is classified as
o Low during the normal operation of the project no impacts are expected
o Medium the impact is likely to occur if extra care is not taken to mitigate
them
o High the environment will be affected irrespectively in some cases such
impact can be reduced
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 6-2
Confidence This is the level knowledgeinformation the environmental impact
practitioner or a specialist had in hisher judgement and is rated as
o Low the judgement is based on intuition and not on knowledge or
information
o Medium common sense and general knowledge informs the decision
o High Scientific and or proven information has been used to give such a
judgment
Significance Based on the above criteria the significance of issues will be
determined This is the importance of the impact in terms of physical extent and
time scale and is rated as
o Low the impacts are less important
o Medium the impacts are important and require attention mitigation is
required to reduce the negative impacts
o High the impacts are of great importance Mitigation is therefore crucial
Cumulative Impacts The possible cumulative impacts will also be considered
Mitigation Mitigation for significant issues is incorporated into the EMP for
construction
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 7-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS
71 IMPACTS DURING CONSTRUCTION
711 Air quality
Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris
handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine
particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural
operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks
and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)
Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Fugitive particulate emissions (dust)
related to construction activities Regional
Short
term Medium High High Medium Regional
Short
term Low High High Low
Construction vehicle gas emissions Regional Short
term Medium High High Medium Regional
Short
term Low High High Low
712 Heritage and archaeological resources
Naturedescription of impact excavation activities may impact on unidentified heritage resources
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-2
Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based
on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments
Heritage and archaeological
resources Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on unidentified heritage
resources Local
Short
term
Medium -
high Low High Low
713 Biodiversity and conservation
Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation
importance and cause soil contamination
Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species
Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan
and has compiled a list of protected species to be rescued (see draft EMP)
Biodiversity and conservation Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Loss of fauna and flora Local Perma
nent
Medium -
high High High High Local
Permanen
t Medium High High Medium
Soil contamination Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-3
714 Water related impacts
Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater
runoff spills and leaks Soil erosion
Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of
spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste
disposal Stormwater quality monitoring (see draft EMP)
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Soil erosion Local Short
term Medium Medium High Medium Local
Short
term Medium Low High Low
715 Waste management
Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed
Commentmitigation see draft EMP and waste management plan
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-4
Waste management Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Local
Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
716 Health and safety
Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Short
term
Medium -
high
Medium -
high High High Local
Short
term
Medium -
high Low High Low
717 Traffic
Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and
construction workers from surrounding areas and transport of equipment from the port
Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low
Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and
accurate estimates of quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-5
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Increased traffic on N2 and within the
IDZ Regional
Short
term Low High High Low
718 Noise
Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Short
term
Medium-
high High High Medium Local
Short
term Medium High High Medium
719 Socio-economic
Naturedescription of impact temporary employment will be created during the construction phase
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-6
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Temporary employment Regional Short
term Medium High High Medium
72 IMPACTS DURING OPERATION
721 Air quality
NatureDescription of impact gas and particulate emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning
Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local
sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and
veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute
to background fine particulate concentrations (von Gruenewaldt 2011b)
Assumptions and limitations Potential release of CR6+
As no emission factors are available for trivalent chromium processing the
potential impacts due to these activities could not be quantified
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Dust emitted from traffic on paved roads Regional Long Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-7
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
term
Hydrogen chloride emissions from
pickling process Local
Long
term Low High High Low
Particulate emissions (smoke) from
galvanizing process (due to the
volatilization of flux)
Local Long
term Low High High Low
Particulate oxides of nitrogen carbon
monoxide and sulphur dioxide emissions
from LNG burner
Local Long
term Low High High Low
Nuisance related to odour Local Long
term Low Low High Low
Abnormally high hydrogen chloride and
particulate emissions due to scrubber
malfunction
Local Short
term Medium Low High Medium
Gases (eg SOx NOx CO etc) and
smoke emitted in case of a fire Local
Short
term High Low High Medium
722 Water quality
NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks
Commentmitigation see draft EMP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-8
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Stormwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
723 Waste management and hazardous substances
NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous
waste both can affect environmental quality and human health
Commentmitigation see draft EMP and waste management plan
Waste management and hazardous
substances Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Regional
Long
term High
Medium -
high High High Regional Long term High Low High Low
Soilwaterair pollution due to improper
transport storage and handling of
hazardous substances
Regional Long
term High
Medium -
high High High Regional Long term High Low High Low
Health hazard Local Long
term High
Medium -
high High High Local Long term High Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-9
724 Health and safety
Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Long
term
Medium-
high
Medium-
high High High Local Long term
Medium-
high Low High Low
725 Traffic
Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on
the road network
Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak
hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road
network within Zone 6 of the IDZ (Iliso 2011)
Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)
Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of
quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-10
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on traffic and capacity of the N2 Regional Long
term Low High High Low
Impact on traffic and capacity of ring
road 1 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR435 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR450 Local
Long
term Low High High Low
Impact on traffic and capacity of
Neptune road Local
Long
term Low High High Low
726 Noise
Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Long
term Medium High High Medium Local Long term Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-11
727 Socio-economic
Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate
revenue for the municipality and the region as a whole
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Employment and economic growth Regional Short
term Medium High High Medium
73 COMPARATIVE ASSESSMENT OF IMPACTS
During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as
low during operation after mitigation
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 8-1
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
As a tenant operating in the IDZ Casa Steel will be required to comply with all
current and future CDC requirements as well as with the relevant conditions of
permits licences issued to CDC (eg Integrated Stormwater Masterplan for the
eastern side of the Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)
In particular the CDC has its own requirements regarding the monitoring of certain
aspects of the project such as the quality of the effluent and the noise levels These
have been incorporated into the EMP
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 9-1
9 ENVIRONMENTAL IMPACT STATEMENT
All predicted negative impacts can be mitigated to a low significance The only
exceptions are biodiversity as the construction of the plant will result in the
destruction of habitat and loss of fauna and flora and noise impacts inherent to
construction activities Mitigation measures have been included in the EMP for these
impacts and they have a medium significance post-mitigation
Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium to
long term similar impacts are likely to occur due to ongoing developments in the IDZ
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 10-1
10 CONCLUSION AND RECOMMENDATIONS
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as
other infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified
and assessed No fatal flaws have been identified
It is recommended that the project be approved subject to the conditions listed in
chapter 9 and adherence to the EMP requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 11-1
11 REFERENCES
Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ
Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants
Bennie JS (2010) The historical component (built environment) of the Heritage
Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port
Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report
compiled for Eastern Cape Heritage Consultants
Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater
Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay
Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage
Consultants
BKS (2006) Coega Industrial Development Zone Transport Study Volume 3
Demand Modelling Report Final Draft
Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I
Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6
Report compiled for SRK Consulting
Coastal amp Environmental Services (2010) Environmental Impact Assessment for the
Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone
Volume 3 Environmental Impact Assessment Report CES Grahamstown
Coega Development Corporation (2008) Industry Waste Management Plan -
Strategic Master Plan Report
Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants
Report No CDCSHE 03 8122
Department of Water Affairs and Forestry (1998) Waste Management Series
ldquoMinimum Requirements For The Handling Classification And Disposal Of
Hazardous Wasterdquo Second Edition
Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising
Plant in the Coega Industrial Development Zone
Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the
Coega Industrial Development Zone (IDZ) Specialist Water Study
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 11-2
Jacobs E (2008) Final Environmental Impact Report and Draft Environmental
Management Plan Proposed Steel Recycling and Processing Facility within the
Coega IDZ Report compiled for SRK Consulting
Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY
Galvanising Plant in the Coega Industrial Development Zone Waste Management
and Hazardous Substances Report compiled for ILISO Consulting
RSA National air quality standard for thoracic particulates (PM10) SA standards
(Government Gazette No 32816)
von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed
Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape
Report compiled for ILISO Consulting
von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel
Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report
compiled for ILISO Consulting
Additional sources
Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed
Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared
for Coastal Environmental Services
Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed
Kalagadi Manganese smelter in the Coega Industrial Development Zone Port
Elizabeth Eastern Cape Province Report prepared for Coastal Environmental
Services
Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia
steel recycling facility at the Coega Industrial Development Area Port Elizabeth
Prepared for SRK Consulting Port Elizabeth
APPENDIX A
LIST OF INTERESTED AND
AFFECTED PARTIES
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
DEDEARegional Manager
and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza
DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza
DEA Ocean and
CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza
DEA Ocean and
Coast
Oceanographer land-
based sources of
marine pollution
Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza
DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza
CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza
CDCEnvironmental
Project
Manager
Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza
TNPAPort of Ngqura
Environmental
Manager
Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet
NMBMEnvironmental
ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza
NMBMEnvironmental
ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza
DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza
DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza
WESSASenior Conservation
Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza
Zwartkops
ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700
hughlauegmailcom
zwartkopstrustiafricacom
SANParksNational Marine
CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza
Department Of
LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza
NMBM Air Quality
Division
Assistant
DirectorAir
Pollution and Noise
Templeton Titima 079 490 0574 Ttitimamandelametrogovza
NMBM Air Quality
DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza
NUMSARegional
RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
Department of
HealthNadiema
van der
Bergh083 378 2103
nadiemavanderberghimpiloecprovgov
za
DWA Chief Services
Officer
Joseph Jacobs 041 586 4884 jjacobsdwafgovza
EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza
NUMSecretary of union
officesZandile Xhentsa 043 743 6597 zxhentsanumorgza
DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza
Dynamic
CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom
EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza
Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza
UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom
lprincezago2uticom
Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza
Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza
Absa Mr Johann Steyn 082 3775820 johannstabsacoza
Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza
PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza
Universal
EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza
Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza
GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom
Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza
NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom
DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza
DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza
TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet
DWA Mr Landile Jack JackLdwagovza
DWA Ms Lizna Fourie FourieL4dwagovza
APPENDIX B
NOTICE OF ATMOSPHERIC
EMISSIONS LICENCE APPLICATION
AND ADVERTISEMENT
APPENDIX C
NOTICE OF COMMENT PERIOD FOR
DRAFT SCOPING REPORT
APPENDIX D
SUMMARY OF ISSUES RAISED AND
RESPONSES THERETO
April 2012
1
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DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))
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This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses
provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process
conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the
Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
2
IssueCommentQuestion Date
received Origin Response
1 Please provide more information with respect to the potential
dangers including the toxicity of the proposed project
07032011
By email
Wayne Poulton
(Bosun Brick
tenant at the
IDZ)
An Environmental Impact Assessment (EIA) was undertaken
which assessed the potential toxicity of the emissions and
effluent Mitigation measures were also recommended in the draft
Environmental Management Programme (EMP) to avoid
minimise or compensate any significant impacts The Draft
Environmental Impact Report and draft EMP were made available
to stakeholders for comment in March 2012
2 Do you have a Background Information Document (BID) or
similar that provides more information on the project
27032011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The BID was sent to all registered IampAPs on 4 May 2011
3 The RoD issued to the CDC on 632007 for the change in
land use for the remaining area of the Coega IDZ includes a
number of requirements with respect to
atmospheric emissions that should be considered in the
Atmospheric Emissions Licence (AEL) application such as
prohibiting and monitoring where possible visible emission
plumes to the atmosphere In particular the
recommendations on pp87-91 of the final revised Scoping
Report dated Nov 2006 must be implemented (clause 421)
04042011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
We have obtained copies of the documents referred to and ensure
that these requirements were taken into account in the
environmental assessment and AEL application
4 If the Port of Ngqura is used for import and export the scope
of the traffic impact assessment (TIA) should also include the
port
10052011
By email
Elliot
Motsoahole
(TNPA Port of
Ngqura)
The scope of the TIA was extended to include port related traffic
The TNPA at the Port of Ngqura was consulted and does not
have any objection to the project TNPA has indicated that the
development would require a minimum number of vessels per
year which would have minimal impact on the Port operations
However due notice would have to be given to the Port of Ngqura
before a vessel is scheduled to arrive so that the vessel can be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
3
IssueCommentQuestion Date
received Origin Response
accommodated at an available berth
5 Concerns with respect to potential stormwater pollution
draining into the Coega catchment and the port of Ngqura
The port needs to be dredged and heavy metals present a
risk in that regard
16052011
By
telephone
Andrew Lucas
(Department of
Water Affairs)
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination by effluent waste or
hazardousdangerous substances is very low
Thus no metals oils or other contaminants are expected to be
present in the stormwater
However stormwater pollution can occur in exceptional
circumstances such as accidents and emergencies The
emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
6 All steel sheets bathing unit must be under roof
7 The sludge out of the decreasing bath will be high in Na and
pH Therefore handling and disposal must be clarified up front
in this project
8 Per se the wastewater from decreasing bath will have high
ph and the component from the pickling unit will have low ph
Then it may be assumed that both streams will neutralize
each other Please then clarify proposed sewer discharge
with Nelson Mandela Bay Municipality up-front for acceptance
of influent as per the documented proposal
9 Pickling may result in dissolved metals How does your team
expect to deal with this As it is planned for discharge into
24052011
By email
Landile Jack
(Department of
Water Affairs)
All bathing units will be under roof
Effluent from the degreasing and pickling baths will be discharged
to the wastewater treatment plant The respectively alkaline and
acidic effluents will mix and neutralise each other in the
wastewater treatment plant Calcium or gypsum will be added if
required to complete the neutralisation process Effluent from the
treatment plant will be discharged to sewer Contact has been
made with the relevant officials and the Municipalityrsquos
requirements have been obtained The effluent discharged to
sewer will notably comply with the applicable discharge standards
Traces of metals (eg iron) may be present but will not exceed
prescribed thresholds The necessary authorisation will be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
4
IssueCommentQuestion Date
received Origin Response
sewer Clarity and acceptance needs to be agreed with
Nelson Mandela Bay Municipality Who owns the sewer
10 Quenching unit will results to Zinc particles How will this
affect sewer discharge This again must be dealt with within
the negotiations with the Municipality
11 Once all has been agreed with the Municipality and at the
same time due negotiations must be done with hazardous
waste courier and disposal facility to accept the hazardous
waste identified in all production lines
12 Of note is the low volume of the proposed WWTW facility ie
250 cubmweek And the no discharge of the quenching
water ie over-flow and cooling only Hence Zinc particles
generation
obtained from the municipality
The sludge from the treatment plant will be collected by a licensed
service provider and disposed of at a permitted site
The quenching bath will be periodically emptied (every 6 months)
and the water discharged will go to the water treatment plant Zinc
particles will settle in the sludge which will be disposed of at a
permitted site
Contact has been made with EnviroServ who manages the
Aloes II HH waste site regarding collection and disposal of
hazardous waste (See waste management report)
13 Investigate the potential effects of toxicity andor influence of
emissions waste and hazardous substances both in
terrestrial and marine fauna
14 With regards to water usage where is the plant going to
extract its waters used in galvanization andor waste
management process ie rainfall rivers or even from the
sea) and which avenues would be more environmental
friendly and effective
31052011
By email
A Bewana
(SANPARKS)
Emissions waste and hazardous substances are not expected to
affect terrestrial or marine ecosystems The air quality study
concluded that atmospheric emissions would not be harmful to
human health and by extension terrestrial fauna There are no
standards for air quality for defining faunal impacts therefore by
ensuring that standards for humans are complied with the impact
on fauna is deemed to be acceptable In this case the impact of
emissions on terrestrial and marine fauna are thus not significant
Solid and liquid wastes both general and hazardous as well as
hazardous substances will be stored handled and disposed of
appropriately to as not to cause harm to terrestrial or marine
fauna
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
5
IssueCommentQuestion Date
received Origin Response
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination and hence land-based
marine pollution by effluent waste or hazardousdangerous
substances is very low
The risk of emissions waste and hazardous substances to
terrestrial and marine fauna is thus very low
However pollution of terrestrial and marine ecosystems can occur
in exceptional circumstances such as accidents and emergencies
The emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
The CDC has an agreement with the NMBM to supply potable
water to the Coega IDZ Currently the infrastructure to supply
return effluent (RE) to the IDZ is not in place therefore Casa Steel
will be supplied with potable water up until such time as the
following 2 options of RE are available
1) Upgrading of the existing Fishwater Flats waste water
treatment works (between IDZ amp PE) including RE plant
and infrastructure to pipe RE to the IDZ (EIA for the
upgrade is underway)
2) Construction of a new waste water treatment works
including RE plant in Zone 9 of the Coega IDZ
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option should be investigated further between Agni and Casa The
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
6
IssueCommentQuestion Date
received Origin Response
CDC can facilitate discussions between the 2 investors
Compliance with CDC Permits amp Requirements
15 It should be made clear that tenants will be required to
comply with CDC requirements and the relevant conditions of
permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water
Licence for its Storm Water Systems on the
East Side of the Coega River that tenants will
need to take cognizance of The contents of the
ldquoIntegrated Stormwater Masterplan for the
eastern side of the Coega IDZ Oct 2010rdquo
especially the Table of best practice p53
onwards may need to be taken cognizance of
o CDC is developing an Operations
Environmental Management Plan that will place
certain obligations on tenants
16 Environmental audits and data collected during monitoring
(eg stack emissions stormwater) will need to be shared with
CDC
Air Emissions
17 Presumably permanent in stack monitoring will be required in
terms of AEL permit requirements
18 Abnormal operating conditions resulting in air emissions ndash I
could find nothing in the EIR to indicate under what
circumstances these could occur (eg start-up) potential
frequency and duration and the impact on ambient air quality
ndash these events usually result in the most problems wrt air
emissions
09042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
15 Compliance with the CDCrsquos Permits amp Requirements has
been included explicitly as a requirement in the EIR (p8-1) and
EMP (pp18 and 25) in the following terms
ldquoAs a tenant operating in the IDZ Casa Steel will be required to
comply with all current and future CDC requirements as well as
with the relevant conditions of permits licences issued to CDC
(eg Integrated Stormwater Masterplan for the eastern side of the
Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)rdquo
16 The need to communicate with the CDC on monitoring and
auditing activities was emphasised in Chapter 8 of the EMP The
following paragraphs were added
ldquoDuring construction the environmental officer will be responsible
for monitoring compliance with the EMP and authorisation
conditions and keeping records as required in the EMP andor
authorisation conditions
The ECO will conduct site inspections every two weeks audit the
records kept by the environmental officer and submit an
environmental compliance report every two months to the
authorities and the CDC (via the Environmental Monitoring
Committeersquos ECO)
During operation the health and safety officer will monitor
compliance with the EMP and the conditions of the Environmental
Authorisation Data collected during monitoring activities and any
environmental audits conducted will be shared with authorities
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
7
IssueCommentQuestion Date
received Origin Response
Water
19 Large volumes of (2000 m3mth) of water are required of
which only 400m3 needs to be potable The NMBM return
effluent system will provide non-potable water once it is
constructed What other water recycling initiatives can be
utilized to reduce potable water requirements (the ISWMP for
the eastern side of the Coega IDZ has some best practice
guidelines collecting rainwater from the roof etc)
General
20 There is no mention of how the CDC Architectural Guidelines
will be incorporated into the development (eg to prevent a
stark uniform warehouse type development)
21 Does NMBM have adequate fire services to cover this
development Apart from the large petroleum store are there
any other large fire hazards
22 Reports from the tenantrsquos ECO during construction and from
the SHE Officer during operations should be channeled to the
Coega Environmental Monitoring Committee This can be
directly or preferably via the EMCrsquos ECO (this will be while
the EMC and ECO are in place) A precedent has been set
for this in the Environmental Authorisations for Agni-Steel and
Kalagadi Manganese Smelter
23 All mitigation actions emanating from the EIR should be
summarized (preferably in a table) If compliance with them is
to be part of the Environmental Authorization from DEDEAT
then they (or the ones that DEDEAT deems to be applicable)
and the CDC (via the Environmental Monitoring Committeersquos
ECO)
The ECO (during construction) and the health and safety officer
(during operation) will report to the Coega Environmental
Monitoring Committee (EMC) via the EMCrsquos ECO (this will be
while the EMC and ECO are in place)rdquo
17 The draft EMP recommends regular monitoring of emissions
from the scrubbers and from the chromating process Additional
emissions monitoring requirements will be confirmed once the
AEL is issued Mention has been made in the EMP (pp11 and 19)
that all AEL conditions including monitoring and reporting
requirements should be adhered to
18 Abnormal emissions can occur in exceptional circumstances
Start-up will not cause abnormal emissions as the scrubbers
will be commissioned first and will be functioning once the plant
starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions
would be emitted as a building fugitive
The hourly hydrogen chloride ground level concentrations
(directly offsite) were predicted to be 239 microgmsup3 (based on the
emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits
as stipulated for listed activities for galvanising processes) using a
screen model which assumes worst case meteorological
conditions The health effect screening level for hourly HCl
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
8
IssueCommentQuestion Date
received Origin Response
should be attached to the EA as an Appendix (otherwise no
one knows about them or takes cognizance of them)
concentrations is 2100 microgmsup3 Assuming abnormal emissions
emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset
conditions will still be well within the health effect screening
levels
Similarly the hourly particulate emissions from the building
fugitives during upset conditions would amount to 293 microgmsup3
(based on the emission limits as stipulated for listed activities for
galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1
January 2015) directly off-site
Therefore if emissions are 5 times higher normal they will still be
within health effect screening levels and the daily PM10 NAAQS
levels
In the case of a fire a cocktail of gases and particulates could be
emitted and could be over the recommended levels This
situation will however be dealt with as an emergency and
normalised as quickly as is possible
The above has been added to the impact identificationdescription
and assessment sections of the EIR
19 The CDC has an agreement with the NMBM to supply
potable water to the Coega IDZ Currently the infrastructure to
supply return effluent to the IDZ is not in place therefore Casa
Steel will be supplied with potable water up until such time as the
infrastructure is in place
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
9
IssueCommentQuestion Date
received Origin Response
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option will be investigated further between Agni and Casa The
CDC has come forward to facilitate discussions between the two
investors
Other water recycling initiatives such as rainwater harvesting
have been considered but are not practical
20 The CDCrsquos Architectural and Landscape Design guidelines
contain requirements pertaining to such aspects as the height
orientation and mass and form of buildings as well as guidelines
for landscaping and signage in order to ensure an attractive
development and achieve an architectural integrity within the
Coega IDZ The plans for the proposed galvanizing plant will be
submitted to the Design Review Committee for approval as
required by the CDC
21 Casa Steel will be required to install fire hydrants according
to the NMBMrsquos standardsrequirements The CDC will provide
potable water (up until such time as return effluent is available)
and a connection to the boundary of the site which will be
connected to the fire hydrants The installation of the fire hydrants
will require approval by the Metrorsquos Fire Chief as was done for
Agni-Steel one of the investors in Zone 6
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
10
IssueCommentQuestion Date
received Origin Response
The Coega IDZ falls within the NMBM and therefore the rates and
taxes paid by the CDC covers the fire services for which the Metro
is responsible Currently the Metro has sufficient capacity to
provide fire services to the tenants within the IDZ This was
confirmed in discussion with the CDCrsquos Infrastructure
Development Unit It is however unknown at which point the
Metrorsquos Disaster Management Plan would not be able to
accommodate servicing tenants in the IDZ
The LNG burner is the only major fire hazard on the plant
22 See response to item 16 above
23 Key mitigation and management measures emanating from
the EIR were recapitulated in Chapter 9 of the EIR to form part of
the conditions attached to the Environmental Authorization from
DEDEAT All mitigation measures recommended as a result of the
impact assessment are presented in a table in the draft EMP
which is appended to the EIR (Appendix J)
24 Hydrogen chloride is one of the main emissions There are no
ambient air quality guidelines for HCl and the EIR says
concentrations will be well within health parameters
However the main problem with HCl is its corrosive effect -
there is absolutely no mention of this in the draft EIR nor air
specialist report
There needs to be some sort of comment assessment as to
whether HCl emissions are likely to impact on for example
the adjacent Agni-Steel Plant wrt corrosion - their factory
structure will be made of steel
11042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The atmospheric corrosion of metals is a complex process with
both the extent of deterioration and the mechanisms varying
considerably depending on the metal Depending on the way
pollutants are transported from the atmosphere to the corroding
surface two types of deposition processes are recognized in
atmospheric corrosion ndash dry deposition and wet deposition Wet
deposition refers to precipitation whereas dry deposition refers to
the remaining processes including gas phase deposition and
particle deposition The most important pollutants acting as
corrosive agents are sulphur and nitrogen compounds including
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
11
IssueCommentQuestion Date
received Origin Response
The EIR specialist rpt suggests monitoring HCl at ground
level on the property boundary and this is supported in case
there are complaints from neighbours
secondary pollutants and particulates Pollutants can contribute to
corrosivity individually however there may be a synergistic effect
when more than one of these pollutants is present in the
environment being affected In the field of atmospheric corrosion
sulphur dioxide is the single most investigated gaseous pollutant
and the quantification of the direct contribution of sulphur dioxide
to the corrosion process of metallic materials is comparatively well
understood (Tidblad amp Kucera 1998)
Very little work has reported on the effect of HCl on the
degradation of materials in the environment with no local dose-
response thresholds developed for corrosion occurring due to HCl
exposures This is probably because HCl which is present
outdoors in markedly reduced concentrations when compared
with SO2 has not been considered to contribute to significant
degradation of materials (Syed 2006) For this reason the
incremental corrosion due to HCl from the Coega Galvanising
Plant cannot be quantified
25 It is unacceptable for ILISO to be using CDC maps (see
figure 9 ndash pg5-6) without these maps being referenced
accordingly particularly when it appears that a CDC map has
been used and then overlaid with features by an unknown
author (ie CASA steel site Port (where the boundaries
depicted are incorrect) and a North legend which is out of
keeping with the overall cartographic intent of the original
work
26 Figure 10 is not referenced appropriately and I believe that I
commented previously in respect to references to roads not
12042012
By email
Graham Taylor
(Spatial
Development
Manager -
Infrastructure
Development
CDC)
This has been rectified in the final version of the report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
12
IssueCommentQuestion Date
received Origin Response
yet built As a result Figure 10 is confusing and clarity needs
to be provided in terms of referencing In addition the Port
shape is irregular and similar to the comment above
27 I acknowledge the emergency preparedness and response
plan but please confirm that this includes pro-active routine
monitoring of storm water leaving your premises to verify that
your assumptions of clean storm water are correct
13042012
By post
Andrew Lucas
(Director
WRampU
Department of
Water Affairs)
Pro-active routine monitoring of stormwater leaving the premises
will be undertaken This has been explicitly emphasised in
chapter 8 of the draft EMP
28 Will portablechemical toilets be used during construction
29 What provisions have been made for storm water drainage
during construction
18042012
By
telephone
Department of
Water Affairs
Port Elizabeth
Chemical toilets will be used during construction
The Casa Steel site will be located at the corner of two roads
drainage of stormwater from the site will take place through the
roadsrsquo drainage system
From Lea September [mailtoleailisocom]
Sent 11 March 2011 0935 AM
To Wayne Poulton
Cc Terry Baker
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Wayne
An Environmental Impact Assessment (EIA) will be undertaken for this project during the
next 10 to 12 months
We foresee that some of the key environmental impacts of the project will be in terms of air
quality water quality waste and hazardous substances
At this stage I am not able to give you any details regarding the potential toxicity of the
emissions andor effluent However specialist studies will be conducted as part of the EIA
that will determine the key impacts of the project Mitigation measures will also be identified
to avoid minimise or compensate any significant impacts
You are registered on the stakeholder database and you will be kept informed of progress in
the EIA process you will notably get the opportunity to access the reports produced and
provide any feedback on them
Please feel free to contact me should you need any further information
Best regards
Lea September
From Wayne Poulton [mailtowaynepbosuncoza]
Sent 07 March 2011 1257 PM
To Lea September
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
Please can you provide me with some more information as to the potential dangers including
the toxicity of this
Kind regards
Wayne
From Lea September [mailtoleailisocom]
Sent 04 March 2011 1123
To Lea September
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 March 2011 0745 AM
To Paul Martin
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 05 April 2011 0847 AM
To Paul Martin
Cc Terry Baker Renee von Gruenewaldt
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Thank you Paul for this information
I have downloaded a copy of the RoD and Scoping report you referred to and will make sure
these requirements are taken into account in the environmental assessment
Best regards
Lea September
From Paul Martin [mailtopmartinaxxesscoza]
Sent 04 April 2011 0955 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Further to my comments on 27311
Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in
the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega
IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised
scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions
including prohibiting and monitoring where possible visible emission plumes to the atmosphere
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Paul Martin
Sent Monday March 28 2011 745 AM
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 10 May 2011 0327 PM
To ElliotMotsoaholetransnetnet
Cc Terry Baker
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Mr Motsoahole
Thank you for your input on this issue
The Port of Ngqura will indeed be used for import and export At the moment the scope of
the traffic impact assessment only covers road traffic I have however relayed the matter to
our traffic specialist and we will consider this issue in the finalization of the Scoping Report I
will keep you informed of any developments in that regard
I trust this is acceptable to you
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]
Sent 10 May 2011 0855 AM
To Lea September
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
It has been noted that Casa Steel will source steel coils from various markets internationally and
in South Africa and the bulk of the plantrsquos production output will be exported to African countries
However there is no mention of logistic requirements
Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will
be used the scope of traffic impact assessment should also include the port
Regards
From Lea September [mailtoleailisocom]
Sent 04 May 2011 0747 AM
To Lea September
Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
Please find attached a letter announcing the EIA process underway for the proposed 80 000
tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as
a Background Information Document (BID) outlining the details of the project
Please contact me should you require any further information on this project
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
Elliot Motsoahole
Manager - Environment
Transnet National Ports Authority
Port of Nqqura
Port Control Building Klub Road Port Elizabeth 6212
PO Box 612054 Bluewater Bay 6212
+27 41 507 8450
+27 86 674 7729
Cell +27 83 542 5619
E-mail Elliotmotsoaholetransnetnet
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
DISCLAIMER The information contained in this communication is subject to copyright and
intended only for the use of leailisocom Unauthorised use disclosure or copying is
strictly prohibited Should a virus infection occur as a result of this communication the sender
will not be liable If you have received this communication in error please notify
elliotmotsoaholetransnetnet
From Lea September [mailtoleailisocom]
Sent 25 May 2011 1147 AM
To Jack Landile (ELS)
Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi
Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Landile
Thank you for your input
Contact has been made with the relevant Municipal Directorate and we will follow up with
them to obtain clarifications on all these issues
I have added both Lizna and yourself on the database and will keep you updated on
progress on this project
Best regards
Lea September
From Jack Landile (ELS) [mailtoJackLdwagovza]
Sent 24 May 2011 0524 PM
To Fourie Lizna (ELS)
Cc Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Hi Lizna
I missed you on this sorry
I linked Pieter twice Instead
Regards
Landile
From Jack Landile (ELS)
Sent 24 May 2011 0445 PM
To leailisocom
Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Lea
The e-mail you sent to Mr Kooverji dated 19 May 2011 refer
Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are
All steel sheets bathing unit must be under roof
The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project
Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal
Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer
Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality
Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines
Of note is the low volume of the proposed WWTW facility ie 250 cubmweek
And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles
generation
Regards
Landile
From Lea September [mailtoleailisocom]
Sent 19 May 2011 0947 AM
To Lea September
Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Stakeholder
Please find attached the remaining appendices to the draft Scoping report for the proposed
80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 June 2011 0411 PM
To Aphiwe Bewana
Subject RE Proposed 80 000 TPY Galvanizing plant in Coega
Dear Mr Bewana
Thank you for your input and apologies for the late reply
We have taken note of your comments and are will be taking them forward in the EIA phase
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Aphiwe Bewana [mailtoaphiwebewanagmailcom]
Sent 31 May 2011 1205 PM
To Lea September
Subject Re Proposed 80 000 TPY Galvanizing plant in Coega
Comment
Re Proposed 80 000 TPY Galvanizing plant in Coega
As SANParks we would like the EIA phase to investigate the potential effects of toxicity
andor influence of emissions waste and hazardous substances both in terrestrial and
marine fauna In the draft scoping report reference has been made with regards to the
terrestrial fauna but there is no attention to potential effects to marine fauna
Equally with regards to water usage where is the plant going to extract its waters used in
galvanization andor waste management process ie rainfall rivers or even from the sea)
and which avenues would be more environmental friendly and effective
Regards
Aphiwe Bewana
Marine Planner
South African National Parks
POBox 76693
NMMU
Port Elizabeth
6031
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 06 July 2011 1031 AM
To Lea September
Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Hi Lea
Irsquove reviewed the Final Scoping Report Herewith a few comments
1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the
Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a
revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the
NMBLP Please include only those in the IDZ as part of your IAP list
Regards
Andrea
From Lea September [mailtoleailisocom]
Sent Wednesday July 06 2011 859 AM
To Lea Septemberrsquo
Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Dear Stakeholder
The final scoping report for the above-mentioned project (attached) is available for comment
until 27 July 2011
The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic
commentaryrdquo tab
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 09 April 2012 1159 AM
To Lea September
Subject Comments on Galvanising Plant EIR Coega IDZ
Lea
Attached are my comments on the Draft EIR for the Coega IDZ galvanising
plant
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
Email attachment
COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ
Dr Paul Martin PO Box 61029
Bluewater Bay 6212 Tel 041 4665698
Email pmartinaxxesscoza
Compliance with CDC Permits amp Requirements
It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of
o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants
Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC
Air Emissions
Presumably permanent in stack monitoring will be required in terms of AEL permit requirements
Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions
Water
Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)
General
There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)
Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards
Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter
All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 11 April 2012 1245 PM
To Lea September
Subject Fw Comments on Galvanising Plant EIR Coega IDZ
Lea
One other comment on that I have on the Galvanising Plant Draft EIR
Hydrogen chloride is one of the main emissions There are no ambient air
quality guidelines for HCl and the EIR says concentrations will be well
within health parameters
However the main problem with HCl is its corrosive effect - there is
absolutely no mention of this in the draft EIR nor air specialist report
There needs to be some sort of comment assessment as to whether HCl
emissions are likely to impact on for example the adjacent Agni-Steel
Plant wrt corrosion - their factory structure will be made of steel
The EIR specialist rpt suggests monitoring HCl at ground level on the
property boundary and this is supported in case there are complaints from
neighbours
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Paul Martin ltpmartinaxxesscozagt
To Lea September ltleailisocomgt
Sent Monday April 09 2012 1158 AM
Subject Comments on Galvanising Plant EIR Coega IDZ
gt Lea
gt
gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising
gt plant
gt
gt
gt Dr Paul Martin
gt PO Box 61029
gt Bluewater Bay 6212
gt Tel 041 4665698
gt Cell 0732524111
gt email pmartinaxxesscoza
gt
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 12 April 2012 1139 AM
To Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Hi Lea
Hope yoursquore keeping well
I have requested comments from my colleagues and the CDC Casa team on the Draft EIR
Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report
Regards
Andrea
From Graham Taylor
Sent Thursday April 12 2012 838 AM
To Andrea Von Holdt Firhana Sam
Cc Johan Fourie Maria van Zyl Melikhaya Sihawu
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Andrea Firhana
Firhana if you could please ensure that the co-ordinates provided in the EIR correspond
with our records (pages 4-1 amp 4-2)
My comments are as follows
It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work
Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above
Regards
Graham Taylor
Spatial Development Manager - Infrastructure Development
Mobile 0832283055
Office 0414030454
Facsimile 0865185033
Email GrahamTaylorcoegacoza
Website wwwcoegacom
right PLACE | right TIME | right CHOICE
This email and all contents are subject to the following disclaimer
httpwwwcoegacomemaildisclaimerhtml
From Lea September [mailtoleailisocom]
Sent 04 May 2012 0411 PM
To Andrea Von Holdt
Cc Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Dear Andrea
We have taken note of the comments from the GIS Unit These issues have been rectified in
the final version of the EIR
Please can you forward to the relevant persons at the GIS Unit
Thank you
Best regards
Lea September
APPENDIX E
BACKGROUND INFORMATION
DOCUMENT
APPENDIX F
AIR QUALITY IMPACT ASSESSMENT
APPENDIX G
TRAFFIC IMPACT ASSESSMENT
APPENDIX H
WASTE MANAGEMENT AND HAZARDOUS
SUBSTANCES SPECIALIST STUDY
APPENDIX I
WATER QUALITY SPECIALIST STUDY
APPENDIX J
ENVIRONMENTAL MANAGEMENT
PROGRAMME
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 ii
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS 5-2
53 BIODIVERSITY AND CONSERVATION 5-2
54 WATER QUALITY 5-2 55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES 5-3
56 HEALTH AND SAFETY 5-5
57 TRAFFIC 5-5
58 NOISE 5-9
59 SOCIO-ECONOMIC ASPECTS 5-10
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY 6-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS 7-1
71 IMPACTS DURING CONSTRUCTION 7-1
711 Air quality 7-1
712 Heritage and archaeological resources 7-1
713 Biodiversity and conservation 7-2
714 Water related impacts 7-3
715 Waste management 7-3
716 Health and safety 7-4
717 Traffic 7-4
718 Noise 7-5
719 Socio-economic 7-5
72 IMPACTS DURING OPERATION 7-6
721 Air quality 7-6
722 Water quality 7-7
723 Waste management and hazardous substances 7-8
724 Health and safety 7-9
725 Traffic 7-9
726 Noise 7-10
727 Socio-economic 7-11
73 COMPARATIVE ASSESSMENT OF IMPACTS 7-11
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME 8-1
9 ENVIRONMENTAL IMPACT STATEMENT 9-1
10 CONCLUSION AND RECOMMENDATIONS 10-1
11 REFERENCES 11-1
LIST OF FIGURES
Figure 1 Process flow diagram for proposed galvanizing plant 2-2
Figure 2 Continuous Galvanizing Line 2-3
Figure 3 Location of the proposed galvanizing plant 2-5
Figure 4 Zone layout in the Coega IDZ 4-1
Figure 5 Site location 4-2
Figure 6 Coega IDZ Open Space Management Plan (OSMP) 4-5
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble gravels
exposed by tracks in Zone 6 (Source Binneman 2010) 4-8
Figure 8 Coega IDZ road network layout (Adapted from BKS 2006) 5-6
Figure 9 Coega IDZ road network 5-7
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 iii
Figure 10 Trip distribution for freight and personnel trips 5-8
Figure 11 Morning peak hour Casa Steel development traffic 5-9
Figure 12 Casa Steel organisation chart 5-10
LIST OF TABLES
Table 1 Coordinates of site corners for the proposed galvanizing plant 4-1
Table 2 Hazardous materials to be used on site 5-4
APPENDICES
APPENDIX A List of registered stakeholders
APPENDIX B Notice of AEL application and advertisements
APPENDIX C Notice of comment period for draft scoping report
APPENDIX D Summary of issues raised and responses thereto
APPENDIX E Background Information Document
APPENDIX F Air Quality Impact Assessment
APPENDIX G Traffic Impact Assessment
APPENDIX H Waste Management and Hazardous Substances specialist study
APPENDIX I Water Quality Specialist Study
APPENDIX J Environmental Management Programme (EMP)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 iv
ACRONYMS
AEL Atmospheric Emissions Licence
BID Background Information Document
CCA Custom Controlled Area
CDC Coega Development Corporation
DEA Department of Environmental Affairs
DEDEAT Department of Economic Development Environmental Affairs and Tourism
DWA Department of Water Affairs
EAP Environmental Assessment Practitioner
EIA Environmental Impact Assessment
ELC Environmental Liaison Committee
EMP Environmental Management Programme
GN Government Notice
IampAPs Interested and Affected Parties
IDZ Industrial Development Zone
LNG Liquid natural gas
masl Meters above sea level
MSDS Material Safety Data sheet
NEMA National Environmental Management Act
NEMBA National Environment Management Biodiversity Act (No10 of 2004)
NMBM Nelson Mandela Bay Municipality
OSMP Open Space Management Plan
PoS Plan of Study
SAHRA South African Heritage Resources Agency
TNPA Transnet National Ports Authority
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 v
EXECUTIVE SUMMARY
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone
(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province
Galvanizing consists of coating steel with zinc in order to protect it from corrosion An
Environmental Impact Assessment (EIA) is required as the proposed project involves several
activities listed in terms of Section 24 of the National Environmental Management Act
(NEMA) 107 of 1998 as amended and requires an environmental authorisation The
project also involves activities listed in terms of the National Environmental Management Air
Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008
which respectively require an Atmospheric Emissions Licence and a Waste Management
Licence
The Scoping and Environmental Impact Assessment process underway covers all aspects of
the project and informs all three applications
Scoping was the first phase of investigations and aimed to inter alia identify potential key
environmental issues and impacts to be addressed in the EIA phase
The following environmental issues and potential impacts identified in the Scoping Phase
were investigated in the EIA
Air quality
The galvanizing process generates atmospheric emissions which are regulated in terms
of the National Environmental Management Air Quality Act and appropriate measures
are required in order to adhere to the applicable standards Other sources of impact on
air quality include emissions from the LNG burner emissions and dust from the transport
of steel and other materials in trucks as well as dust and gas emissions related to
construction activities Mitigation measures recommended in the EMP will ensure that air
quality impacts are kept to a minimum and compliance with emissions standards is
maintained
Biodiversity and conservation
Certain types of vegetation in the IDZ are of high conservation importance Protected
species will be rescued as per the CDCrsquos requirements
Water quality
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through spills
or leaks This risk can however be minimized if not avoided altogether through design
choices (bunded areas) and the adherence to best practice guidelines for the handling or
the transport of hazardous substances and waste
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vi
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
Waste management and hazardous substances
The plant will generate a relatively small amount of solid waste which will be re-used
recycled or disposed of in accordance with the EMP recommendations
There will be a wastewater treatment plant on site which will neutralise process water
(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer
Hazardous waste from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site
at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and
removed on a monthly basis is limited to 10 m3
A number of substances classified as hazardous are used in the galvanizing process and
the transport and handling of these is subject to certain rules and guidelines
In addition the permanent storage of a high quantity of liquid petroleum on site (20 000
litres at any one time) is subject to certain specifications and requires approval from the
municipality
Health and safety
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling of the various substances used will be done in
accordance with applicable instructions (cf material safety data sheets)
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as provide
site supervision including executing tests (individual test cold run and hot run) during 3
months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the EMP
Traffic
In the operational phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and from
the Port of Ngqura
The traffic expected to be generated during construction as well as operation is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low and
the total traffic generated by Casa Steel is also relatively low
The impact on port traffic is also negligible and well within the portrsquos capacity
Socio-economic aspects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vii
The proposed galvanizing plant will make a positive contribution by creating jobs during
construction and operation and generating business for the various service providers
Fatal flaws
No fatal flaws have been identified
The significance of these potential key environmental impacts were assessed in the EIA
phase and the findings of this phase of investigations are presented in this report
The main findings of the EIA are as follows
During construction impacts post-mitigation are low with the exception of noise and
biodiversity as the construction of the plant will result in the destruction of habitat
and loss of fauna and flora and noise impacts inherent to construction activities
Mitigation measures have been included in the EMP for these impacts and they have
a medium significance post-mitigation
All impacts were assessed as low during operation after mitigation
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium
to long term similar impacts are likely to occur due to ongoing developments in the
IDZ
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
The CDC has its own requirements regarding the monitoring of certain aspects of the
project such as the quality of the effluent and the noise levels These have been
incorporated into the EMP Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as other
infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified and
assessed No fatal flaws have been identified
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 viii
It is recommended that the project be approved subject to the conditions listed above
and adherence to the EMP recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-1
1 INTRODUCTION
11 BACKGROUND
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)
Nelson Mandela Bay Municipality Eastern Cape Province
The demand for galvanised steel products is high in South Africa and Africa and is
expected to increase in the foreseeable future From an economic point of view the
proposed project has therefore been found to be viable
Casa Steel will source the steel coils from various markets internationally and in
South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is
destined to be exported mainly to African countries
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
An Environmental Impact Assessment (EIA) is required as the proposed project
involves several activities listed in terms of Section 24 of the National Environmental
Management Act (NEMA) No 107 of 1998 as amended and requires an
environmental authorisation
The following listed activities requiring environmental authorisation have been
identified
Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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
Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped
land to industrial use greater than 1 ha but less than 20 ha in size outside an
urban area
Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any
process or activity requiring a license in terms of national or provincial legislation
governing the generation or release of emissions
Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5
hectares or more of vegetation where 75 or more of the vegetative cover
constitutes indigenous vegetation except where such removal of vegetation is
required for
(i) purposes of agriculture or afforestation inside areas identified in
spatial instruments adopted by the competent authority for
agriculture or afforestation purposes
(ii) the undertaking of a process or activity included in the list of waste
management activities published in terms of section 19 of the
National Environmental Management Waste Act 2008 (Act No 59
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-2
of 2008) in which case the activity is regarded to be excluded from
this list
(iii) the undertaking of a linear activity falling below the thresholds in
Notice 544 of 2010
Hot dip galvanizing is a listed activity in terms of section 21 of the National
Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires
an Atmospheric Emissions Licence (AEL)
In addition the treatment of wastewater with an annual throughput capacity of more
than 2000 m3 is a listed activity in terms of the National Environmental Management
Waste Act 59 of 2008 and requires a waste management licence
ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental
Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact
Assessment process in terms of section 24 of NEMA for the construction and
operation of the proposed galvanizing plant The EIA process covers all aspects of
the project and informs all three applications (for environmental authorisation waste
management licence and AEL)
13 PURPOSE OF THIS REPORT
This report builds on the scoping report submitted to the Eastern Cape Department of
Economic Development and Environmental Affairs (DEDEA) and the Nelson
Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It
describes the proposed project and presents the findings of the second phase of
investigations (EIA phase)
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP)
The EIA was managed by Ms Terry Baker a certified Environmental Assessment
Practitioner with 20 years of working experience She has a MA in Environmental
Management and specialises in Environmental Impact Assessments and Project
Management She has been involved in a variety of different types of EIAs including
for water supply projects dams transmission lines roads and airports in South
Africa Botswana Uganda Lesotho and Mozambique She has been involved in
water resource management and public participation programmes on a number of
projects Terry has also been involved in the use of Geographic Information Systems
environmental status quo reports water quality assessments socio-economic and
institutional development projects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-3
15 PROJECT TEAM
In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen
(water quality specialist) and Lea September (EAP) with specialist input from Renee
von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous
substances) and Seniel Pillay (Traffic Impact Assessor)
The Business Unit Head of the ILISO Environmental Management Discipline Group
Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is
a Fellow of the South African Institution of Civil Engineers a member of the South
African Society of Aquatic Scientists of the Environmental Scientific Association of
the International Water Association of the Water Institute of South Africa and of the
Vaal River Catchment Association He is a certified Environmental Assessment
Practitioner with 30 years experience who specialises in project management
environmental impact assessments and water resource planning He specifically has
extensive experience in water quality especially water quality management water
quality monitoring and water quality assessment Martin has experience in managing
projects that involve multi-disciplinary teams and public consultation and
participation in South Africa and abroad
Lea September is an Environmental Assessment Practitioner with a Masters degree
in Environmental Management She has experience in impact assessment and
environmental management and has been responsible for drafting impact
assessment reports and Environmental Management Programmes and conducting
public participation processes as well as high level environmental screenings for a
variety of projects in the energy water transport and industrial sectors
Renee von Gruenewaldt has nine-years experience in the field of air pollution
impact assessment and air quality management Prior to becoming involved in air
quality consultation she was part of the Highveld Boundary Layer Wind Research
Group based at the University of Pretoria Since joining Environmental Management
Services (the company now Airshed Planning Professionals) she has undertaken
numerous air pollution impact studies and has provided extensive guidance to both
industry and government on air quality management practices
Pieter Smuts graduated as a Civil Engineer and became involved in the field of
municipal engineering and infrastructure construction He has specialized during the
last twelve years in solid waste management He has completed waste management
plans feasibility studies and final designs of waste management facilities in South
Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and
the review of the Mavoco hazardous waste landfill design in Maputo Mozambique
and completed a study on hazardous waste (textile factory sludge) management in
Maseru Lesotho
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-4
Seniel Pillay is a transportation engineer with over 16 years experience in
transportation planning and traffic engineering He has been involved in a wide
range of projects ranging from developing the Transport Operations Plan for the
FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System
for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller
traffic impact assessments for inter alia road improvement schemes Of particular
relevance to this project his experience includes Heavy Goods Vehicle Study for
eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact
Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash
Preliminary Transportation Assessment
16 STRUCTURE OF THIS REPORT
The proposed project and the alternatives considered are described in Chapter 2
Chapter 3 details the approach adopted for the EIA phase
The biophysical and socio-economic environment affected by the activity is described
in Chapter 4
The environmental impacts identified are discussed in Chapter 5
The EIA methodology is described in Chapter 6 and Chapter 7 presents the results
of the impact assessment
The environmental impact statement is presented in Chapter 8
Finally Chapter 9 spell out the conclusions and recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-1
2 DESCRIPTION OF THE PROPOSED PROJECT
21 TECHNICAL ASPECTS
211 The galvanizing process
Galvanizing consists of coating steel with zinc in order to protect it from corrosion
Before steel strips can be galvanized they undergo a pre-treatment in order to
ensure that the steel sheets are free from any surface oxides as they enter the
molten zinc coating Bath This is done by removing the oil from the steel sheets (in
the degreasing unit) and then removing the rust from the surface of the sheet (in the
pickling unit)
The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The
melting zinc on the strip surface will be cooled and solidified through air cooling in the
cooling tower
Finally the galvanised steel sheets are dipped into a water quenching tank in order to
further cool the sheets from about 150degC to 40degC
It is possible to make galvanised steel more durable by chromating it Approximately
50 of the galvanised steel production output will receive chromate passivation
treatment after quenching the galvanised steel sheets will be sprayed with a chrome
solution (3 kgcm2)
After galvanizing and chromating the steel sheets are cut to achieve the desired coil
size and weight and transported to the storage yard
The process flow diagram below (Figure 1) illustrates the main stages of the
galvanizing process and indicates the major inputs and outputs as well as the
resulting effluent and atmospheric emissions
Draft Environmenal Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-2
Figure 1 Process flow diagram for proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-3
212 Main inputs and outputs in operational phase
In view of the above the main inputs will be as follows
Steel coils 85 000 tonsyear
Zinc 870 tonsyear
Electricity 2500 kVA
Water 2000 m3month (of which 400 m3 will be potable water)
Liquid Natural Gas (LNG) 270 NM3hour
Sodium hydroxide (NaOH) 1000 m3year
Hydrochloric acid (HCl) 800 m3year
Chrome (Cr+3) 10 m3year
The main outputs will be
Galvanized steel 80 000 tonsyear
Scrap metal 20 tonsyear
General waste 65 tonsyear
Hazardous waste 2 m3month
Wastewater 012 Mlweek
Atmospheric emissions lt 5 ppm
213 Installations on site
The bulk of the operations involved in the galvanizing process occur along a
continuous galvanizing line (See Figure 2 below) which is the main piece of
machinery required for the proposed galvanising plant
Figure 2 Continuous Galvanizing Line
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-4
Water is one of the major inputs and is used throughout the galvanizing process notably
for rinsing and cooling purposes and as a mixing agent for the various chemical
solutions The plant will have a water treatment plant on site to treat the water used in
the various processes (approx 250 m3
of wastewater per week) The wastewater
treatment facility will be operated by a professional water treatment company as Casa
Steel does not have the required expertise in house to treat its process water Sulphuric
acid (H2SO4) is used as part of the treatment process to reduce caustic soda The
neutralised water is discharged to the sewer while any sludge is disposed of as
hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)
will be disposed of
Some critical areas of the galvanizing process such as the zinc pot require uninterrupted
power It is therefore proposed to install an LNG burner to maintain the zinc bath at a
temperature of between 450 and 460degC
22 LOCATION OF THE PROPOSED GALVANIZING PLANT
The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast
of Port Elizabeth in the Eastern Cape (Figure 3)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-5
Figure 3 Location of the proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-6
23 NEED AND DESIRABILITY
The profitability of the proposed project has been established by Casa Steel and a
pre-feasibility study has confirmed that the proposed project was feasible from a
technical and financial point of view The Coega IDZ is specifically designed to host
facilities such as a galvanizing plant and can provide the necessary infrastructure
and services to its investors It therefore constitutes a very suitable location for the
project
24 ALTERNATIVES IDENTIFIED
Zone 6 has been specifically earmarked for heavy ferrous metal industries and is
therefore a suitable location for the proposed galvanizing plant as such no site
alternatives have been provided for and assessed in this EIA However prior to the
commencement of the EIA process Casa Steel was presented with a number of
different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the
selection of the site were
(a) The dimensions of the land the site should be at least 200 m long and
50 m wide in order to accommodate the galvanizing line and adjacent lay
down area and additional land should be available next to the site for future
expansion
(b) The fiscal arrangements applying to the site the site should be located
within the future Custom Controlled Area (CCA) as the bulk of the
production output of the plant will be exported
The no-go alternative is assessed in this report
25 CONSTRUCTION ASPECTS
The construction phase of the project will take about 12 months and will essentially
consist of erecting a building to house the galvanizing line and other equipment and
preparing a concrete laydown area adjacent to the building
The CDC will provide an access point from the existing tarred road that will lead to
the site
Approximately 100 workers from the surrounding areas will be contracted for the
construction work
The requirements in terms of services during construction are listed below
Water 1000 m3month
Electricity 2500 kVA
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-7
The CDC will provide temporary services for the construction phase including a
conservancy tank for flush toilets Sewage infrastructure will only be provided for the
operational phase
26 OPERATION ASPECTS
Before the plant can become fully operational the equipment and machinery will be
tested for approximately 3 months The supplier will supervise these tests as part of
the transfer of know-how and training of staff on the plant
Casa Steel will start operating the plant at a reduced capacity (about 50 000
tonsyear) for a period of time (mostly determined by market aspects) before bringing
production to full capacity (80 000 tonsyear) This is done by operating the line for
longer hours
Approximately 50 to 60 people will be working on the plant Approximately 6-10 of
these will be unskilled 40-45 skilled and about 5 people in managerial positions
The requirements in terms of services during operation are as follows
Water 2000 m3month
Electricity 2500 kVA
Effluent discharge 24 m3day
The CDC has entered into agreements with the municipality to secure the provision
of services such as water and electricity to its tenants Tenants in the IDZ have their
own agreements with the NMBM for electricity while the agreements for water and
sewage are with the Facilities Unit of the CDC
Regarding discharge of wastewater to the sewer the municipality indicated that the
only requirement is that the water discharged complies with applicable municipal
discharge standards
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 3-1
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT
31 OBJECTIVES
The main objectives of the EIA phase are to
Assess the significance of the environmental issues and impacts identified in the
scoping phase focusing on key impacts
Recommend appropriate measures to mitigate negative impacts and enhance the
benefits and include them in the draft EMP
Undertake a public participation process that provides opportunities for all
interested and affected parties (IampAPs) to be involved
32 AUTHORITY CONSULTATION
The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental
Liaison Committeersquo (ELC) which comprises representatives of various authorities
including DEDEAT the Department of Environmental Affairs (DEA) and Department
of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the
Coega Development Corporation (CDC) and Transnet National Ports Authority
(TNPA) The ELC has been specifically formed to facilitate EIA applications in the
IDZ
Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to
the clearance of vegetation should be included in the application A formal request
was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the
application and all registered stakeholders were informed of the request in writing on
19 October 2011
33 PUBLIC PARTICIPATION PROCESS CONDUCTED
On-site notices were replaced by a notification displayed on the CDCrsquos digital notice
board at the business centre in Zone 1 of the IDZ The eNotice was placed on
13 April 2011 and will remain for the full duration of the EIA process
Registered stakeholders will be notified in writing of the availability of the draft EIA
report and EMP which will also be advertised in a local newspaper Stakeholders
including state departments and the public will have forty (40) days to comment on
the draft EIA report and EMP The draft EIA report and EMP will be sent by email
where possible and made available for download on the ILISO website
(wwwilisocom)
A summary of all issues and comments received during the stakeholder consultation
process as well as of correspondence in that regard will be captured in an Issues
and Responses Report that will form an Appendix to the EIA Report
The list of registered IampAPs is included in Appendix A
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 3-2
34 LEGISLATION AND GUIDELINES CONSIDERED
The following legislation and guidelines were considered in the preparation of this
report
National Environmental Management Act Act No 107 of 1998
NEMA EIA Regulations 2010
National Environmental Management Air Quality Act Act No 39 of 2004
National Environmental Management Waste Act Act No 59 of 2008
Hazardous Substances Act Act 15 of 1993
Occupational Health and Safety Act Act 85 of 1993
Hazardous Chemical Substances Regulations 1995 (GNR 1179)
Major Hazard Installation Regulations 2001 (GNR 692)
National Water Act Act 36 of 1998
National Heritage Resources Act Act 25 of 1999
DEAT Integrated Environmental Management Information Series 1-5 and 12-15
NEMA draft Implementation Guideline
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Public Participation (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Alternatives (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Draft Guideline for Determining the Scope of Specialist
Involvement in EIA Processes (2005)
IAIA guidelines
National air quality standard for thoracic particulates Government Gazette
No 32816
Listed activities and associated minimum standards identified in terms of section
21 of the National Environmental Management Air Quality Act Act No 39 of
2004 Government Notice 248 of 2009
Minimum Requirements for the Handling Classification and Disposal of
Hazardous Waste DWAF Waste Management Series (1998)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-1
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION
The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega
IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay
to the north of the N2 highway between Port Elizabeth and Grahamstown east of the
Coega River
The co-ordinates of the corners of the site are shown in Table 1
Table 1 Coordinates of site corners for the proposed galvanizing plant
Point Longitude Latitude
A 25deg411126E 33deg45587S
B 25deg411156E 33deg45499S
C 25deg411938E 33deg45131S
D 25deg412174E 33deg45481S
E 25deg412508E 33deg45979S
F 25deg412634E 33deg451160S
G 25deg411782E 33deg451560S
H 25deg411692E 33deg451428S
J 25deg411314E 33deg45868S
Figure 4 Zone layout in the Coega IDZ
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-2
Figure 5 Site location
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-3
42 SOCIO-ECONOMIC CHARACTERISTICS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the
NMBM There are no residents within the IDZ
As far as the broader NMBM and Eastern Cape Province are concerned the
following can be noted The NMBM is located within the Eastern Cape Province the
2nd largest Province in South Africa (3rd in terms of population) characterised by a
predominantly black population with low incomes and high levels of unemployment
(CES 2010)
The NMBM has a population of just above 11 million and covers an area of
1 950 km2 It is the main urban and industrial centre of the province and Port
Elizabeth in particular which forms part of the NMBM is the commercial capital of
the Eastern Cape 52 of the NMBM population is female and 37 is below the
age of 20 these two groups are particularly affected by unemployment
43 BIOPHYSICAL CHARACTERISTICS
431 Surface and ground water
No rivers occur in Zone 6 There is however a natural attenuation pond on the
southern most part of the site which will have to be avoided
The IDZ is underlain by calcrete sand and gravel deposits that overlie low
permeability clays These clays limit the vertical infiltration of rainwater and induce a
horizontal groundwater flow towards the Coega River channel which is the most
significant surface water feature in the Coega IDZ Consequently rapid run-off takes
place following precipitation (Jacobs 2008)
Groundwater levels at Coega are generally about 3 to 5 m below surface ie just
above the contact between the permeable sands and the underlying impermeable
clays The groundwater flow direction is to the southeast following the surface water
drainage direction (Jacobs 2008)
432 Climate and atmospheric conditions
Port Elizabeth has a warm temperate climate and the temperature ranges are not
extreme Exceptionally high temperatures may be experienced during berg wind
conditions which occur frequently during autumn and winter Extreme temperatures
also occur during summer with little accompanying wind
The wind regime for the area largely reflects the synoptic scale circulation with
dominant westerly and northwesterly flow fields representing the pre-frontal
conditions and south-westerly flow fields representing the frontal conditions The
south-easterly and south-westerly wind flow (land breeze) increases during daytime
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-4
conditions with westerly and north-westerly wind flow increasing during the night (sea
breeze)
The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of
Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15
km southwest) and Port Elizabeth (~23 km southwest)
An ambient air monitoring network has been established in the Coega IDZ which
consists of three monitors Saltworks Motherwell and Amsterdamplein Although
NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative
impacts due to the proposed Galvanising Plant is PM10 A maximum daily average
PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed
SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3
was exceeded on 17 days in 2007 and 26 days in 2008
Existing sources of emissions in the vicinity of the proposed galvanizing plant include
industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other
fugitive dust sources (von Gruenewaldt 2011b)
433 Geology and soils
Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel
and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly
limestone and conglomerate
434 Terrestrial ecology
This section draws from the EIA report compiled for the Agni Steel (formerly Afro-
Asia) steel processing facility which is adjacent to the proposed site for the
galvanizing plant (Jacobs 2008)
The area consists largely of grasses succulents and scrubby bush with alien
species making up the greater part of the more dense vegetation
Zone 6 falls within the inland vegetation and is characterised by a vegetation type
referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the
Coega IDZ and has been found to have three times the level of endemism of other
vegetation communities in the Coega IDZ Bontveld therefore has a high
conservation status Two Bontveld conservation areas have been identified within the
IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)
Bontveld that will be destroyed as a result of development in the IDZ will be given
conservation status in these two areas
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-5
Figure 6 Coega IDZ Open Space Management Plan (OSMP)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-6
Certain areas in the IDZ are invaded by alien plant species The most common
invader species is rooikrans (Acacia cyclops) which presently forms large
monospecific stands in areas throughout the Coega IDZ There are several other
aliens present that pose a threat to the flora of this area including the prickly pear
(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)
Loss of vegetation and alien plant invasion due to human activity has resulted in a
reduction in the diversity of terrestrial fauna
The majority of mammals present in the Coega IDZ are small or medium-sized Of
the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed
gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of
Algoa Bay however it is not considered threatened The gerbil is common in
foredune and dune thicket habitat in the Coega region and is therefore unlikely to
occur on the proposed site
A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird
species are resident or common to the area Most diversity occurs in the thicket
although the coastal area also supports specialised avifauna Two species of tern
the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well
as the Cape gannet (Morus capensis) and the African penguin (Spheniscus
demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne
caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant
(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser
flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns
are two of the most endangered coastal species in South Africa Other bird species
of conservation concern include the Whitefronted plover (Charadrius marginatus)
African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus
bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus
ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides
paradisea) Breeding pairs of Damara terns and African black oyster catchers have
been observed in the coastal dunes of the IDZ but should not be affected by
developments that fall outside the dune areas
The Eastern Cape supports nearly a third (approximately 133 species) of the reptile
species recorded in South Africa More than half of the Eastern Capersquos endemic
reptile species occur in the Algoa Bay area giving the region a high conservation
value A total of 63 reptile species are believed to occur within the Coega IDZ The
majority of these are found in Succulent Thicket and riverine habitats Only a few
reptile species occur in the coastal dunes and estuarine habitats More than a third of
the species are described as relatively tolerant of disturbed environments provided
that migration corridors of suitable habitat are maintained to link pristine habitats
Twenty two reptiles are of special concern including five endemic species (two of
which may also be endangered) four endangered sea turtles eight species listed
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-7
with CITES one rare species and four species at the periphery of their range
Fourteen of these species of special concern are confirmed as occurring on or within
2 km of the Coega IDZ
A total of 32 amphibian species and sub-species occur in the Eastern Cape
representing almost a third of the species recorded in South Africa However none of
the species are endemic or Red Data Book species Based on previous studies in the
area it is estimated that approximately 17 amphibian species occur within the Coega
IDZ Four species are listed as peripheral but none are threatened internationally
These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog
(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and
the bubbling kassina (Kassina senegalensis)
The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated
vegetation has not been extensively studied One grasshopper species Acrotylos
hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue
(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis
pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in
four localities in the Eastern Cape one of which is within the Coega IDZ The Coega
copper Aloeides clarki is endemic to this particular region of the Eastern Cape and
is currently known to occur in three localities two of which are in the Coega IDZ The
localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the
Coega IDZ and their distributions were taken into account when defining Coegarsquos
open space system and Development Framework Plan
435 Land use and topography
The land is currently undeveloped and earmarked for industrial development The
site is relatively flat ranging from an elevation of 66 masl on the northern-most
corner to 59 masl at the southern-most corner
436 Heritage and archaeological survey
Extensive studies have been undertaken in Zone 6 with respect to heritage aspects
Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a
2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond
2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is
currently being finalised
Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing
Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha
in extent and was located next to the R102 road to Motherwell Kaplan conducted
HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi
Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will
now be located in Zone 5)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-8
The various archaeological investigations reached similar observations and
conclusions Stone tools of various densities and types were found throughout the
zone The majority of the stone tools were mainly of Earlier and Middle Stone Age
and occasional Later Stone Age origins (Figure 4)
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble
gravels exposed by tracks in Zone 6 (Source Binneman 2010)
The stone tools which comprised of quartzite flakes chunks flaked pebblecobble
and cores were randomly distributed across the landscape and are in secondary
context There were no lsquoconcentrationsrsquo of tools observed which suggested any
spatial patterning or activity areas although these may be present or covered by soil
and vegetation
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 5-1
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED
The following environmental issues and potential impacts were identified in the
Scoping phase
51 AIR QUALITY
The galvanizing process generates atmospheric emissions with particulates and
hydrogen chloride representing the main pollutants of concern The plant is fitted with
air extraction as well as scrubber systems which are designed to retain the bulk of
pollutants and particles for each of the processes in such a way that less than 5 ppm
of gases and particles will be released into the atmosphere after the fume scrubber
Other sources of impact on air quality include emissions from the LNG burner as well
as emissions and dust from the transport of steel and other materials in trucks
Construction activities will also create dust and gas emissions due to the clearing of
groundcover tipping of material to storage pile levelling of area wind erosion from
storage piles vehicle and construction equipment activity and tailpipe emissions
from vehicles and construction equipment such as graders scrapers and dozers
Overall the air quality impact assessment (Gruenewaldt 2011b) found that
The predicted particulate oxides of nitrogen carbon monoxide and sulphur
dioxide concentrations are all below the National Ambient Air Quality Standards
for all averaging periods
The predicted off-site concentrations of hydrogen chloride are well below the
most stringent effect screening levels
No odour threshold exceedances for hydrogen chloride were predicted to occur
due to routine operations at the Steel Galvanising Plant The South Wales
Environmental Protection Authority stipulates that an odour unit of 20 is
acceptable for urban areas The odour unit would be lt10 directly off-site for
hydrogen chloride
Abnormal emissions can occur in exceptional circumstances Start-up will not
cause abnormal emissions as the scrubbers will be commissioned first and will be
functioning once the plant starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions would be emitted as a
building fugitive
The hourly hydrogen chloride ground level concentrations (directly offsite) were
predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based
on the emission limits as stipulated for listed activities for galvanising processes)
using a screen model which assumes worst case meteorological conditions The
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-2
health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming
abnormal emissions emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset conditions will still
be well within the health effect screening levels
Similarly the hourly particulate emissions from the building fugitives during upset
conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for
listed activities for galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly
off-site
Therefore if emissions are 5 times higher normal they will still be within health effect
screening levels and the daily PM10 NAAQS levels
In the case of a fire a cocktail of gases and particulates could be emitted and could
be over the recommended levels This situation will however be dealt with as an
emergency and normalised as quickly as is possible
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS
The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of
its heritage potential and there are no proposed protected geosites in Zone 6
Should any artefacts be discovered during construction procedures stipulated in the
draft EMP will apply
53 BIODIVERSITY AND CONSERVATION
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
In terms of terrestrial fauna the CDCrsquos open space management plan provides for
the preservation of certain corridors The destruction of certain habitats as a result of
the development will therefore not automatically result in the loss of certain species
54 WATER QUALITY
There is a natural attenuation pond on the southern most part of the site which will be
avoided
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through
spills or leaks
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-3
This risk can however be minimized if not avoided altogether The floor of the factory
will be designed as a bunded area to contain any spills and the entire process will be
contained Potential spills or leaks will therefore be contained and will not impact on
water resources Storm water is therefore considered clean water under normal
operational conditions An oil trap will be placed at the exit of the site to ensure that
no grease from the laydown area enters the stormwater system
Spills and leaks can occur during the handling or the transport of hazardous
substances Best practice guidelines will be followed to ensure that this risk is
adequately managed
Wastewater discharged to sewer will be treated to comply with municipal discharge
standards and is not expected to have an impact on the chemical characteristics of
the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be
discharged from the plant is small in relation to the total volume received at the
Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works
(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently
operated at 61 of its capacity which is approximately 80 Mℓday Thus the
0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore
not have any significant impact on the WWTW
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES
The plant will generate a relatively small amount of solid waste in the form of scrap
metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)
The scrap metal may be sold to other steel processing facilities such as Agni Steel
which will be located next to the plant or collected and disposed of with the rest of
the solid waste by a licensed service provider
As mentioned previously there will be a wastewater treatment plant on site which will
neutralise process water (012 Mlweek) in order to ensure it is of a standard
acceptable for discharge to sewer Waste in the form of sludge from the
neutralization or spent acid must be disposed of as a hazardous waste Solid waste
from the filters used for air quality control is also in this category These wastes can
usually be tested and then delisted which means that it can be placed in a general
purpose landfill
Hazardous effluent from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-
site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored
and removed on a monthly basis is limited to 10 m3
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-4
A number of substances classified as hazardous are used in the galvanizing process
(Table 2) and the transport and handling of these is subject to certain rules and
guidelines In particular the material safety data sheets (cf Appendix H) should be
referred to for inter alia hazards identification accidental release measures
handling and storage precautions exposure controlpersonal protection ecological
information and transport information The Hazardous Chemical Substances
Regulations 1995 should also be adhered to in respect of the transport and storage
of hazardous chemical substances
Table 2 Hazardous materials to be used on site
Major Input Materials
Substance
listed in the
SABS 0228
Group II
hazardous
substances
Volumes to be
stored on site at
any one time
Diesel radic 2000 litres
Liquid petroleum radic 20 000 liters
Sodium hydroxide (NaOH)
(used for degreasing) 8 radic 1000m
3
Hydrochloric acid (HCI)
(used for pickling) 8 radic 800m
3
Zinc (used for galvanising) - TBD
Trivalent chromium (CR+3
)
(used for chromating) 8 radic 10m
3
Sulphuric acid (H2SO4) (used for
treatment of waste water on site) 8 radic TBD
Ammonium Hydroxide (NH4OH) 8 radic TBD
TBD ndash To be determined
Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one
time) and is classified as a flammable substance Specification for flammable storage
facilities in accordance with the requirements of the Nelson Mandela Bay
Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for
quantities between 5000 and 20 000 liters the substance must be kept in a
flammable liquid store which complies with the requirements of a specification
obtainable from the Department Some of the requirements are
Flammable liquid and solid storage facilities are only permitted on the ground
floor
Decanting of flammable liquids and solids are not permitted within any building
Due to the fact that there are flammable materials on site a certificate may be
required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and
Emergency Services Department to confirm that facilities for flammable storage
are in accordance with their requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-5
Because of the permanent installation and high quantity of liquid petroleum on site
the Major Hazard Installation Regulations 2001 promulgated under the Occupational
Health and Safety Act No 85 of 1993 applies A written application for approval of
the installation is required to be submitted to the chief inspector Department of
Labour provincial director Department of Labour and NMBM prior to construction
In addition a risk assessment should be formulated covering all hazardous materials
together with an emergency preparedness and response plan
56 HEALTH AND SAFETY
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling instructions as well as occupational exposure limits
are indicated in the material safety data sheets of the various substances used
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as
provide site supervision including executing tests (individual test cold run and hot
run) during 3 months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the
EMP
In addition the emergency preparedness and response plan will cover the health and
safety aspects related to emergency situations
57 TRAFFIC
The volumes of traffic at the IDZ are currently relatively low and variable depending
on the different zones in the IDZ however these volumes will increase as more
developments are implemented
The construction phase of the Casa Steel development will take about 12 months
and will essentially consist of erecting a building to house the galvanizing line and
other equipment and preparing a concrete laydown area adjacent to the building
The traffic that would be generated during the construction phase can be expected to
be less than the traffic that would be generated by the Casa Steel development when
it is fully operational
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-6
In the operation phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and
from the Port of Ngqura
The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the
Casa Steel development would be off Ring Road 1 The other roads of significance
for the Casa Steel development are the N2 Neptune Road MR435 and MR450
Access to the port is given by Neptune Road Road Link NEP-03 has not yet been
built
Figure 8 Coega IDZ road network identification
(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-7
Figure 9 Coega IDZ road network
Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No
01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-8
The distribution of freight trips is fixed as the majority of trips will be made between
the Port of Ngqura and the Casa Steel site With regard to personnel trips there are
various points of origins (the surrounding residential areas) that could be used by
staff going to the Casa Steel site The distribution of personnel trips is based on
existing traffic count information and is shown in Figure 10
Figure 10 Trip distribution for freight and personnel trips
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The resultant expected Casa Steel traffic assignment is shown in Figure 11
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-9
Figure 11 Morning peak hour Casa Steel development traffic
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The traffic that is expected to be generated by the Casa Steel development is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low
and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)
Consultation has taken place with Transnet Port Authority (TPA) to establish the
impact of the galvanizing plant operations on traffic inside the port The additional
ships entering and exiting the port of Ngqura as a result of the proposed development
will have a negligible impact on port traffic and TPA indicated that it would be well
within the portrsquos capacity
58 NOISE
Noise is not foreseen to be a significant issue insofar as the noise levels inside the
plant and at the boundary of the site will not exceed the limits prescribed by the CDC
Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels
during the day and 60 decibels at night
Mitigation of noise impacts will be addressed in the design of the noise-emitting
components of the plant and their enclosures
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-10
59 SOCIO-ECONOMIC ASPECTS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of
NMBM There are no residents within the IDZ
The direct socio-economic impacts of the proposed project are thus limited to the
employment generated by the project during construction and operation Job creation
remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)
and the IDZ and Port of Ngqura are expected to become a significant catalyst to the
economic growth of the Municipality and the region with current investments at
Coega creating more jobs and stimulating the economy
In this context the proposed galvanizing plant will make a positive contribution
towards the achievement of these goals
There will be 50 to 60 employees during operation phase distributed as follows
Figure 12 Casa Steel organisation chart
Even though a large part of the inputs will be imported and the bulk of the production
output will be exported there will be some positive impacts for the economy of the
region and of South Africa in general Notably the requirements of the plant for
water electricity waste collection and disposal waste water treatment and transport
for example will create business for the various service providers and have an
indirect impact on employment and fiscal revenues as a result
From a visual impact point of view it can be anticipated that the landscape in the IDZ
will be significantly affected over time by developments related to the establishment
of the port and various industries
HEAD ( WORKS )
MGR ( COMM) MGR ( ADMNHR ) Manager marketing
MANAGER OPERATION MANAGER MANAGER MANAGER Q C
AC FIN PUR ampSTORE
PPC SH-GALV SH-tech
SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF
1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO
JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF
2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO
WORKERS WORKERS 7NOS
15 7
RAW MAT amp
DESP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 6-1
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
A description of the nature of the impact any specific legal requirements and the
stage (constructiondecommissioning or operation) will be given Impacts are
considered to be the same during construction and decommissioning The
significance of the potential impacts will be considered before and after identified
mitigation is implemented
The following criteria will be used to evaluate significance
Nature The nature of the impact will be classified as positive or negative and
direct or indirect
Extent and location Magnitude of the impact and is classified as
Local the impacted area is only at the site ndash the actual extent of the activity
Regional the impacted area extends to the surrounding immediate and
neighbouring properties
National the impact can be considered to be of national importance
Duration This measures the lifetime of the impact and is classified as
o Short term the impact will be for 0 ndash 3 years or only last for the period of
construction
o Medium term three to ten years
o Long term longer than 10 years or the impact will continue for the entire
operational lifetime of the project
o Permanent this applies to the impact that will remain after the operational
lifetime of the project
Intensity This is the degree to which the project affects or changes the
environment and is classified as
o Low the change is slight and often not noticeable and the natural functioning
of the environment is not affected
o Medium The environment is remarkably altered but still functions in a
modified way
o High Functioning of the affected environment is disturbed and can cease
Probability This is the likelihood or the chances that the impact will occur and
is classified as
o Low during the normal operation of the project no impacts are expected
o Medium the impact is likely to occur if extra care is not taken to mitigate
them
o High the environment will be affected irrespectively in some cases such
impact can be reduced
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 6-2
Confidence This is the level knowledgeinformation the environmental impact
practitioner or a specialist had in hisher judgement and is rated as
o Low the judgement is based on intuition and not on knowledge or
information
o Medium common sense and general knowledge informs the decision
o High Scientific and or proven information has been used to give such a
judgment
Significance Based on the above criteria the significance of issues will be
determined This is the importance of the impact in terms of physical extent and
time scale and is rated as
o Low the impacts are less important
o Medium the impacts are important and require attention mitigation is
required to reduce the negative impacts
o High the impacts are of great importance Mitigation is therefore crucial
Cumulative Impacts The possible cumulative impacts will also be considered
Mitigation Mitigation for significant issues is incorporated into the EMP for
construction
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 7-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS
71 IMPACTS DURING CONSTRUCTION
711 Air quality
Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris
handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine
particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural
operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks
and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)
Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Fugitive particulate emissions (dust)
related to construction activities Regional
Short
term Medium High High Medium Regional
Short
term Low High High Low
Construction vehicle gas emissions Regional Short
term Medium High High Medium Regional
Short
term Low High High Low
712 Heritage and archaeological resources
Naturedescription of impact excavation activities may impact on unidentified heritage resources
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-2
Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based
on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments
Heritage and archaeological
resources Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on unidentified heritage
resources Local
Short
term
Medium -
high Low High Low
713 Biodiversity and conservation
Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation
importance and cause soil contamination
Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species
Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan
and has compiled a list of protected species to be rescued (see draft EMP)
Biodiversity and conservation Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Loss of fauna and flora Local Perma
nent
Medium -
high High High High Local
Permanen
t Medium High High Medium
Soil contamination Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-3
714 Water related impacts
Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater
runoff spills and leaks Soil erosion
Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of
spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste
disposal Stormwater quality monitoring (see draft EMP)
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Soil erosion Local Short
term Medium Medium High Medium Local
Short
term Medium Low High Low
715 Waste management
Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed
Commentmitigation see draft EMP and waste management plan
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-4
Waste management Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Local
Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
716 Health and safety
Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Short
term
Medium -
high
Medium -
high High High Local
Short
term
Medium -
high Low High Low
717 Traffic
Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and
construction workers from surrounding areas and transport of equipment from the port
Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low
Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and
accurate estimates of quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-5
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Increased traffic on N2 and within the
IDZ Regional
Short
term Low High High Low
718 Noise
Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Short
term
Medium-
high High High Medium Local
Short
term Medium High High Medium
719 Socio-economic
Naturedescription of impact temporary employment will be created during the construction phase
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-6
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Temporary employment Regional Short
term Medium High High Medium
72 IMPACTS DURING OPERATION
721 Air quality
NatureDescription of impact gas and particulate emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning
Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local
sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and
veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute
to background fine particulate concentrations (von Gruenewaldt 2011b)
Assumptions and limitations Potential release of CR6+
As no emission factors are available for trivalent chromium processing the
potential impacts due to these activities could not be quantified
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Dust emitted from traffic on paved roads Regional Long Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-7
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
term
Hydrogen chloride emissions from
pickling process Local
Long
term Low High High Low
Particulate emissions (smoke) from
galvanizing process (due to the
volatilization of flux)
Local Long
term Low High High Low
Particulate oxides of nitrogen carbon
monoxide and sulphur dioxide emissions
from LNG burner
Local Long
term Low High High Low
Nuisance related to odour Local Long
term Low Low High Low
Abnormally high hydrogen chloride and
particulate emissions due to scrubber
malfunction
Local Short
term Medium Low High Medium
Gases (eg SOx NOx CO etc) and
smoke emitted in case of a fire Local
Short
term High Low High Medium
722 Water quality
NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks
Commentmitigation see draft EMP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-8
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Stormwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
723 Waste management and hazardous substances
NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous
waste both can affect environmental quality and human health
Commentmitigation see draft EMP and waste management plan
Waste management and hazardous
substances Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Regional
Long
term High
Medium -
high High High Regional Long term High Low High Low
Soilwaterair pollution due to improper
transport storage and handling of
hazardous substances
Regional Long
term High
Medium -
high High High Regional Long term High Low High Low
Health hazard Local Long
term High
Medium -
high High High Local Long term High Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-9
724 Health and safety
Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Long
term
Medium-
high
Medium-
high High High Local Long term
Medium-
high Low High Low
725 Traffic
Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on
the road network
Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak
hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road
network within Zone 6 of the IDZ (Iliso 2011)
Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)
Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of
quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-10
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on traffic and capacity of the N2 Regional Long
term Low High High Low
Impact on traffic and capacity of ring
road 1 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR435 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR450 Local
Long
term Low High High Low
Impact on traffic and capacity of
Neptune road Local
Long
term Low High High Low
726 Noise
Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Long
term Medium High High Medium Local Long term Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-11
727 Socio-economic
Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate
revenue for the municipality and the region as a whole
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Employment and economic growth Regional Short
term Medium High High Medium
73 COMPARATIVE ASSESSMENT OF IMPACTS
During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as
low during operation after mitigation
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 8-1
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
As a tenant operating in the IDZ Casa Steel will be required to comply with all
current and future CDC requirements as well as with the relevant conditions of
permits licences issued to CDC (eg Integrated Stormwater Masterplan for the
eastern side of the Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)
In particular the CDC has its own requirements regarding the monitoring of certain
aspects of the project such as the quality of the effluent and the noise levels These
have been incorporated into the EMP
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 9-1
9 ENVIRONMENTAL IMPACT STATEMENT
All predicted negative impacts can be mitigated to a low significance The only
exceptions are biodiversity as the construction of the plant will result in the
destruction of habitat and loss of fauna and flora and noise impacts inherent to
construction activities Mitigation measures have been included in the EMP for these
impacts and they have a medium significance post-mitigation
Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium to
long term similar impacts are likely to occur due to ongoing developments in the IDZ
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 10-1
10 CONCLUSION AND RECOMMENDATIONS
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as
other infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified
and assessed No fatal flaws have been identified
It is recommended that the project be approved subject to the conditions listed in
chapter 9 and adherence to the EMP requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 11-1
11 REFERENCES
Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ
Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants
Bennie JS (2010) The historical component (built environment) of the Heritage
Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port
Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report
compiled for Eastern Cape Heritage Consultants
Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater
Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay
Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage
Consultants
BKS (2006) Coega Industrial Development Zone Transport Study Volume 3
Demand Modelling Report Final Draft
Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I
Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6
Report compiled for SRK Consulting
Coastal amp Environmental Services (2010) Environmental Impact Assessment for the
Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone
Volume 3 Environmental Impact Assessment Report CES Grahamstown
Coega Development Corporation (2008) Industry Waste Management Plan -
Strategic Master Plan Report
Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants
Report No CDCSHE 03 8122
Department of Water Affairs and Forestry (1998) Waste Management Series
ldquoMinimum Requirements For The Handling Classification And Disposal Of
Hazardous Wasterdquo Second Edition
Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising
Plant in the Coega Industrial Development Zone
Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the
Coega Industrial Development Zone (IDZ) Specialist Water Study
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 11-2
Jacobs E (2008) Final Environmental Impact Report and Draft Environmental
Management Plan Proposed Steel Recycling and Processing Facility within the
Coega IDZ Report compiled for SRK Consulting
Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY
Galvanising Plant in the Coega Industrial Development Zone Waste Management
and Hazardous Substances Report compiled for ILISO Consulting
RSA National air quality standard for thoracic particulates (PM10) SA standards
(Government Gazette No 32816)
von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed
Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape
Report compiled for ILISO Consulting
von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel
Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report
compiled for ILISO Consulting
Additional sources
Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed
Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared
for Coastal Environmental Services
Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed
Kalagadi Manganese smelter in the Coega Industrial Development Zone Port
Elizabeth Eastern Cape Province Report prepared for Coastal Environmental
Services
Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia
steel recycling facility at the Coega Industrial Development Area Port Elizabeth
Prepared for SRK Consulting Port Elizabeth
APPENDIX A
LIST OF INTERESTED AND
AFFECTED PARTIES
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
DEDEARegional Manager
and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza
DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza
DEA Ocean and
CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza
DEA Ocean and
Coast
Oceanographer land-
based sources of
marine pollution
Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza
DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza
CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza
CDCEnvironmental
Project
Manager
Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza
TNPAPort of Ngqura
Environmental
Manager
Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet
NMBMEnvironmental
ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza
NMBMEnvironmental
ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza
DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza
DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza
WESSASenior Conservation
Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza
Zwartkops
ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700
hughlauegmailcom
zwartkopstrustiafricacom
SANParksNational Marine
CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza
Department Of
LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza
NMBM Air Quality
Division
Assistant
DirectorAir
Pollution and Noise
Templeton Titima 079 490 0574 Ttitimamandelametrogovza
NMBM Air Quality
DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza
NUMSARegional
RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
Department of
HealthNadiema
van der
Bergh083 378 2103
nadiemavanderberghimpiloecprovgov
za
DWA Chief Services
Officer
Joseph Jacobs 041 586 4884 jjacobsdwafgovza
EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza
NUMSecretary of union
officesZandile Xhentsa 043 743 6597 zxhentsanumorgza
DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza
Dynamic
CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom
EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza
Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza
UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom
lprincezago2uticom
Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza
Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza
Absa Mr Johann Steyn 082 3775820 johannstabsacoza
Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza
PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza
Universal
EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza
Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza
GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom
Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza
NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom
DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza
DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza
TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet
DWA Mr Landile Jack JackLdwagovza
DWA Ms Lizna Fourie FourieL4dwagovza
APPENDIX B
NOTICE OF ATMOSPHERIC
EMISSIONS LICENCE APPLICATION
AND ADVERTISEMENT
APPENDIX C
NOTICE OF COMMENT PERIOD FOR
DRAFT SCOPING REPORT
APPENDIX D
SUMMARY OF ISSUES RAISED AND
RESPONSES THERETO
April 2012
1
PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL
DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))
IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt
AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt
This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses
provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process
conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the
Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
2
IssueCommentQuestion Date
received Origin Response
1 Please provide more information with respect to the potential
dangers including the toxicity of the proposed project
07032011
By email
Wayne Poulton
(Bosun Brick
tenant at the
IDZ)
An Environmental Impact Assessment (EIA) was undertaken
which assessed the potential toxicity of the emissions and
effluent Mitigation measures were also recommended in the draft
Environmental Management Programme (EMP) to avoid
minimise or compensate any significant impacts The Draft
Environmental Impact Report and draft EMP were made available
to stakeholders for comment in March 2012
2 Do you have a Background Information Document (BID) or
similar that provides more information on the project
27032011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The BID was sent to all registered IampAPs on 4 May 2011
3 The RoD issued to the CDC on 632007 for the change in
land use for the remaining area of the Coega IDZ includes a
number of requirements with respect to
atmospheric emissions that should be considered in the
Atmospheric Emissions Licence (AEL) application such as
prohibiting and monitoring where possible visible emission
plumes to the atmosphere In particular the
recommendations on pp87-91 of the final revised Scoping
Report dated Nov 2006 must be implemented (clause 421)
04042011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
We have obtained copies of the documents referred to and ensure
that these requirements were taken into account in the
environmental assessment and AEL application
4 If the Port of Ngqura is used for import and export the scope
of the traffic impact assessment (TIA) should also include the
port
10052011
By email
Elliot
Motsoahole
(TNPA Port of
Ngqura)
The scope of the TIA was extended to include port related traffic
The TNPA at the Port of Ngqura was consulted and does not
have any objection to the project TNPA has indicated that the
development would require a minimum number of vessels per
year which would have minimal impact on the Port operations
However due notice would have to be given to the Port of Ngqura
before a vessel is scheduled to arrive so that the vessel can be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
3
IssueCommentQuestion Date
received Origin Response
accommodated at an available berth
5 Concerns with respect to potential stormwater pollution
draining into the Coega catchment and the port of Ngqura
The port needs to be dredged and heavy metals present a
risk in that regard
16052011
By
telephone
Andrew Lucas
(Department of
Water Affairs)
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination by effluent waste or
hazardousdangerous substances is very low
Thus no metals oils or other contaminants are expected to be
present in the stormwater
However stormwater pollution can occur in exceptional
circumstances such as accidents and emergencies The
emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
6 All steel sheets bathing unit must be under roof
7 The sludge out of the decreasing bath will be high in Na and
pH Therefore handling and disposal must be clarified up front
in this project
8 Per se the wastewater from decreasing bath will have high
ph and the component from the pickling unit will have low ph
Then it may be assumed that both streams will neutralize
each other Please then clarify proposed sewer discharge
with Nelson Mandela Bay Municipality up-front for acceptance
of influent as per the documented proposal
9 Pickling may result in dissolved metals How does your team
expect to deal with this As it is planned for discharge into
24052011
By email
Landile Jack
(Department of
Water Affairs)
All bathing units will be under roof
Effluent from the degreasing and pickling baths will be discharged
to the wastewater treatment plant The respectively alkaline and
acidic effluents will mix and neutralise each other in the
wastewater treatment plant Calcium or gypsum will be added if
required to complete the neutralisation process Effluent from the
treatment plant will be discharged to sewer Contact has been
made with the relevant officials and the Municipalityrsquos
requirements have been obtained The effluent discharged to
sewer will notably comply with the applicable discharge standards
Traces of metals (eg iron) may be present but will not exceed
prescribed thresholds The necessary authorisation will be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
4
IssueCommentQuestion Date
received Origin Response
sewer Clarity and acceptance needs to be agreed with
Nelson Mandela Bay Municipality Who owns the sewer
10 Quenching unit will results to Zinc particles How will this
affect sewer discharge This again must be dealt with within
the negotiations with the Municipality
11 Once all has been agreed with the Municipality and at the
same time due negotiations must be done with hazardous
waste courier and disposal facility to accept the hazardous
waste identified in all production lines
12 Of note is the low volume of the proposed WWTW facility ie
250 cubmweek And the no discharge of the quenching
water ie over-flow and cooling only Hence Zinc particles
generation
obtained from the municipality
The sludge from the treatment plant will be collected by a licensed
service provider and disposed of at a permitted site
The quenching bath will be periodically emptied (every 6 months)
and the water discharged will go to the water treatment plant Zinc
particles will settle in the sludge which will be disposed of at a
permitted site
Contact has been made with EnviroServ who manages the
Aloes II HH waste site regarding collection and disposal of
hazardous waste (See waste management report)
13 Investigate the potential effects of toxicity andor influence of
emissions waste and hazardous substances both in
terrestrial and marine fauna
14 With regards to water usage where is the plant going to
extract its waters used in galvanization andor waste
management process ie rainfall rivers or even from the
sea) and which avenues would be more environmental
friendly and effective
31052011
By email
A Bewana
(SANPARKS)
Emissions waste and hazardous substances are not expected to
affect terrestrial or marine ecosystems The air quality study
concluded that atmospheric emissions would not be harmful to
human health and by extension terrestrial fauna There are no
standards for air quality for defining faunal impacts therefore by
ensuring that standards for humans are complied with the impact
on fauna is deemed to be acceptable In this case the impact of
emissions on terrestrial and marine fauna are thus not significant
Solid and liquid wastes both general and hazardous as well as
hazardous substances will be stored handled and disposed of
appropriately to as not to cause harm to terrestrial or marine
fauna
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
5
IssueCommentQuestion Date
received Origin Response
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination and hence land-based
marine pollution by effluent waste or hazardousdangerous
substances is very low
The risk of emissions waste and hazardous substances to
terrestrial and marine fauna is thus very low
However pollution of terrestrial and marine ecosystems can occur
in exceptional circumstances such as accidents and emergencies
The emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
The CDC has an agreement with the NMBM to supply potable
water to the Coega IDZ Currently the infrastructure to supply
return effluent (RE) to the IDZ is not in place therefore Casa Steel
will be supplied with potable water up until such time as the
following 2 options of RE are available
1) Upgrading of the existing Fishwater Flats waste water
treatment works (between IDZ amp PE) including RE plant
and infrastructure to pipe RE to the IDZ (EIA for the
upgrade is underway)
2) Construction of a new waste water treatment works
including RE plant in Zone 9 of the Coega IDZ
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option should be investigated further between Agni and Casa The
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
6
IssueCommentQuestion Date
received Origin Response
CDC can facilitate discussions between the 2 investors
Compliance with CDC Permits amp Requirements
15 It should be made clear that tenants will be required to
comply with CDC requirements and the relevant conditions of
permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water
Licence for its Storm Water Systems on the
East Side of the Coega River that tenants will
need to take cognizance of The contents of the
ldquoIntegrated Stormwater Masterplan for the
eastern side of the Coega IDZ Oct 2010rdquo
especially the Table of best practice p53
onwards may need to be taken cognizance of
o CDC is developing an Operations
Environmental Management Plan that will place
certain obligations on tenants
16 Environmental audits and data collected during monitoring
(eg stack emissions stormwater) will need to be shared with
CDC
Air Emissions
17 Presumably permanent in stack monitoring will be required in
terms of AEL permit requirements
18 Abnormal operating conditions resulting in air emissions ndash I
could find nothing in the EIR to indicate under what
circumstances these could occur (eg start-up) potential
frequency and duration and the impact on ambient air quality
ndash these events usually result in the most problems wrt air
emissions
09042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
15 Compliance with the CDCrsquos Permits amp Requirements has
been included explicitly as a requirement in the EIR (p8-1) and
EMP (pp18 and 25) in the following terms
ldquoAs a tenant operating in the IDZ Casa Steel will be required to
comply with all current and future CDC requirements as well as
with the relevant conditions of permits licences issued to CDC
(eg Integrated Stormwater Masterplan for the eastern side of the
Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)rdquo
16 The need to communicate with the CDC on monitoring and
auditing activities was emphasised in Chapter 8 of the EMP The
following paragraphs were added
ldquoDuring construction the environmental officer will be responsible
for monitoring compliance with the EMP and authorisation
conditions and keeping records as required in the EMP andor
authorisation conditions
The ECO will conduct site inspections every two weeks audit the
records kept by the environmental officer and submit an
environmental compliance report every two months to the
authorities and the CDC (via the Environmental Monitoring
Committeersquos ECO)
During operation the health and safety officer will monitor
compliance with the EMP and the conditions of the Environmental
Authorisation Data collected during monitoring activities and any
environmental audits conducted will be shared with authorities
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
7
IssueCommentQuestion Date
received Origin Response
Water
19 Large volumes of (2000 m3mth) of water are required of
which only 400m3 needs to be potable The NMBM return
effluent system will provide non-potable water once it is
constructed What other water recycling initiatives can be
utilized to reduce potable water requirements (the ISWMP for
the eastern side of the Coega IDZ has some best practice
guidelines collecting rainwater from the roof etc)
General
20 There is no mention of how the CDC Architectural Guidelines
will be incorporated into the development (eg to prevent a
stark uniform warehouse type development)
21 Does NMBM have adequate fire services to cover this
development Apart from the large petroleum store are there
any other large fire hazards
22 Reports from the tenantrsquos ECO during construction and from
the SHE Officer during operations should be channeled to the
Coega Environmental Monitoring Committee This can be
directly or preferably via the EMCrsquos ECO (this will be while
the EMC and ECO are in place) A precedent has been set
for this in the Environmental Authorisations for Agni-Steel and
Kalagadi Manganese Smelter
23 All mitigation actions emanating from the EIR should be
summarized (preferably in a table) If compliance with them is
to be part of the Environmental Authorization from DEDEAT
then they (or the ones that DEDEAT deems to be applicable)
and the CDC (via the Environmental Monitoring Committeersquos
ECO)
The ECO (during construction) and the health and safety officer
(during operation) will report to the Coega Environmental
Monitoring Committee (EMC) via the EMCrsquos ECO (this will be
while the EMC and ECO are in place)rdquo
17 The draft EMP recommends regular monitoring of emissions
from the scrubbers and from the chromating process Additional
emissions monitoring requirements will be confirmed once the
AEL is issued Mention has been made in the EMP (pp11 and 19)
that all AEL conditions including monitoring and reporting
requirements should be adhered to
18 Abnormal emissions can occur in exceptional circumstances
Start-up will not cause abnormal emissions as the scrubbers
will be commissioned first and will be functioning once the plant
starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions
would be emitted as a building fugitive
The hourly hydrogen chloride ground level concentrations
(directly offsite) were predicted to be 239 microgmsup3 (based on the
emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits
as stipulated for listed activities for galvanising processes) using a
screen model which assumes worst case meteorological
conditions The health effect screening level for hourly HCl
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
8
IssueCommentQuestion Date
received Origin Response
should be attached to the EA as an Appendix (otherwise no
one knows about them or takes cognizance of them)
concentrations is 2100 microgmsup3 Assuming abnormal emissions
emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset
conditions will still be well within the health effect screening
levels
Similarly the hourly particulate emissions from the building
fugitives during upset conditions would amount to 293 microgmsup3
(based on the emission limits as stipulated for listed activities for
galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1
January 2015) directly off-site
Therefore if emissions are 5 times higher normal they will still be
within health effect screening levels and the daily PM10 NAAQS
levels
In the case of a fire a cocktail of gases and particulates could be
emitted and could be over the recommended levels This
situation will however be dealt with as an emergency and
normalised as quickly as is possible
The above has been added to the impact identificationdescription
and assessment sections of the EIR
19 The CDC has an agreement with the NMBM to supply
potable water to the Coega IDZ Currently the infrastructure to
supply return effluent to the IDZ is not in place therefore Casa
Steel will be supplied with potable water up until such time as the
infrastructure is in place
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
9
IssueCommentQuestion Date
received Origin Response
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option will be investigated further between Agni and Casa The
CDC has come forward to facilitate discussions between the two
investors
Other water recycling initiatives such as rainwater harvesting
have been considered but are not practical
20 The CDCrsquos Architectural and Landscape Design guidelines
contain requirements pertaining to such aspects as the height
orientation and mass and form of buildings as well as guidelines
for landscaping and signage in order to ensure an attractive
development and achieve an architectural integrity within the
Coega IDZ The plans for the proposed galvanizing plant will be
submitted to the Design Review Committee for approval as
required by the CDC
21 Casa Steel will be required to install fire hydrants according
to the NMBMrsquos standardsrequirements The CDC will provide
potable water (up until such time as return effluent is available)
and a connection to the boundary of the site which will be
connected to the fire hydrants The installation of the fire hydrants
will require approval by the Metrorsquos Fire Chief as was done for
Agni-Steel one of the investors in Zone 6
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
10
IssueCommentQuestion Date
received Origin Response
The Coega IDZ falls within the NMBM and therefore the rates and
taxes paid by the CDC covers the fire services for which the Metro
is responsible Currently the Metro has sufficient capacity to
provide fire services to the tenants within the IDZ This was
confirmed in discussion with the CDCrsquos Infrastructure
Development Unit It is however unknown at which point the
Metrorsquos Disaster Management Plan would not be able to
accommodate servicing tenants in the IDZ
The LNG burner is the only major fire hazard on the plant
22 See response to item 16 above
23 Key mitigation and management measures emanating from
the EIR were recapitulated in Chapter 9 of the EIR to form part of
the conditions attached to the Environmental Authorization from
DEDEAT All mitigation measures recommended as a result of the
impact assessment are presented in a table in the draft EMP
which is appended to the EIR (Appendix J)
24 Hydrogen chloride is one of the main emissions There are no
ambient air quality guidelines for HCl and the EIR says
concentrations will be well within health parameters
However the main problem with HCl is its corrosive effect -
there is absolutely no mention of this in the draft EIR nor air
specialist report
There needs to be some sort of comment assessment as to
whether HCl emissions are likely to impact on for example
the adjacent Agni-Steel Plant wrt corrosion - their factory
structure will be made of steel
11042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The atmospheric corrosion of metals is a complex process with
both the extent of deterioration and the mechanisms varying
considerably depending on the metal Depending on the way
pollutants are transported from the atmosphere to the corroding
surface two types of deposition processes are recognized in
atmospheric corrosion ndash dry deposition and wet deposition Wet
deposition refers to precipitation whereas dry deposition refers to
the remaining processes including gas phase deposition and
particle deposition The most important pollutants acting as
corrosive agents are sulphur and nitrogen compounds including
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
11
IssueCommentQuestion Date
received Origin Response
The EIR specialist rpt suggests monitoring HCl at ground
level on the property boundary and this is supported in case
there are complaints from neighbours
secondary pollutants and particulates Pollutants can contribute to
corrosivity individually however there may be a synergistic effect
when more than one of these pollutants is present in the
environment being affected In the field of atmospheric corrosion
sulphur dioxide is the single most investigated gaseous pollutant
and the quantification of the direct contribution of sulphur dioxide
to the corrosion process of metallic materials is comparatively well
understood (Tidblad amp Kucera 1998)
Very little work has reported on the effect of HCl on the
degradation of materials in the environment with no local dose-
response thresholds developed for corrosion occurring due to HCl
exposures This is probably because HCl which is present
outdoors in markedly reduced concentrations when compared
with SO2 has not been considered to contribute to significant
degradation of materials (Syed 2006) For this reason the
incremental corrosion due to HCl from the Coega Galvanising
Plant cannot be quantified
25 It is unacceptable for ILISO to be using CDC maps (see
figure 9 ndash pg5-6) without these maps being referenced
accordingly particularly when it appears that a CDC map has
been used and then overlaid with features by an unknown
author (ie CASA steel site Port (where the boundaries
depicted are incorrect) and a North legend which is out of
keeping with the overall cartographic intent of the original
work
26 Figure 10 is not referenced appropriately and I believe that I
commented previously in respect to references to roads not
12042012
By email
Graham Taylor
(Spatial
Development
Manager -
Infrastructure
Development
CDC)
This has been rectified in the final version of the report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
12
IssueCommentQuestion Date
received Origin Response
yet built As a result Figure 10 is confusing and clarity needs
to be provided in terms of referencing In addition the Port
shape is irregular and similar to the comment above
27 I acknowledge the emergency preparedness and response
plan but please confirm that this includes pro-active routine
monitoring of storm water leaving your premises to verify that
your assumptions of clean storm water are correct
13042012
By post
Andrew Lucas
(Director
WRampU
Department of
Water Affairs)
Pro-active routine monitoring of stormwater leaving the premises
will be undertaken This has been explicitly emphasised in
chapter 8 of the draft EMP
28 Will portablechemical toilets be used during construction
29 What provisions have been made for storm water drainage
during construction
18042012
By
telephone
Department of
Water Affairs
Port Elizabeth
Chemical toilets will be used during construction
The Casa Steel site will be located at the corner of two roads
drainage of stormwater from the site will take place through the
roadsrsquo drainage system
From Lea September [mailtoleailisocom]
Sent 11 March 2011 0935 AM
To Wayne Poulton
Cc Terry Baker
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Wayne
An Environmental Impact Assessment (EIA) will be undertaken for this project during the
next 10 to 12 months
We foresee that some of the key environmental impacts of the project will be in terms of air
quality water quality waste and hazardous substances
At this stage I am not able to give you any details regarding the potential toxicity of the
emissions andor effluent However specialist studies will be conducted as part of the EIA
that will determine the key impacts of the project Mitigation measures will also be identified
to avoid minimise or compensate any significant impacts
You are registered on the stakeholder database and you will be kept informed of progress in
the EIA process you will notably get the opportunity to access the reports produced and
provide any feedback on them
Please feel free to contact me should you need any further information
Best regards
Lea September
From Wayne Poulton [mailtowaynepbosuncoza]
Sent 07 March 2011 1257 PM
To Lea September
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
Please can you provide me with some more information as to the potential dangers including
the toxicity of this
Kind regards
Wayne
From Lea September [mailtoleailisocom]
Sent 04 March 2011 1123
To Lea September
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 March 2011 0745 AM
To Paul Martin
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 05 April 2011 0847 AM
To Paul Martin
Cc Terry Baker Renee von Gruenewaldt
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Thank you Paul for this information
I have downloaded a copy of the RoD and Scoping report you referred to and will make sure
these requirements are taken into account in the environmental assessment
Best regards
Lea September
From Paul Martin [mailtopmartinaxxesscoza]
Sent 04 April 2011 0955 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Further to my comments on 27311
Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in
the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega
IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised
scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions
including prohibiting and monitoring where possible visible emission plumes to the atmosphere
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Paul Martin
Sent Monday March 28 2011 745 AM
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 10 May 2011 0327 PM
To ElliotMotsoaholetransnetnet
Cc Terry Baker
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Mr Motsoahole
Thank you for your input on this issue
The Port of Ngqura will indeed be used for import and export At the moment the scope of
the traffic impact assessment only covers road traffic I have however relayed the matter to
our traffic specialist and we will consider this issue in the finalization of the Scoping Report I
will keep you informed of any developments in that regard
I trust this is acceptable to you
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]
Sent 10 May 2011 0855 AM
To Lea September
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
It has been noted that Casa Steel will source steel coils from various markets internationally and
in South Africa and the bulk of the plantrsquos production output will be exported to African countries
However there is no mention of logistic requirements
Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will
be used the scope of traffic impact assessment should also include the port
Regards
From Lea September [mailtoleailisocom]
Sent 04 May 2011 0747 AM
To Lea September
Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
Please find attached a letter announcing the EIA process underway for the proposed 80 000
tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as
a Background Information Document (BID) outlining the details of the project
Please contact me should you require any further information on this project
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
Elliot Motsoahole
Manager - Environment
Transnet National Ports Authority
Port of Nqqura
Port Control Building Klub Road Port Elizabeth 6212
PO Box 612054 Bluewater Bay 6212
+27 41 507 8450
+27 86 674 7729
Cell +27 83 542 5619
E-mail Elliotmotsoaholetransnetnet
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
DISCLAIMER The information contained in this communication is subject to copyright and
intended only for the use of leailisocom Unauthorised use disclosure or copying is
strictly prohibited Should a virus infection occur as a result of this communication the sender
will not be liable If you have received this communication in error please notify
elliotmotsoaholetransnetnet
From Lea September [mailtoleailisocom]
Sent 25 May 2011 1147 AM
To Jack Landile (ELS)
Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi
Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Landile
Thank you for your input
Contact has been made with the relevant Municipal Directorate and we will follow up with
them to obtain clarifications on all these issues
I have added both Lizna and yourself on the database and will keep you updated on
progress on this project
Best regards
Lea September
From Jack Landile (ELS) [mailtoJackLdwagovza]
Sent 24 May 2011 0524 PM
To Fourie Lizna (ELS)
Cc Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Hi Lizna
I missed you on this sorry
I linked Pieter twice Instead
Regards
Landile
From Jack Landile (ELS)
Sent 24 May 2011 0445 PM
To leailisocom
Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Lea
The e-mail you sent to Mr Kooverji dated 19 May 2011 refer
Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are
All steel sheets bathing unit must be under roof
The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project
Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal
Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer
Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality
Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines
Of note is the low volume of the proposed WWTW facility ie 250 cubmweek
And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles
generation
Regards
Landile
From Lea September [mailtoleailisocom]
Sent 19 May 2011 0947 AM
To Lea September
Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Stakeholder
Please find attached the remaining appendices to the draft Scoping report for the proposed
80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 June 2011 0411 PM
To Aphiwe Bewana
Subject RE Proposed 80 000 TPY Galvanizing plant in Coega
Dear Mr Bewana
Thank you for your input and apologies for the late reply
We have taken note of your comments and are will be taking them forward in the EIA phase
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Aphiwe Bewana [mailtoaphiwebewanagmailcom]
Sent 31 May 2011 1205 PM
To Lea September
Subject Re Proposed 80 000 TPY Galvanizing plant in Coega
Comment
Re Proposed 80 000 TPY Galvanizing plant in Coega
As SANParks we would like the EIA phase to investigate the potential effects of toxicity
andor influence of emissions waste and hazardous substances both in terrestrial and
marine fauna In the draft scoping report reference has been made with regards to the
terrestrial fauna but there is no attention to potential effects to marine fauna
Equally with regards to water usage where is the plant going to extract its waters used in
galvanization andor waste management process ie rainfall rivers or even from the sea)
and which avenues would be more environmental friendly and effective
Regards
Aphiwe Bewana
Marine Planner
South African National Parks
POBox 76693
NMMU
Port Elizabeth
6031
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 06 July 2011 1031 AM
To Lea September
Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Hi Lea
Irsquove reviewed the Final Scoping Report Herewith a few comments
1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the
Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a
revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the
NMBLP Please include only those in the IDZ as part of your IAP list
Regards
Andrea
From Lea September [mailtoleailisocom]
Sent Wednesday July 06 2011 859 AM
To Lea Septemberrsquo
Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Dear Stakeholder
The final scoping report for the above-mentioned project (attached) is available for comment
until 27 July 2011
The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic
commentaryrdquo tab
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 09 April 2012 1159 AM
To Lea September
Subject Comments on Galvanising Plant EIR Coega IDZ
Lea
Attached are my comments on the Draft EIR for the Coega IDZ galvanising
plant
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
Email attachment
COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ
Dr Paul Martin PO Box 61029
Bluewater Bay 6212 Tel 041 4665698
Email pmartinaxxesscoza
Compliance with CDC Permits amp Requirements
It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of
o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants
Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC
Air Emissions
Presumably permanent in stack monitoring will be required in terms of AEL permit requirements
Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions
Water
Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)
General
There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)
Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards
Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter
All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 11 April 2012 1245 PM
To Lea September
Subject Fw Comments on Galvanising Plant EIR Coega IDZ
Lea
One other comment on that I have on the Galvanising Plant Draft EIR
Hydrogen chloride is one of the main emissions There are no ambient air
quality guidelines for HCl and the EIR says concentrations will be well
within health parameters
However the main problem with HCl is its corrosive effect - there is
absolutely no mention of this in the draft EIR nor air specialist report
There needs to be some sort of comment assessment as to whether HCl
emissions are likely to impact on for example the adjacent Agni-Steel
Plant wrt corrosion - their factory structure will be made of steel
The EIR specialist rpt suggests monitoring HCl at ground level on the
property boundary and this is supported in case there are complaints from
neighbours
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Paul Martin ltpmartinaxxesscozagt
To Lea September ltleailisocomgt
Sent Monday April 09 2012 1158 AM
Subject Comments on Galvanising Plant EIR Coega IDZ
gt Lea
gt
gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising
gt plant
gt
gt
gt Dr Paul Martin
gt PO Box 61029
gt Bluewater Bay 6212
gt Tel 041 4665698
gt Cell 0732524111
gt email pmartinaxxesscoza
gt
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 12 April 2012 1139 AM
To Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Hi Lea
Hope yoursquore keeping well
I have requested comments from my colleagues and the CDC Casa team on the Draft EIR
Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report
Regards
Andrea
From Graham Taylor
Sent Thursday April 12 2012 838 AM
To Andrea Von Holdt Firhana Sam
Cc Johan Fourie Maria van Zyl Melikhaya Sihawu
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Andrea Firhana
Firhana if you could please ensure that the co-ordinates provided in the EIR correspond
with our records (pages 4-1 amp 4-2)
My comments are as follows
It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work
Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above
Regards
Graham Taylor
Spatial Development Manager - Infrastructure Development
Mobile 0832283055
Office 0414030454
Facsimile 0865185033
Email GrahamTaylorcoegacoza
Website wwwcoegacom
right PLACE | right TIME | right CHOICE
This email and all contents are subject to the following disclaimer
httpwwwcoegacomemaildisclaimerhtml
From Lea September [mailtoleailisocom]
Sent 04 May 2012 0411 PM
To Andrea Von Holdt
Cc Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Dear Andrea
We have taken note of the comments from the GIS Unit These issues have been rectified in
the final version of the EIR
Please can you forward to the relevant persons at the GIS Unit
Thank you
Best regards
Lea September
APPENDIX E
BACKGROUND INFORMATION
DOCUMENT
APPENDIX F
AIR QUALITY IMPACT ASSESSMENT
APPENDIX G
TRAFFIC IMPACT ASSESSMENT
APPENDIX H
WASTE MANAGEMENT AND HAZARDOUS
SUBSTANCES SPECIALIST STUDY
APPENDIX I
WATER QUALITY SPECIALIST STUDY
APPENDIX J
ENVIRONMENTAL MANAGEMENT
PROGRAMME
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 iii
Figure 10 Trip distribution for freight and personnel trips 5-8
Figure 11 Morning peak hour Casa Steel development traffic 5-9
Figure 12 Casa Steel organisation chart 5-10
LIST OF TABLES
Table 1 Coordinates of site corners for the proposed galvanizing plant 4-1
Table 2 Hazardous materials to be used on site 5-4
APPENDICES
APPENDIX A List of registered stakeholders
APPENDIX B Notice of AEL application and advertisements
APPENDIX C Notice of comment period for draft scoping report
APPENDIX D Summary of issues raised and responses thereto
APPENDIX E Background Information Document
APPENDIX F Air Quality Impact Assessment
APPENDIX G Traffic Impact Assessment
APPENDIX H Waste Management and Hazardous Substances specialist study
APPENDIX I Water Quality Specialist Study
APPENDIX J Environmental Management Programme (EMP)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 iv
ACRONYMS
AEL Atmospheric Emissions Licence
BID Background Information Document
CCA Custom Controlled Area
CDC Coega Development Corporation
DEA Department of Environmental Affairs
DEDEAT Department of Economic Development Environmental Affairs and Tourism
DWA Department of Water Affairs
EAP Environmental Assessment Practitioner
EIA Environmental Impact Assessment
ELC Environmental Liaison Committee
EMP Environmental Management Programme
GN Government Notice
IampAPs Interested and Affected Parties
IDZ Industrial Development Zone
LNG Liquid natural gas
masl Meters above sea level
MSDS Material Safety Data sheet
NEMA National Environmental Management Act
NEMBA National Environment Management Biodiversity Act (No10 of 2004)
NMBM Nelson Mandela Bay Municipality
OSMP Open Space Management Plan
PoS Plan of Study
SAHRA South African Heritage Resources Agency
TNPA Transnet National Ports Authority
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 v
EXECUTIVE SUMMARY
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone
(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province
Galvanizing consists of coating steel with zinc in order to protect it from corrosion An
Environmental Impact Assessment (EIA) is required as the proposed project involves several
activities listed in terms of Section 24 of the National Environmental Management Act
(NEMA) 107 of 1998 as amended and requires an environmental authorisation The
project also involves activities listed in terms of the National Environmental Management Air
Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008
which respectively require an Atmospheric Emissions Licence and a Waste Management
Licence
The Scoping and Environmental Impact Assessment process underway covers all aspects of
the project and informs all three applications
Scoping was the first phase of investigations and aimed to inter alia identify potential key
environmental issues and impacts to be addressed in the EIA phase
The following environmental issues and potential impacts identified in the Scoping Phase
were investigated in the EIA
Air quality
The galvanizing process generates atmospheric emissions which are regulated in terms
of the National Environmental Management Air Quality Act and appropriate measures
are required in order to adhere to the applicable standards Other sources of impact on
air quality include emissions from the LNG burner emissions and dust from the transport
of steel and other materials in trucks as well as dust and gas emissions related to
construction activities Mitigation measures recommended in the EMP will ensure that air
quality impacts are kept to a minimum and compliance with emissions standards is
maintained
Biodiversity and conservation
Certain types of vegetation in the IDZ are of high conservation importance Protected
species will be rescued as per the CDCrsquos requirements
Water quality
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through spills
or leaks This risk can however be minimized if not avoided altogether through design
choices (bunded areas) and the adherence to best practice guidelines for the handling or
the transport of hazardous substances and waste
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vi
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
Waste management and hazardous substances
The plant will generate a relatively small amount of solid waste which will be re-used
recycled or disposed of in accordance with the EMP recommendations
There will be a wastewater treatment plant on site which will neutralise process water
(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer
Hazardous waste from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site
at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and
removed on a monthly basis is limited to 10 m3
A number of substances classified as hazardous are used in the galvanizing process and
the transport and handling of these is subject to certain rules and guidelines
In addition the permanent storage of a high quantity of liquid petroleum on site (20 000
litres at any one time) is subject to certain specifications and requires approval from the
municipality
Health and safety
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling of the various substances used will be done in
accordance with applicable instructions (cf material safety data sheets)
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as provide
site supervision including executing tests (individual test cold run and hot run) during 3
months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the EMP
Traffic
In the operational phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and from
the Port of Ngqura
The traffic expected to be generated during construction as well as operation is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low and
the total traffic generated by Casa Steel is also relatively low
The impact on port traffic is also negligible and well within the portrsquos capacity
Socio-economic aspects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vii
The proposed galvanizing plant will make a positive contribution by creating jobs during
construction and operation and generating business for the various service providers
Fatal flaws
No fatal flaws have been identified
The significance of these potential key environmental impacts were assessed in the EIA
phase and the findings of this phase of investigations are presented in this report
The main findings of the EIA are as follows
During construction impacts post-mitigation are low with the exception of noise and
biodiversity as the construction of the plant will result in the destruction of habitat
and loss of fauna and flora and noise impacts inherent to construction activities
Mitigation measures have been included in the EMP for these impacts and they have
a medium significance post-mitigation
All impacts were assessed as low during operation after mitigation
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium
to long term similar impacts are likely to occur due to ongoing developments in the
IDZ
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
The CDC has its own requirements regarding the monitoring of certain aspects of the
project such as the quality of the effluent and the noise levels These have been
incorporated into the EMP Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as other
infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified and
assessed No fatal flaws have been identified
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 viii
It is recommended that the project be approved subject to the conditions listed above
and adherence to the EMP recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-1
1 INTRODUCTION
11 BACKGROUND
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)
Nelson Mandela Bay Municipality Eastern Cape Province
The demand for galvanised steel products is high in South Africa and Africa and is
expected to increase in the foreseeable future From an economic point of view the
proposed project has therefore been found to be viable
Casa Steel will source the steel coils from various markets internationally and in
South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is
destined to be exported mainly to African countries
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
An Environmental Impact Assessment (EIA) is required as the proposed project
involves several activities listed in terms of Section 24 of the National Environmental
Management Act (NEMA) No 107 of 1998 as amended and requires an
environmental authorisation
The following listed activities requiring environmental authorisation have been
identified
Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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
Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped
land to industrial use greater than 1 ha but less than 20 ha in size outside an
urban area
Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any
process or activity requiring a license in terms of national or provincial legislation
governing the generation or release of emissions
Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5
hectares or more of vegetation where 75 or more of the vegetative cover
constitutes indigenous vegetation except where such removal of vegetation is
required for
(i) purposes of agriculture or afforestation inside areas identified in
spatial instruments adopted by the competent authority for
agriculture or afforestation purposes
(ii) the undertaking of a process or activity included in the list of waste
management activities published in terms of section 19 of the
National Environmental Management Waste Act 2008 (Act No 59
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-2
of 2008) in which case the activity is regarded to be excluded from
this list
(iii) the undertaking of a linear activity falling below the thresholds in
Notice 544 of 2010
Hot dip galvanizing is a listed activity in terms of section 21 of the National
Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires
an Atmospheric Emissions Licence (AEL)
In addition the treatment of wastewater with an annual throughput capacity of more
than 2000 m3 is a listed activity in terms of the National Environmental Management
Waste Act 59 of 2008 and requires a waste management licence
ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental
Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact
Assessment process in terms of section 24 of NEMA for the construction and
operation of the proposed galvanizing plant The EIA process covers all aspects of
the project and informs all three applications (for environmental authorisation waste
management licence and AEL)
13 PURPOSE OF THIS REPORT
This report builds on the scoping report submitted to the Eastern Cape Department of
Economic Development and Environmental Affairs (DEDEA) and the Nelson
Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It
describes the proposed project and presents the findings of the second phase of
investigations (EIA phase)
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP)
The EIA was managed by Ms Terry Baker a certified Environmental Assessment
Practitioner with 20 years of working experience She has a MA in Environmental
Management and specialises in Environmental Impact Assessments and Project
Management She has been involved in a variety of different types of EIAs including
for water supply projects dams transmission lines roads and airports in South
Africa Botswana Uganda Lesotho and Mozambique She has been involved in
water resource management and public participation programmes on a number of
projects Terry has also been involved in the use of Geographic Information Systems
environmental status quo reports water quality assessments socio-economic and
institutional development projects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-3
15 PROJECT TEAM
In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen
(water quality specialist) and Lea September (EAP) with specialist input from Renee
von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous
substances) and Seniel Pillay (Traffic Impact Assessor)
The Business Unit Head of the ILISO Environmental Management Discipline Group
Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is
a Fellow of the South African Institution of Civil Engineers a member of the South
African Society of Aquatic Scientists of the Environmental Scientific Association of
the International Water Association of the Water Institute of South Africa and of the
Vaal River Catchment Association He is a certified Environmental Assessment
Practitioner with 30 years experience who specialises in project management
environmental impact assessments and water resource planning He specifically has
extensive experience in water quality especially water quality management water
quality monitoring and water quality assessment Martin has experience in managing
projects that involve multi-disciplinary teams and public consultation and
participation in South Africa and abroad
Lea September is an Environmental Assessment Practitioner with a Masters degree
in Environmental Management She has experience in impact assessment and
environmental management and has been responsible for drafting impact
assessment reports and Environmental Management Programmes and conducting
public participation processes as well as high level environmental screenings for a
variety of projects in the energy water transport and industrial sectors
Renee von Gruenewaldt has nine-years experience in the field of air pollution
impact assessment and air quality management Prior to becoming involved in air
quality consultation she was part of the Highveld Boundary Layer Wind Research
Group based at the University of Pretoria Since joining Environmental Management
Services (the company now Airshed Planning Professionals) she has undertaken
numerous air pollution impact studies and has provided extensive guidance to both
industry and government on air quality management practices
Pieter Smuts graduated as a Civil Engineer and became involved in the field of
municipal engineering and infrastructure construction He has specialized during the
last twelve years in solid waste management He has completed waste management
plans feasibility studies and final designs of waste management facilities in South
Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and
the review of the Mavoco hazardous waste landfill design in Maputo Mozambique
and completed a study on hazardous waste (textile factory sludge) management in
Maseru Lesotho
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-4
Seniel Pillay is a transportation engineer with over 16 years experience in
transportation planning and traffic engineering He has been involved in a wide
range of projects ranging from developing the Transport Operations Plan for the
FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System
for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller
traffic impact assessments for inter alia road improvement schemes Of particular
relevance to this project his experience includes Heavy Goods Vehicle Study for
eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact
Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash
Preliminary Transportation Assessment
16 STRUCTURE OF THIS REPORT
The proposed project and the alternatives considered are described in Chapter 2
Chapter 3 details the approach adopted for the EIA phase
The biophysical and socio-economic environment affected by the activity is described
in Chapter 4
The environmental impacts identified are discussed in Chapter 5
The EIA methodology is described in Chapter 6 and Chapter 7 presents the results
of the impact assessment
The environmental impact statement is presented in Chapter 8
Finally Chapter 9 spell out the conclusions and recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-1
2 DESCRIPTION OF THE PROPOSED PROJECT
21 TECHNICAL ASPECTS
211 The galvanizing process
Galvanizing consists of coating steel with zinc in order to protect it from corrosion
Before steel strips can be galvanized they undergo a pre-treatment in order to
ensure that the steel sheets are free from any surface oxides as they enter the
molten zinc coating Bath This is done by removing the oil from the steel sheets (in
the degreasing unit) and then removing the rust from the surface of the sheet (in the
pickling unit)
The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The
melting zinc on the strip surface will be cooled and solidified through air cooling in the
cooling tower
Finally the galvanised steel sheets are dipped into a water quenching tank in order to
further cool the sheets from about 150degC to 40degC
It is possible to make galvanised steel more durable by chromating it Approximately
50 of the galvanised steel production output will receive chromate passivation
treatment after quenching the galvanised steel sheets will be sprayed with a chrome
solution (3 kgcm2)
After galvanizing and chromating the steel sheets are cut to achieve the desired coil
size and weight and transported to the storage yard
The process flow diagram below (Figure 1) illustrates the main stages of the
galvanizing process and indicates the major inputs and outputs as well as the
resulting effluent and atmospheric emissions
Draft Environmenal Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-2
Figure 1 Process flow diagram for proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-3
212 Main inputs and outputs in operational phase
In view of the above the main inputs will be as follows
Steel coils 85 000 tonsyear
Zinc 870 tonsyear
Electricity 2500 kVA
Water 2000 m3month (of which 400 m3 will be potable water)
Liquid Natural Gas (LNG) 270 NM3hour
Sodium hydroxide (NaOH) 1000 m3year
Hydrochloric acid (HCl) 800 m3year
Chrome (Cr+3) 10 m3year
The main outputs will be
Galvanized steel 80 000 tonsyear
Scrap metal 20 tonsyear
General waste 65 tonsyear
Hazardous waste 2 m3month
Wastewater 012 Mlweek
Atmospheric emissions lt 5 ppm
213 Installations on site
The bulk of the operations involved in the galvanizing process occur along a
continuous galvanizing line (See Figure 2 below) which is the main piece of
machinery required for the proposed galvanising plant
Figure 2 Continuous Galvanizing Line
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-4
Water is one of the major inputs and is used throughout the galvanizing process notably
for rinsing and cooling purposes and as a mixing agent for the various chemical
solutions The plant will have a water treatment plant on site to treat the water used in
the various processes (approx 250 m3
of wastewater per week) The wastewater
treatment facility will be operated by a professional water treatment company as Casa
Steel does not have the required expertise in house to treat its process water Sulphuric
acid (H2SO4) is used as part of the treatment process to reduce caustic soda The
neutralised water is discharged to the sewer while any sludge is disposed of as
hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)
will be disposed of
Some critical areas of the galvanizing process such as the zinc pot require uninterrupted
power It is therefore proposed to install an LNG burner to maintain the zinc bath at a
temperature of between 450 and 460degC
22 LOCATION OF THE PROPOSED GALVANIZING PLANT
The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast
of Port Elizabeth in the Eastern Cape (Figure 3)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-5
Figure 3 Location of the proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-6
23 NEED AND DESIRABILITY
The profitability of the proposed project has been established by Casa Steel and a
pre-feasibility study has confirmed that the proposed project was feasible from a
technical and financial point of view The Coega IDZ is specifically designed to host
facilities such as a galvanizing plant and can provide the necessary infrastructure
and services to its investors It therefore constitutes a very suitable location for the
project
24 ALTERNATIVES IDENTIFIED
Zone 6 has been specifically earmarked for heavy ferrous metal industries and is
therefore a suitable location for the proposed galvanizing plant as such no site
alternatives have been provided for and assessed in this EIA However prior to the
commencement of the EIA process Casa Steel was presented with a number of
different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the
selection of the site were
(a) The dimensions of the land the site should be at least 200 m long and
50 m wide in order to accommodate the galvanizing line and adjacent lay
down area and additional land should be available next to the site for future
expansion
(b) The fiscal arrangements applying to the site the site should be located
within the future Custom Controlled Area (CCA) as the bulk of the
production output of the plant will be exported
The no-go alternative is assessed in this report
25 CONSTRUCTION ASPECTS
The construction phase of the project will take about 12 months and will essentially
consist of erecting a building to house the galvanizing line and other equipment and
preparing a concrete laydown area adjacent to the building
The CDC will provide an access point from the existing tarred road that will lead to
the site
Approximately 100 workers from the surrounding areas will be contracted for the
construction work
The requirements in terms of services during construction are listed below
Water 1000 m3month
Electricity 2500 kVA
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-7
The CDC will provide temporary services for the construction phase including a
conservancy tank for flush toilets Sewage infrastructure will only be provided for the
operational phase
26 OPERATION ASPECTS
Before the plant can become fully operational the equipment and machinery will be
tested for approximately 3 months The supplier will supervise these tests as part of
the transfer of know-how and training of staff on the plant
Casa Steel will start operating the plant at a reduced capacity (about 50 000
tonsyear) for a period of time (mostly determined by market aspects) before bringing
production to full capacity (80 000 tonsyear) This is done by operating the line for
longer hours
Approximately 50 to 60 people will be working on the plant Approximately 6-10 of
these will be unskilled 40-45 skilled and about 5 people in managerial positions
The requirements in terms of services during operation are as follows
Water 2000 m3month
Electricity 2500 kVA
Effluent discharge 24 m3day
The CDC has entered into agreements with the municipality to secure the provision
of services such as water and electricity to its tenants Tenants in the IDZ have their
own agreements with the NMBM for electricity while the agreements for water and
sewage are with the Facilities Unit of the CDC
Regarding discharge of wastewater to the sewer the municipality indicated that the
only requirement is that the water discharged complies with applicable municipal
discharge standards
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 3-1
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT
31 OBJECTIVES
The main objectives of the EIA phase are to
Assess the significance of the environmental issues and impacts identified in the
scoping phase focusing on key impacts
Recommend appropriate measures to mitigate negative impacts and enhance the
benefits and include them in the draft EMP
Undertake a public participation process that provides opportunities for all
interested and affected parties (IampAPs) to be involved
32 AUTHORITY CONSULTATION
The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental
Liaison Committeersquo (ELC) which comprises representatives of various authorities
including DEDEAT the Department of Environmental Affairs (DEA) and Department
of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the
Coega Development Corporation (CDC) and Transnet National Ports Authority
(TNPA) The ELC has been specifically formed to facilitate EIA applications in the
IDZ
Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to
the clearance of vegetation should be included in the application A formal request
was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the
application and all registered stakeholders were informed of the request in writing on
19 October 2011
33 PUBLIC PARTICIPATION PROCESS CONDUCTED
On-site notices were replaced by a notification displayed on the CDCrsquos digital notice
board at the business centre in Zone 1 of the IDZ The eNotice was placed on
13 April 2011 and will remain for the full duration of the EIA process
Registered stakeholders will be notified in writing of the availability of the draft EIA
report and EMP which will also be advertised in a local newspaper Stakeholders
including state departments and the public will have forty (40) days to comment on
the draft EIA report and EMP The draft EIA report and EMP will be sent by email
where possible and made available for download on the ILISO website
(wwwilisocom)
A summary of all issues and comments received during the stakeholder consultation
process as well as of correspondence in that regard will be captured in an Issues
and Responses Report that will form an Appendix to the EIA Report
The list of registered IampAPs is included in Appendix A
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 3-2
34 LEGISLATION AND GUIDELINES CONSIDERED
The following legislation and guidelines were considered in the preparation of this
report
National Environmental Management Act Act No 107 of 1998
NEMA EIA Regulations 2010
National Environmental Management Air Quality Act Act No 39 of 2004
National Environmental Management Waste Act Act No 59 of 2008
Hazardous Substances Act Act 15 of 1993
Occupational Health and Safety Act Act 85 of 1993
Hazardous Chemical Substances Regulations 1995 (GNR 1179)
Major Hazard Installation Regulations 2001 (GNR 692)
National Water Act Act 36 of 1998
National Heritage Resources Act Act 25 of 1999
DEAT Integrated Environmental Management Information Series 1-5 and 12-15
NEMA draft Implementation Guideline
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Public Participation (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Alternatives (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Draft Guideline for Determining the Scope of Specialist
Involvement in EIA Processes (2005)
IAIA guidelines
National air quality standard for thoracic particulates Government Gazette
No 32816
Listed activities and associated minimum standards identified in terms of section
21 of the National Environmental Management Air Quality Act Act No 39 of
2004 Government Notice 248 of 2009
Minimum Requirements for the Handling Classification and Disposal of
Hazardous Waste DWAF Waste Management Series (1998)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-1
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION
The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega
IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay
to the north of the N2 highway between Port Elizabeth and Grahamstown east of the
Coega River
The co-ordinates of the corners of the site are shown in Table 1
Table 1 Coordinates of site corners for the proposed galvanizing plant
Point Longitude Latitude
A 25deg411126E 33deg45587S
B 25deg411156E 33deg45499S
C 25deg411938E 33deg45131S
D 25deg412174E 33deg45481S
E 25deg412508E 33deg45979S
F 25deg412634E 33deg451160S
G 25deg411782E 33deg451560S
H 25deg411692E 33deg451428S
J 25deg411314E 33deg45868S
Figure 4 Zone layout in the Coega IDZ
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-2
Figure 5 Site location
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-3
42 SOCIO-ECONOMIC CHARACTERISTICS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the
NMBM There are no residents within the IDZ
As far as the broader NMBM and Eastern Cape Province are concerned the
following can be noted The NMBM is located within the Eastern Cape Province the
2nd largest Province in South Africa (3rd in terms of population) characterised by a
predominantly black population with low incomes and high levels of unemployment
(CES 2010)
The NMBM has a population of just above 11 million and covers an area of
1 950 km2 It is the main urban and industrial centre of the province and Port
Elizabeth in particular which forms part of the NMBM is the commercial capital of
the Eastern Cape 52 of the NMBM population is female and 37 is below the
age of 20 these two groups are particularly affected by unemployment
43 BIOPHYSICAL CHARACTERISTICS
431 Surface and ground water
No rivers occur in Zone 6 There is however a natural attenuation pond on the
southern most part of the site which will have to be avoided
The IDZ is underlain by calcrete sand and gravel deposits that overlie low
permeability clays These clays limit the vertical infiltration of rainwater and induce a
horizontal groundwater flow towards the Coega River channel which is the most
significant surface water feature in the Coega IDZ Consequently rapid run-off takes
place following precipitation (Jacobs 2008)
Groundwater levels at Coega are generally about 3 to 5 m below surface ie just
above the contact between the permeable sands and the underlying impermeable
clays The groundwater flow direction is to the southeast following the surface water
drainage direction (Jacobs 2008)
432 Climate and atmospheric conditions
Port Elizabeth has a warm temperate climate and the temperature ranges are not
extreme Exceptionally high temperatures may be experienced during berg wind
conditions which occur frequently during autumn and winter Extreme temperatures
also occur during summer with little accompanying wind
The wind regime for the area largely reflects the synoptic scale circulation with
dominant westerly and northwesterly flow fields representing the pre-frontal
conditions and south-westerly flow fields representing the frontal conditions The
south-easterly and south-westerly wind flow (land breeze) increases during daytime
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-4
conditions with westerly and north-westerly wind flow increasing during the night (sea
breeze)
The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of
Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15
km southwest) and Port Elizabeth (~23 km southwest)
An ambient air monitoring network has been established in the Coega IDZ which
consists of three monitors Saltworks Motherwell and Amsterdamplein Although
NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative
impacts due to the proposed Galvanising Plant is PM10 A maximum daily average
PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed
SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3
was exceeded on 17 days in 2007 and 26 days in 2008
Existing sources of emissions in the vicinity of the proposed galvanizing plant include
industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other
fugitive dust sources (von Gruenewaldt 2011b)
433 Geology and soils
Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel
and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly
limestone and conglomerate
434 Terrestrial ecology
This section draws from the EIA report compiled for the Agni Steel (formerly Afro-
Asia) steel processing facility which is adjacent to the proposed site for the
galvanizing plant (Jacobs 2008)
The area consists largely of grasses succulents and scrubby bush with alien
species making up the greater part of the more dense vegetation
Zone 6 falls within the inland vegetation and is characterised by a vegetation type
referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the
Coega IDZ and has been found to have three times the level of endemism of other
vegetation communities in the Coega IDZ Bontveld therefore has a high
conservation status Two Bontveld conservation areas have been identified within the
IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)
Bontveld that will be destroyed as a result of development in the IDZ will be given
conservation status in these two areas
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-5
Figure 6 Coega IDZ Open Space Management Plan (OSMP)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-6
Certain areas in the IDZ are invaded by alien plant species The most common
invader species is rooikrans (Acacia cyclops) which presently forms large
monospecific stands in areas throughout the Coega IDZ There are several other
aliens present that pose a threat to the flora of this area including the prickly pear
(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)
Loss of vegetation and alien plant invasion due to human activity has resulted in a
reduction in the diversity of terrestrial fauna
The majority of mammals present in the Coega IDZ are small or medium-sized Of
the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed
gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of
Algoa Bay however it is not considered threatened The gerbil is common in
foredune and dune thicket habitat in the Coega region and is therefore unlikely to
occur on the proposed site
A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird
species are resident or common to the area Most diversity occurs in the thicket
although the coastal area also supports specialised avifauna Two species of tern
the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well
as the Cape gannet (Morus capensis) and the African penguin (Spheniscus
demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne
caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant
(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser
flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns
are two of the most endangered coastal species in South Africa Other bird species
of conservation concern include the Whitefronted plover (Charadrius marginatus)
African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus
bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus
ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides
paradisea) Breeding pairs of Damara terns and African black oyster catchers have
been observed in the coastal dunes of the IDZ but should not be affected by
developments that fall outside the dune areas
The Eastern Cape supports nearly a third (approximately 133 species) of the reptile
species recorded in South Africa More than half of the Eastern Capersquos endemic
reptile species occur in the Algoa Bay area giving the region a high conservation
value A total of 63 reptile species are believed to occur within the Coega IDZ The
majority of these are found in Succulent Thicket and riverine habitats Only a few
reptile species occur in the coastal dunes and estuarine habitats More than a third of
the species are described as relatively tolerant of disturbed environments provided
that migration corridors of suitable habitat are maintained to link pristine habitats
Twenty two reptiles are of special concern including five endemic species (two of
which may also be endangered) four endangered sea turtles eight species listed
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-7
with CITES one rare species and four species at the periphery of their range
Fourteen of these species of special concern are confirmed as occurring on or within
2 km of the Coega IDZ
A total of 32 amphibian species and sub-species occur in the Eastern Cape
representing almost a third of the species recorded in South Africa However none of
the species are endemic or Red Data Book species Based on previous studies in the
area it is estimated that approximately 17 amphibian species occur within the Coega
IDZ Four species are listed as peripheral but none are threatened internationally
These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog
(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and
the bubbling kassina (Kassina senegalensis)
The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated
vegetation has not been extensively studied One grasshopper species Acrotylos
hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue
(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis
pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in
four localities in the Eastern Cape one of which is within the Coega IDZ The Coega
copper Aloeides clarki is endemic to this particular region of the Eastern Cape and
is currently known to occur in three localities two of which are in the Coega IDZ The
localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the
Coega IDZ and their distributions were taken into account when defining Coegarsquos
open space system and Development Framework Plan
435 Land use and topography
The land is currently undeveloped and earmarked for industrial development The
site is relatively flat ranging from an elevation of 66 masl on the northern-most
corner to 59 masl at the southern-most corner
436 Heritage and archaeological survey
Extensive studies have been undertaken in Zone 6 with respect to heritage aspects
Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a
2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond
2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is
currently being finalised
Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing
Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha
in extent and was located next to the R102 road to Motherwell Kaplan conducted
HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi
Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will
now be located in Zone 5)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-8
The various archaeological investigations reached similar observations and
conclusions Stone tools of various densities and types were found throughout the
zone The majority of the stone tools were mainly of Earlier and Middle Stone Age
and occasional Later Stone Age origins (Figure 4)
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble
gravels exposed by tracks in Zone 6 (Source Binneman 2010)
The stone tools which comprised of quartzite flakes chunks flaked pebblecobble
and cores were randomly distributed across the landscape and are in secondary
context There were no lsquoconcentrationsrsquo of tools observed which suggested any
spatial patterning or activity areas although these may be present or covered by soil
and vegetation
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 5-1
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED
The following environmental issues and potential impacts were identified in the
Scoping phase
51 AIR QUALITY
The galvanizing process generates atmospheric emissions with particulates and
hydrogen chloride representing the main pollutants of concern The plant is fitted with
air extraction as well as scrubber systems which are designed to retain the bulk of
pollutants and particles for each of the processes in such a way that less than 5 ppm
of gases and particles will be released into the atmosphere after the fume scrubber
Other sources of impact on air quality include emissions from the LNG burner as well
as emissions and dust from the transport of steel and other materials in trucks
Construction activities will also create dust and gas emissions due to the clearing of
groundcover tipping of material to storage pile levelling of area wind erosion from
storage piles vehicle and construction equipment activity and tailpipe emissions
from vehicles and construction equipment such as graders scrapers and dozers
Overall the air quality impact assessment (Gruenewaldt 2011b) found that
The predicted particulate oxides of nitrogen carbon monoxide and sulphur
dioxide concentrations are all below the National Ambient Air Quality Standards
for all averaging periods
The predicted off-site concentrations of hydrogen chloride are well below the
most stringent effect screening levels
No odour threshold exceedances for hydrogen chloride were predicted to occur
due to routine operations at the Steel Galvanising Plant The South Wales
Environmental Protection Authority stipulates that an odour unit of 20 is
acceptable for urban areas The odour unit would be lt10 directly off-site for
hydrogen chloride
Abnormal emissions can occur in exceptional circumstances Start-up will not
cause abnormal emissions as the scrubbers will be commissioned first and will be
functioning once the plant starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions would be emitted as a
building fugitive
The hourly hydrogen chloride ground level concentrations (directly offsite) were
predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based
on the emission limits as stipulated for listed activities for galvanising processes)
using a screen model which assumes worst case meteorological conditions The
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-2
health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming
abnormal emissions emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset conditions will still
be well within the health effect screening levels
Similarly the hourly particulate emissions from the building fugitives during upset
conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for
listed activities for galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly
off-site
Therefore if emissions are 5 times higher normal they will still be within health effect
screening levels and the daily PM10 NAAQS levels
In the case of a fire a cocktail of gases and particulates could be emitted and could
be over the recommended levels This situation will however be dealt with as an
emergency and normalised as quickly as is possible
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS
The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of
its heritage potential and there are no proposed protected geosites in Zone 6
Should any artefacts be discovered during construction procedures stipulated in the
draft EMP will apply
53 BIODIVERSITY AND CONSERVATION
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
In terms of terrestrial fauna the CDCrsquos open space management plan provides for
the preservation of certain corridors The destruction of certain habitats as a result of
the development will therefore not automatically result in the loss of certain species
54 WATER QUALITY
There is a natural attenuation pond on the southern most part of the site which will be
avoided
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through
spills or leaks
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-3
This risk can however be minimized if not avoided altogether The floor of the factory
will be designed as a bunded area to contain any spills and the entire process will be
contained Potential spills or leaks will therefore be contained and will not impact on
water resources Storm water is therefore considered clean water under normal
operational conditions An oil trap will be placed at the exit of the site to ensure that
no grease from the laydown area enters the stormwater system
Spills and leaks can occur during the handling or the transport of hazardous
substances Best practice guidelines will be followed to ensure that this risk is
adequately managed
Wastewater discharged to sewer will be treated to comply with municipal discharge
standards and is not expected to have an impact on the chemical characteristics of
the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be
discharged from the plant is small in relation to the total volume received at the
Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works
(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently
operated at 61 of its capacity which is approximately 80 Mℓday Thus the
0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore
not have any significant impact on the WWTW
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES
The plant will generate a relatively small amount of solid waste in the form of scrap
metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)
The scrap metal may be sold to other steel processing facilities such as Agni Steel
which will be located next to the plant or collected and disposed of with the rest of
the solid waste by a licensed service provider
As mentioned previously there will be a wastewater treatment plant on site which will
neutralise process water (012 Mlweek) in order to ensure it is of a standard
acceptable for discharge to sewer Waste in the form of sludge from the
neutralization or spent acid must be disposed of as a hazardous waste Solid waste
from the filters used for air quality control is also in this category These wastes can
usually be tested and then delisted which means that it can be placed in a general
purpose landfill
Hazardous effluent from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-
site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored
and removed on a monthly basis is limited to 10 m3
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-4
A number of substances classified as hazardous are used in the galvanizing process
(Table 2) and the transport and handling of these is subject to certain rules and
guidelines In particular the material safety data sheets (cf Appendix H) should be
referred to for inter alia hazards identification accidental release measures
handling and storage precautions exposure controlpersonal protection ecological
information and transport information The Hazardous Chemical Substances
Regulations 1995 should also be adhered to in respect of the transport and storage
of hazardous chemical substances
Table 2 Hazardous materials to be used on site
Major Input Materials
Substance
listed in the
SABS 0228
Group II
hazardous
substances
Volumes to be
stored on site at
any one time
Diesel radic 2000 litres
Liquid petroleum radic 20 000 liters
Sodium hydroxide (NaOH)
(used for degreasing) 8 radic 1000m
3
Hydrochloric acid (HCI)
(used for pickling) 8 radic 800m
3
Zinc (used for galvanising) - TBD
Trivalent chromium (CR+3
)
(used for chromating) 8 radic 10m
3
Sulphuric acid (H2SO4) (used for
treatment of waste water on site) 8 radic TBD
Ammonium Hydroxide (NH4OH) 8 radic TBD
TBD ndash To be determined
Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one
time) and is classified as a flammable substance Specification for flammable storage
facilities in accordance with the requirements of the Nelson Mandela Bay
Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for
quantities between 5000 and 20 000 liters the substance must be kept in a
flammable liquid store which complies with the requirements of a specification
obtainable from the Department Some of the requirements are
Flammable liquid and solid storage facilities are only permitted on the ground
floor
Decanting of flammable liquids and solids are not permitted within any building
Due to the fact that there are flammable materials on site a certificate may be
required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and
Emergency Services Department to confirm that facilities for flammable storage
are in accordance with their requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-5
Because of the permanent installation and high quantity of liquid petroleum on site
the Major Hazard Installation Regulations 2001 promulgated under the Occupational
Health and Safety Act No 85 of 1993 applies A written application for approval of
the installation is required to be submitted to the chief inspector Department of
Labour provincial director Department of Labour and NMBM prior to construction
In addition a risk assessment should be formulated covering all hazardous materials
together with an emergency preparedness and response plan
56 HEALTH AND SAFETY
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling instructions as well as occupational exposure limits
are indicated in the material safety data sheets of the various substances used
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as
provide site supervision including executing tests (individual test cold run and hot
run) during 3 months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the
EMP
In addition the emergency preparedness and response plan will cover the health and
safety aspects related to emergency situations
57 TRAFFIC
The volumes of traffic at the IDZ are currently relatively low and variable depending
on the different zones in the IDZ however these volumes will increase as more
developments are implemented
The construction phase of the Casa Steel development will take about 12 months
and will essentially consist of erecting a building to house the galvanizing line and
other equipment and preparing a concrete laydown area adjacent to the building
The traffic that would be generated during the construction phase can be expected to
be less than the traffic that would be generated by the Casa Steel development when
it is fully operational
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-6
In the operation phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and
from the Port of Ngqura
The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the
Casa Steel development would be off Ring Road 1 The other roads of significance
for the Casa Steel development are the N2 Neptune Road MR435 and MR450
Access to the port is given by Neptune Road Road Link NEP-03 has not yet been
built
Figure 8 Coega IDZ road network identification
(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-7
Figure 9 Coega IDZ road network
Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No
01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-8
The distribution of freight trips is fixed as the majority of trips will be made between
the Port of Ngqura and the Casa Steel site With regard to personnel trips there are
various points of origins (the surrounding residential areas) that could be used by
staff going to the Casa Steel site The distribution of personnel trips is based on
existing traffic count information and is shown in Figure 10
Figure 10 Trip distribution for freight and personnel trips
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The resultant expected Casa Steel traffic assignment is shown in Figure 11
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-9
Figure 11 Morning peak hour Casa Steel development traffic
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The traffic that is expected to be generated by the Casa Steel development is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low
and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)
Consultation has taken place with Transnet Port Authority (TPA) to establish the
impact of the galvanizing plant operations on traffic inside the port The additional
ships entering and exiting the port of Ngqura as a result of the proposed development
will have a negligible impact on port traffic and TPA indicated that it would be well
within the portrsquos capacity
58 NOISE
Noise is not foreseen to be a significant issue insofar as the noise levels inside the
plant and at the boundary of the site will not exceed the limits prescribed by the CDC
Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels
during the day and 60 decibels at night
Mitigation of noise impacts will be addressed in the design of the noise-emitting
components of the plant and their enclosures
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-10
59 SOCIO-ECONOMIC ASPECTS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of
NMBM There are no residents within the IDZ
The direct socio-economic impacts of the proposed project are thus limited to the
employment generated by the project during construction and operation Job creation
remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)
and the IDZ and Port of Ngqura are expected to become a significant catalyst to the
economic growth of the Municipality and the region with current investments at
Coega creating more jobs and stimulating the economy
In this context the proposed galvanizing plant will make a positive contribution
towards the achievement of these goals
There will be 50 to 60 employees during operation phase distributed as follows
Figure 12 Casa Steel organisation chart
Even though a large part of the inputs will be imported and the bulk of the production
output will be exported there will be some positive impacts for the economy of the
region and of South Africa in general Notably the requirements of the plant for
water electricity waste collection and disposal waste water treatment and transport
for example will create business for the various service providers and have an
indirect impact on employment and fiscal revenues as a result
From a visual impact point of view it can be anticipated that the landscape in the IDZ
will be significantly affected over time by developments related to the establishment
of the port and various industries
HEAD ( WORKS )
MGR ( COMM) MGR ( ADMNHR ) Manager marketing
MANAGER OPERATION MANAGER MANAGER MANAGER Q C
AC FIN PUR ampSTORE
PPC SH-GALV SH-tech
SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF
1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO
JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF
2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO
WORKERS WORKERS 7NOS
15 7
RAW MAT amp
DESP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 6-1
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
A description of the nature of the impact any specific legal requirements and the
stage (constructiondecommissioning or operation) will be given Impacts are
considered to be the same during construction and decommissioning The
significance of the potential impacts will be considered before and after identified
mitigation is implemented
The following criteria will be used to evaluate significance
Nature The nature of the impact will be classified as positive or negative and
direct or indirect
Extent and location Magnitude of the impact and is classified as
Local the impacted area is only at the site ndash the actual extent of the activity
Regional the impacted area extends to the surrounding immediate and
neighbouring properties
National the impact can be considered to be of national importance
Duration This measures the lifetime of the impact and is classified as
o Short term the impact will be for 0 ndash 3 years or only last for the period of
construction
o Medium term three to ten years
o Long term longer than 10 years or the impact will continue for the entire
operational lifetime of the project
o Permanent this applies to the impact that will remain after the operational
lifetime of the project
Intensity This is the degree to which the project affects or changes the
environment and is classified as
o Low the change is slight and often not noticeable and the natural functioning
of the environment is not affected
o Medium The environment is remarkably altered but still functions in a
modified way
o High Functioning of the affected environment is disturbed and can cease
Probability This is the likelihood or the chances that the impact will occur and
is classified as
o Low during the normal operation of the project no impacts are expected
o Medium the impact is likely to occur if extra care is not taken to mitigate
them
o High the environment will be affected irrespectively in some cases such
impact can be reduced
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 6-2
Confidence This is the level knowledgeinformation the environmental impact
practitioner or a specialist had in hisher judgement and is rated as
o Low the judgement is based on intuition and not on knowledge or
information
o Medium common sense and general knowledge informs the decision
o High Scientific and or proven information has been used to give such a
judgment
Significance Based on the above criteria the significance of issues will be
determined This is the importance of the impact in terms of physical extent and
time scale and is rated as
o Low the impacts are less important
o Medium the impacts are important and require attention mitigation is
required to reduce the negative impacts
o High the impacts are of great importance Mitigation is therefore crucial
Cumulative Impacts The possible cumulative impacts will also be considered
Mitigation Mitigation for significant issues is incorporated into the EMP for
construction
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 7-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS
71 IMPACTS DURING CONSTRUCTION
711 Air quality
Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris
handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine
particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural
operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks
and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)
Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Fugitive particulate emissions (dust)
related to construction activities Regional
Short
term Medium High High Medium Regional
Short
term Low High High Low
Construction vehicle gas emissions Regional Short
term Medium High High Medium Regional
Short
term Low High High Low
712 Heritage and archaeological resources
Naturedescription of impact excavation activities may impact on unidentified heritage resources
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-2
Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based
on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments
Heritage and archaeological
resources Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on unidentified heritage
resources Local
Short
term
Medium -
high Low High Low
713 Biodiversity and conservation
Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation
importance and cause soil contamination
Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species
Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan
and has compiled a list of protected species to be rescued (see draft EMP)
Biodiversity and conservation Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Loss of fauna and flora Local Perma
nent
Medium -
high High High High Local
Permanen
t Medium High High Medium
Soil contamination Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-3
714 Water related impacts
Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater
runoff spills and leaks Soil erosion
Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of
spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste
disposal Stormwater quality monitoring (see draft EMP)
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Soil erosion Local Short
term Medium Medium High Medium Local
Short
term Medium Low High Low
715 Waste management
Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed
Commentmitigation see draft EMP and waste management plan
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-4
Waste management Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Local
Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
716 Health and safety
Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Short
term
Medium -
high
Medium -
high High High Local
Short
term
Medium -
high Low High Low
717 Traffic
Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and
construction workers from surrounding areas and transport of equipment from the port
Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low
Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and
accurate estimates of quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-5
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Increased traffic on N2 and within the
IDZ Regional
Short
term Low High High Low
718 Noise
Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Short
term
Medium-
high High High Medium Local
Short
term Medium High High Medium
719 Socio-economic
Naturedescription of impact temporary employment will be created during the construction phase
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-6
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Temporary employment Regional Short
term Medium High High Medium
72 IMPACTS DURING OPERATION
721 Air quality
NatureDescription of impact gas and particulate emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning
Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local
sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and
veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute
to background fine particulate concentrations (von Gruenewaldt 2011b)
Assumptions and limitations Potential release of CR6+
As no emission factors are available for trivalent chromium processing the
potential impacts due to these activities could not be quantified
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Dust emitted from traffic on paved roads Regional Long Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-7
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
term
Hydrogen chloride emissions from
pickling process Local
Long
term Low High High Low
Particulate emissions (smoke) from
galvanizing process (due to the
volatilization of flux)
Local Long
term Low High High Low
Particulate oxides of nitrogen carbon
monoxide and sulphur dioxide emissions
from LNG burner
Local Long
term Low High High Low
Nuisance related to odour Local Long
term Low Low High Low
Abnormally high hydrogen chloride and
particulate emissions due to scrubber
malfunction
Local Short
term Medium Low High Medium
Gases (eg SOx NOx CO etc) and
smoke emitted in case of a fire Local
Short
term High Low High Medium
722 Water quality
NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks
Commentmitigation see draft EMP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-8
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Stormwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
723 Waste management and hazardous substances
NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous
waste both can affect environmental quality and human health
Commentmitigation see draft EMP and waste management plan
Waste management and hazardous
substances Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Regional
Long
term High
Medium -
high High High Regional Long term High Low High Low
Soilwaterair pollution due to improper
transport storage and handling of
hazardous substances
Regional Long
term High
Medium -
high High High Regional Long term High Low High Low
Health hazard Local Long
term High
Medium -
high High High Local Long term High Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-9
724 Health and safety
Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Long
term
Medium-
high
Medium-
high High High Local Long term
Medium-
high Low High Low
725 Traffic
Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on
the road network
Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak
hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road
network within Zone 6 of the IDZ (Iliso 2011)
Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)
Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of
quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-10
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on traffic and capacity of the N2 Regional Long
term Low High High Low
Impact on traffic and capacity of ring
road 1 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR435 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR450 Local
Long
term Low High High Low
Impact on traffic and capacity of
Neptune road Local
Long
term Low High High Low
726 Noise
Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Long
term Medium High High Medium Local Long term Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-11
727 Socio-economic
Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate
revenue for the municipality and the region as a whole
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Employment and economic growth Regional Short
term Medium High High Medium
73 COMPARATIVE ASSESSMENT OF IMPACTS
During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as
low during operation after mitigation
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 8-1
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
As a tenant operating in the IDZ Casa Steel will be required to comply with all
current and future CDC requirements as well as with the relevant conditions of
permits licences issued to CDC (eg Integrated Stormwater Masterplan for the
eastern side of the Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)
In particular the CDC has its own requirements regarding the monitoring of certain
aspects of the project such as the quality of the effluent and the noise levels These
have been incorporated into the EMP
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 9-1
9 ENVIRONMENTAL IMPACT STATEMENT
All predicted negative impacts can be mitigated to a low significance The only
exceptions are biodiversity as the construction of the plant will result in the
destruction of habitat and loss of fauna and flora and noise impacts inherent to
construction activities Mitigation measures have been included in the EMP for these
impacts and they have a medium significance post-mitigation
Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium to
long term similar impacts are likely to occur due to ongoing developments in the IDZ
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 10-1
10 CONCLUSION AND RECOMMENDATIONS
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as
other infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified
and assessed No fatal flaws have been identified
It is recommended that the project be approved subject to the conditions listed in
chapter 9 and adherence to the EMP requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 11-1
11 REFERENCES
Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ
Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants
Bennie JS (2010) The historical component (built environment) of the Heritage
Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port
Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report
compiled for Eastern Cape Heritage Consultants
Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater
Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay
Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage
Consultants
BKS (2006) Coega Industrial Development Zone Transport Study Volume 3
Demand Modelling Report Final Draft
Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I
Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6
Report compiled for SRK Consulting
Coastal amp Environmental Services (2010) Environmental Impact Assessment for the
Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone
Volume 3 Environmental Impact Assessment Report CES Grahamstown
Coega Development Corporation (2008) Industry Waste Management Plan -
Strategic Master Plan Report
Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants
Report No CDCSHE 03 8122
Department of Water Affairs and Forestry (1998) Waste Management Series
ldquoMinimum Requirements For The Handling Classification And Disposal Of
Hazardous Wasterdquo Second Edition
Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising
Plant in the Coega Industrial Development Zone
Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the
Coega Industrial Development Zone (IDZ) Specialist Water Study
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 11-2
Jacobs E (2008) Final Environmental Impact Report and Draft Environmental
Management Plan Proposed Steel Recycling and Processing Facility within the
Coega IDZ Report compiled for SRK Consulting
Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY
Galvanising Plant in the Coega Industrial Development Zone Waste Management
and Hazardous Substances Report compiled for ILISO Consulting
RSA National air quality standard for thoracic particulates (PM10) SA standards
(Government Gazette No 32816)
von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed
Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape
Report compiled for ILISO Consulting
von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel
Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report
compiled for ILISO Consulting
Additional sources
Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed
Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared
for Coastal Environmental Services
Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed
Kalagadi Manganese smelter in the Coega Industrial Development Zone Port
Elizabeth Eastern Cape Province Report prepared for Coastal Environmental
Services
Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia
steel recycling facility at the Coega Industrial Development Area Port Elizabeth
Prepared for SRK Consulting Port Elizabeth
APPENDIX A
LIST OF INTERESTED AND
AFFECTED PARTIES
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
DEDEARegional Manager
and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza
DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza
DEA Ocean and
CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza
DEA Ocean and
Coast
Oceanographer land-
based sources of
marine pollution
Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza
DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza
CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza
CDCEnvironmental
Project
Manager
Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza
TNPAPort of Ngqura
Environmental
Manager
Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet
NMBMEnvironmental
ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza
NMBMEnvironmental
ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza
DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza
DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza
WESSASenior Conservation
Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza
Zwartkops
ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700
hughlauegmailcom
zwartkopstrustiafricacom
SANParksNational Marine
CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza
Department Of
LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza
NMBM Air Quality
Division
Assistant
DirectorAir
Pollution and Noise
Templeton Titima 079 490 0574 Ttitimamandelametrogovza
NMBM Air Quality
DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza
NUMSARegional
RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
Department of
HealthNadiema
van der
Bergh083 378 2103
nadiemavanderberghimpiloecprovgov
za
DWA Chief Services
Officer
Joseph Jacobs 041 586 4884 jjacobsdwafgovza
EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza
NUMSecretary of union
officesZandile Xhentsa 043 743 6597 zxhentsanumorgza
DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza
Dynamic
CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom
EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza
Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza
UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom
lprincezago2uticom
Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza
Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza
Absa Mr Johann Steyn 082 3775820 johannstabsacoza
Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza
PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza
Universal
EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza
Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza
GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom
Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza
NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom
DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza
DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza
TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet
DWA Mr Landile Jack JackLdwagovza
DWA Ms Lizna Fourie FourieL4dwagovza
APPENDIX B
NOTICE OF ATMOSPHERIC
EMISSIONS LICENCE APPLICATION
AND ADVERTISEMENT
APPENDIX C
NOTICE OF COMMENT PERIOD FOR
DRAFT SCOPING REPORT
APPENDIX D
SUMMARY OF ISSUES RAISED AND
RESPONSES THERETO
April 2012
1
PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL
DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))
IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt
AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt
This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses
provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process
conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the
Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
2
IssueCommentQuestion Date
received Origin Response
1 Please provide more information with respect to the potential
dangers including the toxicity of the proposed project
07032011
By email
Wayne Poulton
(Bosun Brick
tenant at the
IDZ)
An Environmental Impact Assessment (EIA) was undertaken
which assessed the potential toxicity of the emissions and
effluent Mitigation measures were also recommended in the draft
Environmental Management Programme (EMP) to avoid
minimise or compensate any significant impacts The Draft
Environmental Impact Report and draft EMP were made available
to stakeholders for comment in March 2012
2 Do you have a Background Information Document (BID) or
similar that provides more information on the project
27032011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The BID was sent to all registered IampAPs on 4 May 2011
3 The RoD issued to the CDC on 632007 for the change in
land use for the remaining area of the Coega IDZ includes a
number of requirements with respect to
atmospheric emissions that should be considered in the
Atmospheric Emissions Licence (AEL) application such as
prohibiting and monitoring where possible visible emission
plumes to the atmosphere In particular the
recommendations on pp87-91 of the final revised Scoping
Report dated Nov 2006 must be implemented (clause 421)
04042011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
We have obtained copies of the documents referred to and ensure
that these requirements were taken into account in the
environmental assessment and AEL application
4 If the Port of Ngqura is used for import and export the scope
of the traffic impact assessment (TIA) should also include the
port
10052011
By email
Elliot
Motsoahole
(TNPA Port of
Ngqura)
The scope of the TIA was extended to include port related traffic
The TNPA at the Port of Ngqura was consulted and does not
have any objection to the project TNPA has indicated that the
development would require a minimum number of vessels per
year which would have minimal impact on the Port operations
However due notice would have to be given to the Port of Ngqura
before a vessel is scheduled to arrive so that the vessel can be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
3
IssueCommentQuestion Date
received Origin Response
accommodated at an available berth
5 Concerns with respect to potential stormwater pollution
draining into the Coega catchment and the port of Ngqura
The port needs to be dredged and heavy metals present a
risk in that regard
16052011
By
telephone
Andrew Lucas
(Department of
Water Affairs)
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination by effluent waste or
hazardousdangerous substances is very low
Thus no metals oils or other contaminants are expected to be
present in the stormwater
However stormwater pollution can occur in exceptional
circumstances such as accidents and emergencies The
emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
6 All steel sheets bathing unit must be under roof
7 The sludge out of the decreasing bath will be high in Na and
pH Therefore handling and disposal must be clarified up front
in this project
8 Per se the wastewater from decreasing bath will have high
ph and the component from the pickling unit will have low ph
Then it may be assumed that both streams will neutralize
each other Please then clarify proposed sewer discharge
with Nelson Mandela Bay Municipality up-front for acceptance
of influent as per the documented proposal
9 Pickling may result in dissolved metals How does your team
expect to deal with this As it is planned for discharge into
24052011
By email
Landile Jack
(Department of
Water Affairs)
All bathing units will be under roof
Effluent from the degreasing and pickling baths will be discharged
to the wastewater treatment plant The respectively alkaline and
acidic effluents will mix and neutralise each other in the
wastewater treatment plant Calcium or gypsum will be added if
required to complete the neutralisation process Effluent from the
treatment plant will be discharged to sewer Contact has been
made with the relevant officials and the Municipalityrsquos
requirements have been obtained The effluent discharged to
sewer will notably comply with the applicable discharge standards
Traces of metals (eg iron) may be present but will not exceed
prescribed thresholds The necessary authorisation will be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
4
IssueCommentQuestion Date
received Origin Response
sewer Clarity and acceptance needs to be agreed with
Nelson Mandela Bay Municipality Who owns the sewer
10 Quenching unit will results to Zinc particles How will this
affect sewer discharge This again must be dealt with within
the negotiations with the Municipality
11 Once all has been agreed with the Municipality and at the
same time due negotiations must be done with hazardous
waste courier and disposal facility to accept the hazardous
waste identified in all production lines
12 Of note is the low volume of the proposed WWTW facility ie
250 cubmweek And the no discharge of the quenching
water ie over-flow and cooling only Hence Zinc particles
generation
obtained from the municipality
The sludge from the treatment plant will be collected by a licensed
service provider and disposed of at a permitted site
The quenching bath will be periodically emptied (every 6 months)
and the water discharged will go to the water treatment plant Zinc
particles will settle in the sludge which will be disposed of at a
permitted site
Contact has been made with EnviroServ who manages the
Aloes II HH waste site regarding collection and disposal of
hazardous waste (See waste management report)
13 Investigate the potential effects of toxicity andor influence of
emissions waste and hazardous substances both in
terrestrial and marine fauna
14 With regards to water usage where is the plant going to
extract its waters used in galvanization andor waste
management process ie rainfall rivers or even from the
sea) and which avenues would be more environmental
friendly and effective
31052011
By email
A Bewana
(SANPARKS)
Emissions waste and hazardous substances are not expected to
affect terrestrial or marine ecosystems The air quality study
concluded that atmospheric emissions would not be harmful to
human health and by extension terrestrial fauna There are no
standards for air quality for defining faunal impacts therefore by
ensuring that standards for humans are complied with the impact
on fauna is deemed to be acceptable In this case the impact of
emissions on terrestrial and marine fauna are thus not significant
Solid and liquid wastes both general and hazardous as well as
hazardous substances will be stored handled and disposed of
appropriately to as not to cause harm to terrestrial or marine
fauna
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
5
IssueCommentQuestion Date
received Origin Response
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination and hence land-based
marine pollution by effluent waste or hazardousdangerous
substances is very low
The risk of emissions waste and hazardous substances to
terrestrial and marine fauna is thus very low
However pollution of terrestrial and marine ecosystems can occur
in exceptional circumstances such as accidents and emergencies
The emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
The CDC has an agreement with the NMBM to supply potable
water to the Coega IDZ Currently the infrastructure to supply
return effluent (RE) to the IDZ is not in place therefore Casa Steel
will be supplied with potable water up until such time as the
following 2 options of RE are available
1) Upgrading of the existing Fishwater Flats waste water
treatment works (between IDZ amp PE) including RE plant
and infrastructure to pipe RE to the IDZ (EIA for the
upgrade is underway)
2) Construction of a new waste water treatment works
including RE plant in Zone 9 of the Coega IDZ
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option should be investigated further between Agni and Casa The
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
6
IssueCommentQuestion Date
received Origin Response
CDC can facilitate discussions between the 2 investors
Compliance with CDC Permits amp Requirements
15 It should be made clear that tenants will be required to
comply with CDC requirements and the relevant conditions of
permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water
Licence for its Storm Water Systems on the
East Side of the Coega River that tenants will
need to take cognizance of The contents of the
ldquoIntegrated Stormwater Masterplan for the
eastern side of the Coega IDZ Oct 2010rdquo
especially the Table of best practice p53
onwards may need to be taken cognizance of
o CDC is developing an Operations
Environmental Management Plan that will place
certain obligations on tenants
16 Environmental audits and data collected during monitoring
(eg stack emissions stormwater) will need to be shared with
CDC
Air Emissions
17 Presumably permanent in stack monitoring will be required in
terms of AEL permit requirements
18 Abnormal operating conditions resulting in air emissions ndash I
could find nothing in the EIR to indicate under what
circumstances these could occur (eg start-up) potential
frequency and duration and the impact on ambient air quality
ndash these events usually result in the most problems wrt air
emissions
09042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
15 Compliance with the CDCrsquos Permits amp Requirements has
been included explicitly as a requirement in the EIR (p8-1) and
EMP (pp18 and 25) in the following terms
ldquoAs a tenant operating in the IDZ Casa Steel will be required to
comply with all current and future CDC requirements as well as
with the relevant conditions of permits licences issued to CDC
(eg Integrated Stormwater Masterplan for the eastern side of the
Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)rdquo
16 The need to communicate with the CDC on monitoring and
auditing activities was emphasised in Chapter 8 of the EMP The
following paragraphs were added
ldquoDuring construction the environmental officer will be responsible
for monitoring compliance with the EMP and authorisation
conditions and keeping records as required in the EMP andor
authorisation conditions
The ECO will conduct site inspections every two weeks audit the
records kept by the environmental officer and submit an
environmental compliance report every two months to the
authorities and the CDC (via the Environmental Monitoring
Committeersquos ECO)
During operation the health and safety officer will monitor
compliance with the EMP and the conditions of the Environmental
Authorisation Data collected during monitoring activities and any
environmental audits conducted will be shared with authorities
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
7
IssueCommentQuestion Date
received Origin Response
Water
19 Large volumes of (2000 m3mth) of water are required of
which only 400m3 needs to be potable The NMBM return
effluent system will provide non-potable water once it is
constructed What other water recycling initiatives can be
utilized to reduce potable water requirements (the ISWMP for
the eastern side of the Coega IDZ has some best practice
guidelines collecting rainwater from the roof etc)
General
20 There is no mention of how the CDC Architectural Guidelines
will be incorporated into the development (eg to prevent a
stark uniform warehouse type development)
21 Does NMBM have adequate fire services to cover this
development Apart from the large petroleum store are there
any other large fire hazards
22 Reports from the tenantrsquos ECO during construction and from
the SHE Officer during operations should be channeled to the
Coega Environmental Monitoring Committee This can be
directly or preferably via the EMCrsquos ECO (this will be while
the EMC and ECO are in place) A precedent has been set
for this in the Environmental Authorisations for Agni-Steel and
Kalagadi Manganese Smelter
23 All mitigation actions emanating from the EIR should be
summarized (preferably in a table) If compliance with them is
to be part of the Environmental Authorization from DEDEAT
then they (or the ones that DEDEAT deems to be applicable)
and the CDC (via the Environmental Monitoring Committeersquos
ECO)
The ECO (during construction) and the health and safety officer
(during operation) will report to the Coega Environmental
Monitoring Committee (EMC) via the EMCrsquos ECO (this will be
while the EMC and ECO are in place)rdquo
17 The draft EMP recommends regular monitoring of emissions
from the scrubbers and from the chromating process Additional
emissions monitoring requirements will be confirmed once the
AEL is issued Mention has been made in the EMP (pp11 and 19)
that all AEL conditions including monitoring and reporting
requirements should be adhered to
18 Abnormal emissions can occur in exceptional circumstances
Start-up will not cause abnormal emissions as the scrubbers
will be commissioned first and will be functioning once the plant
starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions
would be emitted as a building fugitive
The hourly hydrogen chloride ground level concentrations
(directly offsite) were predicted to be 239 microgmsup3 (based on the
emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits
as stipulated for listed activities for galvanising processes) using a
screen model which assumes worst case meteorological
conditions The health effect screening level for hourly HCl
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
8
IssueCommentQuestion Date
received Origin Response
should be attached to the EA as an Appendix (otherwise no
one knows about them or takes cognizance of them)
concentrations is 2100 microgmsup3 Assuming abnormal emissions
emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset
conditions will still be well within the health effect screening
levels
Similarly the hourly particulate emissions from the building
fugitives during upset conditions would amount to 293 microgmsup3
(based on the emission limits as stipulated for listed activities for
galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1
January 2015) directly off-site
Therefore if emissions are 5 times higher normal they will still be
within health effect screening levels and the daily PM10 NAAQS
levels
In the case of a fire a cocktail of gases and particulates could be
emitted and could be over the recommended levels This
situation will however be dealt with as an emergency and
normalised as quickly as is possible
The above has been added to the impact identificationdescription
and assessment sections of the EIR
19 The CDC has an agreement with the NMBM to supply
potable water to the Coega IDZ Currently the infrastructure to
supply return effluent to the IDZ is not in place therefore Casa
Steel will be supplied with potable water up until such time as the
infrastructure is in place
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
9
IssueCommentQuestion Date
received Origin Response
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option will be investigated further between Agni and Casa The
CDC has come forward to facilitate discussions between the two
investors
Other water recycling initiatives such as rainwater harvesting
have been considered but are not practical
20 The CDCrsquos Architectural and Landscape Design guidelines
contain requirements pertaining to such aspects as the height
orientation and mass and form of buildings as well as guidelines
for landscaping and signage in order to ensure an attractive
development and achieve an architectural integrity within the
Coega IDZ The plans for the proposed galvanizing plant will be
submitted to the Design Review Committee for approval as
required by the CDC
21 Casa Steel will be required to install fire hydrants according
to the NMBMrsquos standardsrequirements The CDC will provide
potable water (up until such time as return effluent is available)
and a connection to the boundary of the site which will be
connected to the fire hydrants The installation of the fire hydrants
will require approval by the Metrorsquos Fire Chief as was done for
Agni-Steel one of the investors in Zone 6
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
10
IssueCommentQuestion Date
received Origin Response
The Coega IDZ falls within the NMBM and therefore the rates and
taxes paid by the CDC covers the fire services for which the Metro
is responsible Currently the Metro has sufficient capacity to
provide fire services to the tenants within the IDZ This was
confirmed in discussion with the CDCrsquos Infrastructure
Development Unit It is however unknown at which point the
Metrorsquos Disaster Management Plan would not be able to
accommodate servicing tenants in the IDZ
The LNG burner is the only major fire hazard on the plant
22 See response to item 16 above
23 Key mitigation and management measures emanating from
the EIR were recapitulated in Chapter 9 of the EIR to form part of
the conditions attached to the Environmental Authorization from
DEDEAT All mitigation measures recommended as a result of the
impact assessment are presented in a table in the draft EMP
which is appended to the EIR (Appendix J)
24 Hydrogen chloride is one of the main emissions There are no
ambient air quality guidelines for HCl and the EIR says
concentrations will be well within health parameters
However the main problem with HCl is its corrosive effect -
there is absolutely no mention of this in the draft EIR nor air
specialist report
There needs to be some sort of comment assessment as to
whether HCl emissions are likely to impact on for example
the adjacent Agni-Steel Plant wrt corrosion - their factory
structure will be made of steel
11042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The atmospheric corrosion of metals is a complex process with
both the extent of deterioration and the mechanisms varying
considerably depending on the metal Depending on the way
pollutants are transported from the atmosphere to the corroding
surface two types of deposition processes are recognized in
atmospheric corrosion ndash dry deposition and wet deposition Wet
deposition refers to precipitation whereas dry deposition refers to
the remaining processes including gas phase deposition and
particle deposition The most important pollutants acting as
corrosive agents are sulphur and nitrogen compounds including
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
11
IssueCommentQuestion Date
received Origin Response
The EIR specialist rpt suggests monitoring HCl at ground
level on the property boundary and this is supported in case
there are complaints from neighbours
secondary pollutants and particulates Pollutants can contribute to
corrosivity individually however there may be a synergistic effect
when more than one of these pollutants is present in the
environment being affected In the field of atmospheric corrosion
sulphur dioxide is the single most investigated gaseous pollutant
and the quantification of the direct contribution of sulphur dioxide
to the corrosion process of metallic materials is comparatively well
understood (Tidblad amp Kucera 1998)
Very little work has reported on the effect of HCl on the
degradation of materials in the environment with no local dose-
response thresholds developed for corrosion occurring due to HCl
exposures This is probably because HCl which is present
outdoors in markedly reduced concentrations when compared
with SO2 has not been considered to contribute to significant
degradation of materials (Syed 2006) For this reason the
incremental corrosion due to HCl from the Coega Galvanising
Plant cannot be quantified
25 It is unacceptable for ILISO to be using CDC maps (see
figure 9 ndash pg5-6) without these maps being referenced
accordingly particularly when it appears that a CDC map has
been used and then overlaid with features by an unknown
author (ie CASA steel site Port (where the boundaries
depicted are incorrect) and a North legend which is out of
keeping with the overall cartographic intent of the original
work
26 Figure 10 is not referenced appropriately and I believe that I
commented previously in respect to references to roads not
12042012
By email
Graham Taylor
(Spatial
Development
Manager -
Infrastructure
Development
CDC)
This has been rectified in the final version of the report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
12
IssueCommentQuestion Date
received Origin Response
yet built As a result Figure 10 is confusing and clarity needs
to be provided in terms of referencing In addition the Port
shape is irregular and similar to the comment above
27 I acknowledge the emergency preparedness and response
plan but please confirm that this includes pro-active routine
monitoring of storm water leaving your premises to verify that
your assumptions of clean storm water are correct
13042012
By post
Andrew Lucas
(Director
WRampU
Department of
Water Affairs)
Pro-active routine monitoring of stormwater leaving the premises
will be undertaken This has been explicitly emphasised in
chapter 8 of the draft EMP
28 Will portablechemical toilets be used during construction
29 What provisions have been made for storm water drainage
during construction
18042012
By
telephone
Department of
Water Affairs
Port Elizabeth
Chemical toilets will be used during construction
The Casa Steel site will be located at the corner of two roads
drainage of stormwater from the site will take place through the
roadsrsquo drainage system
From Lea September [mailtoleailisocom]
Sent 11 March 2011 0935 AM
To Wayne Poulton
Cc Terry Baker
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Wayne
An Environmental Impact Assessment (EIA) will be undertaken for this project during the
next 10 to 12 months
We foresee that some of the key environmental impacts of the project will be in terms of air
quality water quality waste and hazardous substances
At this stage I am not able to give you any details regarding the potential toxicity of the
emissions andor effluent However specialist studies will be conducted as part of the EIA
that will determine the key impacts of the project Mitigation measures will also be identified
to avoid minimise or compensate any significant impacts
You are registered on the stakeholder database and you will be kept informed of progress in
the EIA process you will notably get the opportunity to access the reports produced and
provide any feedback on them
Please feel free to contact me should you need any further information
Best regards
Lea September
From Wayne Poulton [mailtowaynepbosuncoza]
Sent 07 March 2011 1257 PM
To Lea September
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
Please can you provide me with some more information as to the potential dangers including
the toxicity of this
Kind regards
Wayne
From Lea September [mailtoleailisocom]
Sent 04 March 2011 1123
To Lea September
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 March 2011 0745 AM
To Paul Martin
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 05 April 2011 0847 AM
To Paul Martin
Cc Terry Baker Renee von Gruenewaldt
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Thank you Paul for this information
I have downloaded a copy of the RoD and Scoping report you referred to and will make sure
these requirements are taken into account in the environmental assessment
Best regards
Lea September
From Paul Martin [mailtopmartinaxxesscoza]
Sent 04 April 2011 0955 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Further to my comments on 27311
Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in
the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega
IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised
scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions
including prohibiting and monitoring where possible visible emission plumes to the atmosphere
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Paul Martin
Sent Monday March 28 2011 745 AM
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 10 May 2011 0327 PM
To ElliotMotsoaholetransnetnet
Cc Terry Baker
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Mr Motsoahole
Thank you for your input on this issue
The Port of Ngqura will indeed be used for import and export At the moment the scope of
the traffic impact assessment only covers road traffic I have however relayed the matter to
our traffic specialist and we will consider this issue in the finalization of the Scoping Report I
will keep you informed of any developments in that regard
I trust this is acceptable to you
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]
Sent 10 May 2011 0855 AM
To Lea September
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
It has been noted that Casa Steel will source steel coils from various markets internationally and
in South Africa and the bulk of the plantrsquos production output will be exported to African countries
However there is no mention of logistic requirements
Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will
be used the scope of traffic impact assessment should also include the port
Regards
From Lea September [mailtoleailisocom]
Sent 04 May 2011 0747 AM
To Lea September
Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
Please find attached a letter announcing the EIA process underway for the proposed 80 000
tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as
a Background Information Document (BID) outlining the details of the project
Please contact me should you require any further information on this project
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
Elliot Motsoahole
Manager - Environment
Transnet National Ports Authority
Port of Nqqura
Port Control Building Klub Road Port Elizabeth 6212
PO Box 612054 Bluewater Bay 6212
+27 41 507 8450
+27 86 674 7729
Cell +27 83 542 5619
E-mail Elliotmotsoaholetransnetnet
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
DISCLAIMER The information contained in this communication is subject to copyright and
intended only for the use of leailisocom Unauthorised use disclosure or copying is
strictly prohibited Should a virus infection occur as a result of this communication the sender
will not be liable If you have received this communication in error please notify
elliotmotsoaholetransnetnet
From Lea September [mailtoleailisocom]
Sent 25 May 2011 1147 AM
To Jack Landile (ELS)
Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi
Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Landile
Thank you for your input
Contact has been made with the relevant Municipal Directorate and we will follow up with
them to obtain clarifications on all these issues
I have added both Lizna and yourself on the database and will keep you updated on
progress on this project
Best regards
Lea September
From Jack Landile (ELS) [mailtoJackLdwagovza]
Sent 24 May 2011 0524 PM
To Fourie Lizna (ELS)
Cc Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Hi Lizna
I missed you on this sorry
I linked Pieter twice Instead
Regards
Landile
From Jack Landile (ELS)
Sent 24 May 2011 0445 PM
To leailisocom
Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Lea
The e-mail you sent to Mr Kooverji dated 19 May 2011 refer
Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are
All steel sheets bathing unit must be under roof
The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project
Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal
Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer
Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality
Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines
Of note is the low volume of the proposed WWTW facility ie 250 cubmweek
And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles
generation
Regards
Landile
From Lea September [mailtoleailisocom]
Sent 19 May 2011 0947 AM
To Lea September
Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Stakeholder
Please find attached the remaining appendices to the draft Scoping report for the proposed
80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 June 2011 0411 PM
To Aphiwe Bewana
Subject RE Proposed 80 000 TPY Galvanizing plant in Coega
Dear Mr Bewana
Thank you for your input and apologies for the late reply
We have taken note of your comments and are will be taking them forward in the EIA phase
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Aphiwe Bewana [mailtoaphiwebewanagmailcom]
Sent 31 May 2011 1205 PM
To Lea September
Subject Re Proposed 80 000 TPY Galvanizing plant in Coega
Comment
Re Proposed 80 000 TPY Galvanizing plant in Coega
As SANParks we would like the EIA phase to investigate the potential effects of toxicity
andor influence of emissions waste and hazardous substances both in terrestrial and
marine fauna In the draft scoping report reference has been made with regards to the
terrestrial fauna but there is no attention to potential effects to marine fauna
Equally with regards to water usage where is the plant going to extract its waters used in
galvanization andor waste management process ie rainfall rivers or even from the sea)
and which avenues would be more environmental friendly and effective
Regards
Aphiwe Bewana
Marine Planner
South African National Parks
POBox 76693
NMMU
Port Elizabeth
6031
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 06 July 2011 1031 AM
To Lea September
Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Hi Lea
Irsquove reviewed the Final Scoping Report Herewith a few comments
1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the
Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a
revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the
NMBLP Please include only those in the IDZ as part of your IAP list
Regards
Andrea
From Lea September [mailtoleailisocom]
Sent Wednesday July 06 2011 859 AM
To Lea Septemberrsquo
Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Dear Stakeholder
The final scoping report for the above-mentioned project (attached) is available for comment
until 27 July 2011
The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic
commentaryrdquo tab
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 09 April 2012 1159 AM
To Lea September
Subject Comments on Galvanising Plant EIR Coega IDZ
Lea
Attached are my comments on the Draft EIR for the Coega IDZ galvanising
plant
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
Email attachment
COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ
Dr Paul Martin PO Box 61029
Bluewater Bay 6212 Tel 041 4665698
Email pmartinaxxesscoza
Compliance with CDC Permits amp Requirements
It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of
o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants
Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC
Air Emissions
Presumably permanent in stack monitoring will be required in terms of AEL permit requirements
Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions
Water
Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)
General
There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)
Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards
Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter
All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 11 April 2012 1245 PM
To Lea September
Subject Fw Comments on Galvanising Plant EIR Coega IDZ
Lea
One other comment on that I have on the Galvanising Plant Draft EIR
Hydrogen chloride is one of the main emissions There are no ambient air
quality guidelines for HCl and the EIR says concentrations will be well
within health parameters
However the main problem with HCl is its corrosive effect - there is
absolutely no mention of this in the draft EIR nor air specialist report
There needs to be some sort of comment assessment as to whether HCl
emissions are likely to impact on for example the adjacent Agni-Steel
Plant wrt corrosion - their factory structure will be made of steel
The EIR specialist rpt suggests monitoring HCl at ground level on the
property boundary and this is supported in case there are complaints from
neighbours
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Paul Martin ltpmartinaxxesscozagt
To Lea September ltleailisocomgt
Sent Monday April 09 2012 1158 AM
Subject Comments on Galvanising Plant EIR Coega IDZ
gt Lea
gt
gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising
gt plant
gt
gt
gt Dr Paul Martin
gt PO Box 61029
gt Bluewater Bay 6212
gt Tel 041 4665698
gt Cell 0732524111
gt email pmartinaxxesscoza
gt
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 12 April 2012 1139 AM
To Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Hi Lea
Hope yoursquore keeping well
I have requested comments from my colleagues and the CDC Casa team on the Draft EIR
Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report
Regards
Andrea
From Graham Taylor
Sent Thursday April 12 2012 838 AM
To Andrea Von Holdt Firhana Sam
Cc Johan Fourie Maria van Zyl Melikhaya Sihawu
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Andrea Firhana
Firhana if you could please ensure that the co-ordinates provided in the EIR correspond
with our records (pages 4-1 amp 4-2)
My comments are as follows
It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work
Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above
Regards
Graham Taylor
Spatial Development Manager - Infrastructure Development
Mobile 0832283055
Office 0414030454
Facsimile 0865185033
Email GrahamTaylorcoegacoza
Website wwwcoegacom
right PLACE | right TIME | right CHOICE
This email and all contents are subject to the following disclaimer
httpwwwcoegacomemaildisclaimerhtml
From Lea September [mailtoleailisocom]
Sent 04 May 2012 0411 PM
To Andrea Von Holdt
Cc Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Dear Andrea
We have taken note of the comments from the GIS Unit These issues have been rectified in
the final version of the EIR
Please can you forward to the relevant persons at the GIS Unit
Thank you
Best regards
Lea September
APPENDIX E
BACKGROUND INFORMATION
DOCUMENT
APPENDIX F
AIR QUALITY IMPACT ASSESSMENT
APPENDIX G
TRAFFIC IMPACT ASSESSMENT
APPENDIX H
WASTE MANAGEMENT AND HAZARDOUS
SUBSTANCES SPECIALIST STUDY
APPENDIX I
WATER QUALITY SPECIALIST STUDY
APPENDIX J
ENVIRONMENTAL MANAGEMENT
PROGRAMME
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 iv
ACRONYMS
AEL Atmospheric Emissions Licence
BID Background Information Document
CCA Custom Controlled Area
CDC Coega Development Corporation
DEA Department of Environmental Affairs
DEDEAT Department of Economic Development Environmental Affairs and Tourism
DWA Department of Water Affairs
EAP Environmental Assessment Practitioner
EIA Environmental Impact Assessment
ELC Environmental Liaison Committee
EMP Environmental Management Programme
GN Government Notice
IampAPs Interested and Affected Parties
IDZ Industrial Development Zone
LNG Liquid natural gas
masl Meters above sea level
MSDS Material Safety Data sheet
NEMA National Environmental Management Act
NEMBA National Environment Management Biodiversity Act (No10 of 2004)
NMBM Nelson Mandela Bay Municipality
OSMP Open Space Management Plan
PoS Plan of Study
SAHRA South African Heritage Resources Agency
TNPA Transnet National Ports Authority
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 v
EXECUTIVE SUMMARY
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone
(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province
Galvanizing consists of coating steel with zinc in order to protect it from corrosion An
Environmental Impact Assessment (EIA) is required as the proposed project involves several
activities listed in terms of Section 24 of the National Environmental Management Act
(NEMA) 107 of 1998 as amended and requires an environmental authorisation The
project also involves activities listed in terms of the National Environmental Management Air
Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008
which respectively require an Atmospheric Emissions Licence and a Waste Management
Licence
The Scoping and Environmental Impact Assessment process underway covers all aspects of
the project and informs all three applications
Scoping was the first phase of investigations and aimed to inter alia identify potential key
environmental issues and impacts to be addressed in the EIA phase
The following environmental issues and potential impacts identified in the Scoping Phase
were investigated in the EIA
Air quality
The galvanizing process generates atmospheric emissions which are regulated in terms
of the National Environmental Management Air Quality Act and appropriate measures
are required in order to adhere to the applicable standards Other sources of impact on
air quality include emissions from the LNG burner emissions and dust from the transport
of steel and other materials in trucks as well as dust and gas emissions related to
construction activities Mitigation measures recommended in the EMP will ensure that air
quality impacts are kept to a minimum and compliance with emissions standards is
maintained
Biodiversity and conservation
Certain types of vegetation in the IDZ are of high conservation importance Protected
species will be rescued as per the CDCrsquos requirements
Water quality
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through spills
or leaks This risk can however be minimized if not avoided altogether through design
choices (bunded areas) and the adherence to best practice guidelines for the handling or
the transport of hazardous substances and waste
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vi
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
Waste management and hazardous substances
The plant will generate a relatively small amount of solid waste which will be re-used
recycled or disposed of in accordance with the EMP recommendations
There will be a wastewater treatment plant on site which will neutralise process water
(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer
Hazardous waste from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site
at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and
removed on a monthly basis is limited to 10 m3
A number of substances classified as hazardous are used in the galvanizing process and
the transport and handling of these is subject to certain rules and guidelines
In addition the permanent storage of a high quantity of liquid petroleum on site (20 000
litres at any one time) is subject to certain specifications and requires approval from the
municipality
Health and safety
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling of the various substances used will be done in
accordance with applicable instructions (cf material safety data sheets)
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as provide
site supervision including executing tests (individual test cold run and hot run) during 3
months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the EMP
Traffic
In the operational phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and from
the Port of Ngqura
The traffic expected to be generated during construction as well as operation is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low and
the total traffic generated by Casa Steel is also relatively low
The impact on port traffic is also negligible and well within the portrsquos capacity
Socio-economic aspects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vii
The proposed galvanizing plant will make a positive contribution by creating jobs during
construction and operation and generating business for the various service providers
Fatal flaws
No fatal flaws have been identified
The significance of these potential key environmental impacts were assessed in the EIA
phase and the findings of this phase of investigations are presented in this report
The main findings of the EIA are as follows
During construction impacts post-mitigation are low with the exception of noise and
biodiversity as the construction of the plant will result in the destruction of habitat
and loss of fauna and flora and noise impacts inherent to construction activities
Mitigation measures have been included in the EMP for these impacts and they have
a medium significance post-mitigation
All impacts were assessed as low during operation after mitigation
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium
to long term similar impacts are likely to occur due to ongoing developments in the
IDZ
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
The CDC has its own requirements regarding the monitoring of certain aspects of the
project such as the quality of the effluent and the noise levels These have been
incorporated into the EMP Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as other
infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified and
assessed No fatal flaws have been identified
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 viii
It is recommended that the project be approved subject to the conditions listed above
and adherence to the EMP recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-1
1 INTRODUCTION
11 BACKGROUND
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)
Nelson Mandela Bay Municipality Eastern Cape Province
The demand for galvanised steel products is high in South Africa and Africa and is
expected to increase in the foreseeable future From an economic point of view the
proposed project has therefore been found to be viable
Casa Steel will source the steel coils from various markets internationally and in
South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is
destined to be exported mainly to African countries
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
An Environmental Impact Assessment (EIA) is required as the proposed project
involves several activities listed in terms of Section 24 of the National Environmental
Management Act (NEMA) No 107 of 1998 as amended and requires an
environmental authorisation
The following listed activities requiring environmental authorisation have been
identified
Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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
Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped
land to industrial use greater than 1 ha but less than 20 ha in size outside an
urban area
Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any
process or activity requiring a license in terms of national or provincial legislation
governing the generation or release of emissions
Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5
hectares or more of vegetation where 75 or more of the vegetative cover
constitutes indigenous vegetation except where such removal of vegetation is
required for
(i) purposes of agriculture or afforestation inside areas identified in
spatial instruments adopted by the competent authority for
agriculture or afforestation purposes
(ii) the undertaking of a process or activity included in the list of waste
management activities published in terms of section 19 of the
National Environmental Management Waste Act 2008 (Act No 59
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-2
of 2008) in which case the activity is regarded to be excluded from
this list
(iii) the undertaking of a linear activity falling below the thresholds in
Notice 544 of 2010
Hot dip galvanizing is a listed activity in terms of section 21 of the National
Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires
an Atmospheric Emissions Licence (AEL)
In addition the treatment of wastewater with an annual throughput capacity of more
than 2000 m3 is a listed activity in terms of the National Environmental Management
Waste Act 59 of 2008 and requires a waste management licence
ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental
Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact
Assessment process in terms of section 24 of NEMA for the construction and
operation of the proposed galvanizing plant The EIA process covers all aspects of
the project and informs all three applications (for environmental authorisation waste
management licence and AEL)
13 PURPOSE OF THIS REPORT
This report builds on the scoping report submitted to the Eastern Cape Department of
Economic Development and Environmental Affairs (DEDEA) and the Nelson
Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It
describes the proposed project and presents the findings of the second phase of
investigations (EIA phase)
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP)
The EIA was managed by Ms Terry Baker a certified Environmental Assessment
Practitioner with 20 years of working experience She has a MA in Environmental
Management and specialises in Environmental Impact Assessments and Project
Management She has been involved in a variety of different types of EIAs including
for water supply projects dams transmission lines roads and airports in South
Africa Botswana Uganda Lesotho and Mozambique She has been involved in
water resource management and public participation programmes on a number of
projects Terry has also been involved in the use of Geographic Information Systems
environmental status quo reports water quality assessments socio-economic and
institutional development projects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-3
15 PROJECT TEAM
In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen
(water quality specialist) and Lea September (EAP) with specialist input from Renee
von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous
substances) and Seniel Pillay (Traffic Impact Assessor)
The Business Unit Head of the ILISO Environmental Management Discipline Group
Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is
a Fellow of the South African Institution of Civil Engineers a member of the South
African Society of Aquatic Scientists of the Environmental Scientific Association of
the International Water Association of the Water Institute of South Africa and of the
Vaal River Catchment Association He is a certified Environmental Assessment
Practitioner with 30 years experience who specialises in project management
environmental impact assessments and water resource planning He specifically has
extensive experience in water quality especially water quality management water
quality monitoring and water quality assessment Martin has experience in managing
projects that involve multi-disciplinary teams and public consultation and
participation in South Africa and abroad
Lea September is an Environmental Assessment Practitioner with a Masters degree
in Environmental Management She has experience in impact assessment and
environmental management and has been responsible for drafting impact
assessment reports and Environmental Management Programmes and conducting
public participation processes as well as high level environmental screenings for a
variety of projects in the energy water transport and industrial sectors
Renee von Gruenewaldt has nine-years experience in the field of air pollution
impact assessment and air quality management Prior to becoming involved in air
quality consultation she was part of the Highveld Boundary Layer Wind Research
Group based at the University of Pretoria Since joining Environmental Management
Services (the company now Airshed Planning Professionals) she has undertaken
numerous air pollution impact studies and has provided extensive guidance to both
industry and government on air quality management practices
Pieter Smuts graduated as a Civil Engineer and became involved in the field of
municipal engineering and infrastructure construction He has specialized during the
last twelve years in solid waste management He has completed waste management
plans feasibility studies and final designs of waste management facilities in South
Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and
the review of the Mavoco hazardous waste landfill design in Maputo Mozambique
and completed a study on hazardous waste (textile factory sludge) management in
Maseru Lesotho
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-4
Seniel Pillay is a transportation engineer with over 16 years experience in
transportation planning and traffic engineering He has been involved in a wide
range of projects ranging from developing the Transport Operations Plan for the
FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System
for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller
traffic impact assessments for inter alia road improvement schemes Of particular
relevance to this project his experience includes Heavy Goods Vehicle Study for
eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact
Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash
Preliminary Transportation Assessment
16 STRUCTURE OF THIS REPORT
The proposed project and the alternatives considered are described in Chapter 2
Chapter 3 details the approach adopted for the EIA phase
The biophysical and socio-economic environment affected by the activity is described
in Chapter 4
The environmental impacts identified are discussed in Chapter 5
The EIA methodology is described in Chapter 6 and Chapter 7 presents the results
of the impact assessment
The environmental impact statement is presented in Chapter 8
Finally Chapter 9 spell out the conclusions and recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-1
2 DESCRIPTION OF THE PROPOSED PROJECT
21 TECHNICAL ASPECTS
211 The galvanizing process
Galvanizing consists of coating steel with zinc in order to protect it from corrosion
Before steel strips can be galvanized they undergo a pre-treatment in order to
ensure that the steel sheets are free from any surface oxides as they enter the
molten zinc coating Bath This is done by removing the oil from the steel sheets (in
the degreasing unit) and then removing the rust from the surface of the sheet (in the
pickling unit)
The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The
melting zinc on the strip surface will be cooled and solidified through air cooling in the
cooling tower
Finally the galvanised steel sheets are dipped into a water quenching tank in order to
further cool the sheets from about 150degC to 40degC
It is possible to make galvanised steel more durable by chromating it Approximately
50 of the galvanised steel production output will receive chromate passivation
treatment after quenching the galvanised steel sheets will be sprayed with a chrome
solution (3 kgcm2)
After galvanizing and chromating the steel sheets are cut to achieve the desired coil
size and weight and transported to the storage yard
The process flow diagram below (Figure 1) illustrates the main stages of the
galvanizing process and indicates the major inputs and outputs as well as the
resulting effluent and atmospheric emissions
Draft Environmenal Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-2
Figure 1 Process flow diagram for proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-3
212 Main inputs and outputs in operational phase
In view of the above the main inputs will be as follows
Steel coils 85 000 tonsyear
Zinc 870 tonsyear
Electricity 2500 kVA
Water 2000 m3month (of which 400 m3 will be potable water)
Liquid Natural Gas (LNG) 270 NM3hour
Sodium hydroxide (NaOH) 1000 m3year
Hydrochloric acid (HCl) 800 m3year
Chrome (Cr+3) 10 m3year
The main outputs will be
Galvanized steel 80 000 tonsyear
Scrap metal 20 tonsyear
General waste 65 tonsyear
Hazardous waste 2 m3month
Wastewater 012 Mlweek
Atmospheric emissions lt 5 ppm
213 Installations on site
The bulk of the operations involved in the galvanizing process occur along a
continuous galvanizing line (See Figure 2 below) which is the main piece of
machinery required for the proposed galvanising plant
Figure 2 Continuous Galvanizing Line
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-4
Water is one of the major inputs and is used throughout the galvanizing process notably
for rinsing and cooling purposes and as a mixing agent for the various chemical
solutions The plant will have a water treatment plant on site to treat the water used in
the various processes (approx 250 m3
of wastewater per week) The wastewater
treatment facility will be operated by a professional water treatment company as Casa
Steel does not have the required expertise in house to treat its process water Sulphuric
acid (H2SO4) is used as part of the treatment process to reduce caustic soda The
neutralised water is discharged to the sewer while any sludge is disposed of as
hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)
will be disposed of
Some critical areas of the galvanizing process such as the zinc pot require uninterrupted
power It is therefore proposed to install an LNG burner to maintain the zinc bath at a
temperature of between 450 and 460degC
22 LOCATION OF THE PROPOSED GALVANIZING PLANT
The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast
of Port Elizabeth in the Eastern Cape (Figure 3)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-5
Figure 3 Location of the proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-6
23 NEED AND DESIRABILITY
The profitability of the proposed project has been established by Casa Steel and a
pre-feasibility study has confirmed that the proposed project was feasible from a
technical and financial point of view The Coega IDZ is specifically designed to host
facilities such as a galvanizing plant and can provide the necessary infrastructure
and services to its investors It therefore constitutes a very suitable location for the
project
24 ALTERNATIVES IDENTIFIED
Zone 6 has been specifically earmarked for heavy ferrous metal industries and is
therefore a suitable location for the proposed galvanizing plant as such no site
alternatives have been provided for and assessed in this EIA However prior to the
commencement of the EIA process Casa Steel was presented with a number of
different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the
selection of the site were
(a) The dimensions of the land the site should be at least 200 m long and
50 m wide in order to accommodate the galvanizing line and adjacent lay
down area and additional land should be available next to the site for future
expansion
(b) The fiscal arrangements applying to the site the site should be located
within the future Custom Controlled Area (CCA) as the bulk of the
production output of the plant will be exported
The no-go alternative is assessed in this report
25 CONSTRUCTION ASPECTS
The construction phase of the project will take about 12 months and will essentially
consist of erecting a building to house the galvanizing line and other equipment and
preparing a concrete laydown area adjacent to the building
The CDC will provide an access point from the existing tarred road that will lead to
the site
Approximately 100 workers from the surrounding areas will be contracted for the
construction work
The requirements in terms of services during construction are listed below
Water 1000 m3month
Electricity 2500 kVA
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-7
The CDC will provide temporary services for the construction phase including a
conservancy tank for flush toilets Sewage infrastructure will only be provided for the
operational phase
26 OPERATION ASPECTS
Before the plant can become fully operational the equipment and machinery will be
tested for approximately 3 months The supplier will supervise these tests as part of
the transfer of know-how and training of staff on the plant
Casa Steel will start operating the plant at a reduced capacity (about 50 000
tonsyear) for a period of time (mostly determined by market aspects) before bringing
production to full capacity (80 000 tonsyear) This is done by operating the line for
longer hours
Approximately 50 to 60 people will be working on the plant Approximately 6-10 of
these will be unskilled 40-45 skilled and about 5 people in managerial positions
The requirements in terms of services during operation are as follows
Water 2000 m3month
Electricity 2500 kVA
Effluent discharge 24 m3day
The CDC has entered into agreements with the municipality to secure the provision
of services such as water and electricity to its tenants Tenants in the IDZ have their
own agreements with the NMBM for electricity while the agreements for water and
sewage are with the Facilities Unit of the CDC
Regarding discharge of wastewater to the sewer the municipality indicated that the
only requirement is that the water discharged complies with applicable municipal
discharge standards
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 3-1
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT
31 OBJECTIVES
The main objectives of the EIA phase are to
Assess the significance of the environmental issues and impacts identified in the
scoping phase focusing on key impacts
Recommend appropriate measures to mitigate negative impacts and enhance the
benefits and include them in the draft EMP
Undertake a public participation process that provides opportunities for all
interested and affected parties (IampAPs) to be involved
32 AUTHORITY CONSULTATION
The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental
Liaison Committeersquo (ELC) which comprises representatives of various authorities
including DEDEAT the Department of Environmental Affairs (DEA) and Department
of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the
Coega Development Corporation (CDC) and Transnet National Ports Authority
(TNPA) The ELC has been specifically formed to facilitate EIA applications in the
IDZ
Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to
the clearance of vegetation should be included in the application A formal request
was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the
application and all registered stakeholders were informed of the request in writing on
19 October 2011
33 PUBLIC PARTICIPATION PROCESS CONDUCTED
On-site notices were replaced by a notification displayed on the CDCrsquos digital notice
board at the business centre in Zone 1 of the IDZ The eNotice was placed on
13 April 2011 and will remain for the full duration of the EIA process
Registered stakeholders will be notified in writing of the availability of the draft EIA
report and EMP which will also be advertised in a local newspaper Stakeholders
including state departments and the public will have forty (40) days to comment on
the draft EIA report and EMP The draft EIA report and EMP will be sent by email
where possible and made available for download on the ILISO website
(wwwilisocom)
A summary of all issues and comments received during the stakeholder consultation
process as well as of correspondence in that regard will be captured in an Issues
and Responses Report that will form an Appendix to the EIA Report
The list of registered IampAPs is included in Appendix A
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 3-2
34 LEGISLATION AND GUIDELINES CONSIDERED
The following legislation and guidelines were considered in the preparation of this
report
National Environmental Management Act Act No 107 of 1998
NEMA EIA Regulations 2010
National Environmental Management Air Quality Act Act No 39 of 2004
National Environmental Management Waste Act Act No 59 of 2008
Hazardous Substances Act Act 15 of 1993
Occupational Health and Safety Act Act 85 of 1993
Hazardous Chemical Substances Regulations 1995 (GNR 1179)
Major Hazard Installation Regulations 2001 (GNR 692)
National Water Act Act 36 of 1998
National Heritage Resources Act Act 25 of 1999
DEAT Integrated Environmental Management Information Series 1-5 and 12-15
NEMA draft Implementation Guideline
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Public Participation (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Alternatives (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Draft Guideline for Determining the Scope of Specialist
Involvement in EIA Processes (2005)
IAIA guidelines
National air quality standard for thoracic particulates Government Gazette
No 32816
Listed activities and associated minimum standards identified in terms of section
21 of the National Environmental Management Air Quality Act Act No 39 of
2004 Government Notice 248 of 2009
Minimum Requirements for the Handling Classification and Disposal of
Hazardous Waste DWAF Waste Management Series (1998)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-1
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION
The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega
IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay
to the north of the N2 highway between Port Elizabeth and Grahamstown east of the
Coega River
The co-ordinates of the corners of the site are shown in Table 1
Table 1 Coordinates of site corners for the proposed galvanizing plant
Point Longitude Latitude
A 25deg411126E 33deg45587S
B 25deg411156E 33deg45499S
C 25deg411938E 33deg45131S
D 25deg412174E 33deg45481S
E 25deg412508E 33deg45979S
F 25deg412634E 33deg451160S
G 25deg411782E 33deg451560S
H 25deg411692E 33deg451428S
J 25deg411314E 33deg45868S
Figure 4 Zone layout in the Coega IDZ
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-2
Figure 5 Site location
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-3
42 SOCIO-ECONOMIC CHARACTERISTICS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the
NMBM There are no residents within the IDZ
As far as the broader NMBM and Eastern Cape Province are concerned the
following can be noted The NMBM is located within the Eastern Cape Province the
2nd largest Province in South Africa (3rd in terms of population) characterised by a
predominantly black population with low incomes and high levels of unemployment
(CES 2010)
The NMBM has a population of just above 11 million and covers an area of
1 950 km2 It is the main urban and industrial centre of the province and Port
Elizabeth in particular which forms part of the NMBM is the commercial capital of
the Eastern Cape 52 of the NMBM population is female and 37 is below the
age of 20 these two groups are particularly affected by unemployment
43 BIOPHYSICAL CHARACTERISTICS
431 Surface and ground water
No rivers occur in Zone 6 There is however a natural attenuation pond on the
southern most part of the site which will have to be avoided
The IDZ is underlain by calcrete sand and gravel deposits that overlie low
permeability clays These clays limit the vertical infiltration of rainwater and induce a
horizontal groundwater flow towards the Coega River channel which is the most
significant surface water feature in the Coega IDZ Consequently rapid run-off takes
place following precipitation (Jacobs 2008)
Groundwater levels at Coega are generally about 3 to 5 m below surface ie just
above the contact between the permeable sands and the underlying impermeable
clays The groundwater flow direction is to the southeast following the surface water
drainage direction (Jacobs 2008)
432 Climate and atmospheric conditions
Port Elizabeth has a warm temperate climate and the temperature ranges are not
extreme Exceptionally high temperatures may be experienced during berg wind
conditions which occur frequently during autumn and winter Extreme temperatures
also occur during summer with little accompanying wind
The wind regime for the area largely reflects the synoptic scale circulation with
dominant westerly and northwesterly flow fields representing the pre-frontal
conditions and south-westerly flow fields representing the frontal conditions The
south-easterly and south-westerly wind flow (land breeze) increases during daytime
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-4
conditions with westerly and north-westerly wind flow increasing during the night (sea
breeze)
The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of
Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15
km southwest) and Port Elizabeth (~23 km southwest)
An ambient air monitoring network has been established in the Coega IDZ which
consists of three monitors Saltworks Motherwell and Amsterdamplein Although
NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative
impacts due to the proposed Galvanising Plant is PM10 A maximum daily average
PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed
SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3
was exceeded on 17 days in 2007 and 26 days in 2008
Existing sources of emissions in the vicinity of the proposed galvanizing plant include
industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other
fugitive dust sources (von Gruenewaldt 2011b)
433 Geology and soils
Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel
and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly
limestone and conglomerate
434 Terrestrial ecology
This section draws from the EIA report compiled for the Agni Steel (formerly Afro-
Asia) steel processing facility which is adjacent to the proposed site for the
galvanizing plant (Jacobs 2008)
The area consists largely of grasses succulents and scrubby bush with alien
species making up the greater part of the more dense vegetation
Zone 6 falls within the inland vegetation and is characterised by a vegetation type
referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the
Coega IDZ and has been found to have three times the level of endemism of other
vegetation communities in the Coega IDZ Bontveld therefore has a high
conservation status Two Bontveld conservation areas have been identified within the
IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)
Bontveld that will be destroyed as a result of development in the IDZ will be given
conservation status in these two areas
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-5
Figure 6 Coega IDZ Open Space Management Plan (OSMP)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-6
Certain areas in the IDZ are invaded by alien plant species The most common
invader species is rooikrans (Acacia cyclops) which presently forms large
monospecific stands in areas throughout the Coega IDZ There are several other
aliens present that pose a threat to the flora of this area including the prickly pear
(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)
Loss of vegetation and alien plant invasion due to human activity has resulted in a
reduction in the diversity of terrestrial fauna
The majority of mammals present in the Coega IDZ are small or medium-sized Of
the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed
gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of
Algoa Bay however it is not considered threatened The gerbil is common in
foredune and dune thicket habitat in the Coega region and is therefore unlikely to
occur on the proposed site
A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird
species are resident or common to the area Most diversity occurs in the thicket
although the coastal area also supports specialised avifauna Two species of tern
the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well
as the Cape gannet (Morus capensis) and the African penguin (Spheniscus
demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne
caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant
(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser
flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns
are two of the most endangered coastal species in South Africa Other bird species
of conservation concern include the Whitefronted plover (Charadrius marginatus)
African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus
bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus
ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides
paradisea) Breeding pairs of Damara terns and African black oyster catchers have
been observed in the coastal dunes of the IDZ but should not be affected by
developments that fall outside the dune areas
The Eastern Cape supports nearly a third (approximately 133 species) of the reptile
species recorded in South Africa More than half of the Eastern Capersquos endemic
reptile species occur in the Algoa Bay area giving the region a high conservation
value A total of 63 reptile species are believed to occur within the Coega IDZ The
majority of these are found in Succulent Thicket and riverine habitats Only a few
reptile species occur in the coastal dunes and estuarine habitats More than a third of
the species are described as relatively tolerant of disturbed environments provided
that migration corridors of suitable habitat are maintained to link pristine habitats
Twenty two reptiles are of special concern including five endemic species (two of
which may also be endangered) four endangered sea turtles eight species listed
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-7
with CITES one rare species and four species at the periphery of their range
Fourteen of these species of special concern are confirmed as occurring on or within
2 km of the Coega IDZ
A total of 32 amphibian species and sub-species occur in the Eastern Cape
representing almost a third of the species recorded in South Africa However none of
the species are endemic or Red Data Book species Based on previous studies in the
area it is estimated that approximately 17 amphibian species occur within the Coega
IDZ Four species are listed as peripheral but none are threatened internationally
These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog
(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and
the bubbling kassina (Kassina senegalensis)
The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated
vegetation has not been extensively studied One grasshopper species Acrotylos
hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue
(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis
pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in
four localities in the Eastern Cape one of which is within the Coega IDZ The Coega
copper Aloeides clarki is endemic to this particular region of the Eastern Cape and
is currently known to occur in three localities two of which are in the Coega IDZ The
localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the
Coega IDZ and their distributions were taken into account when defining Coegarsquos
open space system and Development Framework Plan
435 Land use and topography
The land is currently undeveloped and earmarked for industrial development The
site is relatively flat ranging from an elevation of 66 masl on the northern-most
corner to 59 masl at the southern-most corner
436 Heritage and archaeological survey
Extensive studies have been undertaken in Zone 6 with respect to heritage aspects
Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a
2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond
2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is
currently being finalised
Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing
Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha
in extent and was located next to the R102 road to Motherwell Kaplan conducted
HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi
Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will
now be located in Zone 5)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-8
The various archaeological investigations reached similar observations and
conclusions Stone tools of various densities and types were found throughout the
zone The majority of the stone tools were mainly of Earlier and Middle Stone Age
and occasional Later Stone Age origins (Figure 4)
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble
gravels exposed by tracks in Zone 6 (Source Binneman 2010)
The stone tools which comprised of quartzite flakes chunks flaked pebblecobble
and cores were randomly distributed across the landscape and are in secondary
context There were no lsquoconcentrationsrsquo of tools observed which suggested any
spatial patterning or activity areas although these may be present or covered by soil
and vegetation
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 5-1
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED
The following environmental issues and potential impacts were identified in the
Scoping phase
51 AIR QUALITY
The galvanizing process generates atmospheric emissions with particulates and
hydrogen chloride representing the main pollutants of concern The plant is fitted with
air extraction as well as scrubber systems which are designed to retain the bulk of
pollutants and particles for each of the processes in such a way that less than 5 ppm
of gases and particles will be released into the atmosphere after the fume scrubber
Other sources of impact on air quality include emissions from the LNG burner as well
as emissions and dust from the transport of steel and other materials in trucks
Construction activities will also create dust and gas emissions due to the clearing of
groundcover tipping of material to storage pile levelling of area wind erosion from
storage piles vehicle and construction equipment activity and tailpipe emissions
from vehicles and construction equipment such as graders scrapers and dozers
Overall the air quality impact assessment (Gruenewaldt 2011b) found that
The predicted particulate oxides of nitrogen carbon monoxide and sulphur
dioxide concentrations are all below the National Ambient Air Quality Standards
for all averaging periods
The predicted off-site concentrations of hydrogen chloride are well below the
most stringent effect screening levels
No odour threshold exceedances for hydrogen chloride were predicted to occur
due to routine operations at the Steel Galvanising Plant The South Wales
Environmental Protection Authority stipulates that an odour unit of 20 is
acceptable for urban areas The odour unit would be lt10 directly off-site for
hydrogen chloride
Abnormal emissions can occur in exceptional circumstances Start-up will not
cause abnormal emissions as the scrubbers will be commissioned first and will be
functioning once the plant starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions would be emitted as a
building fugitive
The hourly hydrogen chloride ground level concentrations (directly offsite) were
predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based
on the emission limits as stipulated for listed activities for galvanising processes)
using a screen model which assumes worst case meteorological conditions The
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-2
health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming
abnormal emissions emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset conditions will still
be well within the health effect screening levels
Similarly the hourly particulate emissions from the building fugitives during upset
conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for
listed activities for galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly
off-site
Therefore if emissions are 5 times higher normal they will still be within health effect
screening levels and the daily PM10 NAAQS levels
In the case of a fire a cocktail of gases and particulates could be emitted and could
be over the recommended levels This situation will however be dealt with as an
emergency and normalised as quickly as is possible
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS
The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of
its heritage potential and there are no proposed protected geosites in Zone 6
Should any artefacts be discovered during construction procedures stipulated in the
draft EMP will apply
53 BIODIVERSITY AND CONSERVATION
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
In terms of terrestrial fauna the CDCrsquos open space management plan provides for
the preservation of certain corridors The destruction of certain habitats as a result of
the development will therefore not automatically result in the loss of certain species
54 WATER QUALITY
There is a natural attenuation pond on the southern most part of the site which will be
avoided
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through
spills or leaks
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-3
This risk can however be minimized if not avoided altogether The floor of the factory
will be designed as a bunded area to contain any spills and the entire process will be
contained Potential spills or leaks will therefore be contained and will not impact on
water resources Storm water is therefore considered clean water under normal
operational conditions An oil trap will be placed at the exit of the site to ensure that
no grease from the laydown area enters the stormwater system
Spills and leaks can occur during the handling or the transport of hazardous
substances Best practice guidelines will be followed to ensure that this risk is
adequately managed
Wastewater discharged to sewer will be treated to comply with municipal discharge
standards and is not expected to have an impact on the chemical characteristics of
the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be
discharged from the plant is small in relation to the total volume received at the
Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works
(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently
operated at 61 of its capacity which is approximately 80 Mℓday Thus the
0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore
not have any significant impact on the WWTW
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES
The plant will generate a relatively small amount of solid waste in the form of scrap
metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)
The scrap metal may be sold to other steel processing facilities such as Agni Steel
which will be located next to the plant or collected and disposed of with the rest of
the solid waste by a licensed service provider
As mentioned previously there will be a wastewater treatment plant on site which will
neutralise process water (012 Mlweek) in order to ensure it is of a standard
acceptable for discharge to sewer Waste in the form of sludge from the
neutralization or spent acid must be disposed of as a hazardous waste Solid waste
from the filters used for air quality control is also in this category These wastes can
usually be tested and then delisted which means that it can be placed in a general
purpose landfill
Hazardous effluent from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-
site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored
and removed on a monthly basis is limited to 10 m3
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-4
A number of substances classified as hazardous are used in the galvanizing process
(Table 2) and the transport and handling of these is subject to certain rules and
guidelines In particular the material safety data sheets (cf Appendix H) should be
referred to for inter alia hazards identification accidental release measures
handling and storage precautions exposure controlpersonal protection ecological
information and transport information The Hazardous Chemical Substances
Regulations 1995 should also be adhered to in respect of the transport and storage
of hazardous chemical substances
Table 2 Hazardous materials to be used on site
Major Input Materials
Substance
listed in the
SABS 0228
Group II
hazardous
substances
Volumes to be
stored on site at
any one time
Diesel radic 2000 litres
Liquid petroleum radic 20 000 liters
Sodium hydroxide (NaOH)
(used for degreasing) 8 radic 1000m
3
Hydrochloric acid (HCI)
(used for pickling) 8 radic 800m
3
Zinc (used for galvanising) - TBD
Trivalent chromium (CR+3
)
(used for chromating) 8 radic 10m
3
Sulphuric acid (H2SO4) (used for
treatment of waste water on site) 8 radic TBD
Ammonium Hydroxide (NH4OH) 8 radic TBD
TBD ndash To be determined
Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one
time) and is classified as a flammable substance Specification for flammable storage
facilities in accordance with the requirements of the Nelson Mandela Bay
Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for
quantities between 5000 and 20 000 liters the substance must be kept in a
flammable liquid store which complies with the requirements of a specification
obtainable from the Department Some of the requirements are
Flammable liquid and solid storage facilities are only permitted on the ground
floor
Decanting of flammable liquids and solids are not permitted within any building
Due to the fact that there are flammable materials on site a certificate may be
required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and
Emergency Services Department to confirm that facilities for flammable storage
are in accordance with their requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-5
Because of the permanent installation and high quantity of liquid petroleum on site
the Major Hazard Installation Regulations 2001 promulgated under the Occupational
Health and Safety Act No 85 of 1993 applies A written application for approval of
the installation is required to be submitted to the chief inspector Department of
Labour provincial director Department of Labour and NMBM prior to construction
In addition a risk assessment should be formulated covering all hazardous materials
together with an emergency preparedness and response plan
56 HEALTH AND SAFETY
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling instructions as well as occupational exposure limits
are indicated in the material safety data sheets of the various substances used
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as
provide site supervision including executing tests (individual test cold run and hot
run) during 3 months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the
EMP
In addition the emergency preparedness and response plan will cover the health and
safety aspects related to emergency situations
57 TRAFFIC
The volumes of traffic at the IDZ are currently relatively low and variable depending
on the different zones in the IDZ however these volumes will increase as more
developments are implemented
The construction phase of the Casa Steel development will take about 12 months
and will essentially consist of erecting a building to house the galvanizing line and
other equipment and preparing a concrete laydown area adjacent to the building
The traffic that would be generated during the construction phase can be expected to
be less than the traffic that would be generated by the Casa Steel development when
it is fully operational
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-6
In the operation phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and
from the Port of Ngqura
The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the
Casa Steel development would be off Ring Road 1 The other roads of significance
for the Casa Steel development are the N2 Neptune Road MR435 and MR450
Access to the port is given by Neptune Road Road Link NEP-03 has not yet been
built
Figure 8 Coega IDZ road network identification
(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-7
Figure 9 Coega IDZ road network
Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No
01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-8
The distribution of freight trips is fixed as the majority of trips will be made between
the Port of Ngqura and the Casa Steel site With regard to personnel trips there are
various points of origins (the surrounding residential areas) that could be used by
staff going to the Casa Steel site The distribution of personnel trips is based on
existing traffic count information and is shown in Figure 10
Figure 10 Trip distribution for freight and personnel trips
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The resultant expected Casa Steel traffic assignment is shown in Figure 11
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-9
Figure 11 Morning peak hour Casa Steel development traffic
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The traffic that is expected to be generated by the Casa Steel development is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low
and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)
Consultation has taken place with Transnet Port Authority (TPA) to establish the
impact of the galvanizing plant operations on traffic inside the port The additional
ships entering and exiting the port of Ngqura as a result of the proposed development
will have a negligible impact on port traffic and TPA indicated that it would be well
within the portrsquos capacity
58 NOISE
Noise is not foreseen to be a significant issue insofar as the noise levels inside the
plant and at the boundary of the site will not exceed the limits prescribed by the CDC
Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels
during the day and 60 decibels at night
Mitigation of noise impacts will be addressed in the design of the noise-emitting
components of the plant and their enclosures
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-10
59 SOCIO-ECONOMIC ASPECTS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of
NMBM There are no residents within the IDZ
The direct socio-economic impacts of the proposed project are thus limited to the
employment generated by the project during construction and operation Job creation
remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)
and the IDZ and Port of Ngqura are expected to become a significant catalyst to the
economic growth of the Municipality and the region with current investments at
Coega creating more jobs and stimulating the economy
In this context the proposed galvanizing plant will make a positive contribution
towards the achievement of these goals
There will be 50 to 60 employees during operation phase distributed as follows
Figure 12 Casa Steel organisation chart
Even though a large part of the inputs will be imported and the bulk of the production
output will be exported there will be some positive impacts for the economy of the
region and of South Africa in general Notably the requirements of the plant for
water electricity waste collection and disposal waste water treatment and transport
for example will create business for the various service providers and have an
indirect impact on employment and fiscal revenues as a result
From a visual impact point of view it can be anticipated that the landscape in the IDZ
will be significantly affected over time by developments related to the establishment
of the port and various industries
HEAD ( WORKS )
MGR ( COMM) MGR ( ADMNHR ) Manager marketing
MANAGER OPERATION MANAGER MANAGER MANAGER Q C
AC FIN PUR ampSTORE
PPC SH-GALV SH-tech
SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF
1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO
JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF
2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO
WORKERS WORKERS 7NOS
15 7
RAW MAT amp
DESP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 6-1
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
A description of the nature of the impact any specific legal requirements and the
stage (constructiondecommissioning or operation) will be given Impacts are
considered to be the same during construction and decommissioning The
significance of the potential impacts will be considered before and after identified
mitigation is implemented
The following criteria will be used to evaluate significance
Nature The nature of the impact will be classified as positive or negative and
direct or indirect
Extent and location Magnitude of the impact and is classified as
Local the impacted area is only at the site ndash the actual extent of the activity
Regional the impacted area extends to the surrounding immediate and
neighbouring properties
National the impact can be considered to be of national importance
Duration This measures the lifetime of the impact and is classified as
o Short term the impact will be for 0 ndash 3 years or only last for the period of
construction
o Medium term three to ten years
o Long term longer than 10 years or the impact will continue for the entire
operational lifetime of the project
o Permanent this applies to the impact that will remain after the operational
lifetime of the project
Intensity This is the degree to which the project affects or changes the
environment and is classified as
o Low the change is slight and often not noticeable and the natural functioning
of the environment is not affected
o Medium The environment is remarkably altered but still functions in a
modified way
o High Functioning of the affected environment is disturbed and can cease
Probability This is the likelihood or the chances that the impact will occur and
is classified as
o Low during the normal operation of the project no impacts are expected
o Medium the impact is likely to occur if extra care is not taken to mitigate
them
o High the environment will be affected irrespectively in some cases such
impact can be reduced
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 6-2
Confidence This is the level knowledgeinformation the environmental impact
practitioner or a specialist had in hisher judgement and is rated as
o Low the judgement is based on intuition and not on knowledge or
information
o Medium common sense and general knowledge informs the decision
o High Scientific and or proven information has been used to give such a
judgment
Significance Based on the above criteria the significance of issues will be
determined This is the importance of the impact in terms of physical extent and
time scale and is rated as
o Low the impacts are less important
o Medium the impacts are important and require attention mitigation is
required to reduce the negative impacts
o High the impacts are of great importance Mitigation is therefore crucial
Cumulative Impacts The possible cumulative impacts will also be considered
Mitigation Mitigation for significant issues is incorporated into the EMP for
construction
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 7-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS
71 IMPACTS DURING CONSTRUCTION
711 Air quality
Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris
handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine
particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural
operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks
and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)
Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Fugitive particulate emissions (dust)
related to construction activities Regional
Short
term Medium High High Medium Regional
Short
term Low High High Low
Construction vehicle gas emissions Regional Short
term Medium High High Medium Regional
Short
term Low High High Low
712 Heritage and archaeological resources
Naturedescription of impact excavation activities may impact on unidentified heritage resources
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-2
Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based
on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments
Heritage and archaeological
resources Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on unidentified heritage
resources Local
Short
term
Medium -
high Low High Low
713 Biodiversity and conservation
Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation
importance and cause soil contamination
Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species
Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan
and has compiled a list of protected species to be rescued (see draft EMP)
Biodiversity and conservation Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Loss of fauna and flora Local Perma
nent
Medium -
high High High High Local
Permanen
t Medium High High Medium
Soil contamination Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-3
714 Water related impacts
Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater
runoff spills and leaks Soil erosion
Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of
spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste
disposal Stormwater quality monitoring (see draft EMP)
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Soil erosion Local Short
term Medium Medium High Medium Local
Short
term Medium Low High Low
715 Waste management
Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed
Commentmitigation see draft EMP and waste management plan
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-4
Waste management Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Local
Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
716 Health and safety
Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Short
term
Medium -
high
Medium -
high High High Local
Short
term
Medium -
high Low High Low
717 Traffic
Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and
construction workers from surrounding areas and transport of equipment from the port
Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low
Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and
accurate estimates of quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-5
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Increased traffic on N2 and within the
IDZ Regional
Short
term Low High High Low
718 Noise
Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Short
term
Medium-
high High High Medium Local
Short
term Medium High High Medium
719 Socio-economic
Naturedescription of impact temporary employment will be created during the construction phase
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-6
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Temporary employment Regional Short
term Medium High High Medium
72 IMPACTS DURING OPERATION
721 Air quality
NatureDescription of impact gas and particulate emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning
Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local
sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and
veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute
to background fine particulate concentrations (von Gruenewaldt 2011b)
Assumptions and limitations Potential release of CR6+
As no emission factors are available for trivalent chromium processing the
potential impacts due to these activities could not be quantified
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Dust emitted from traffic on paved roads Regional Long Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-7
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
term
Hydrogen chloride emissions from
pickling process Local
Long
term Low High High Low
Particulate emissions (smoke) from
galvanizing process (due to the
volatilization of flux)
Local Long
term Low High High Low
Particulate oxides of nitrogen carbon
monoxide and sulphur dioxide emissions
from LNG burner
Local Long
term Low High High Low
Nuisance related to odour Local Long
term Low Low High Low
Abnormally high hydrogen chloride and
particulate emissions due to scrubber
malfunction
Local Short
term Medium Low High Medium
Gases (eg SOx NOx CO etc) and
smoke emitted in case of a fire Local
Short
term High Low High Medium
722 Water quality
NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks
Commentmitigation see draft EMP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-8
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Stormwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
723 Waste management and hazardous substances
NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous
waste both can affect environmental quality and human health
Commentmitigation see draft EMP and waste management plan
Waste management and hazardous
substances Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Regional
Long
term High
Medium -
high High High Regional Long term High Low High Low
Soilwaterair pollution due to improper
transport storage and handling of
hazardous substances
Regional Long
term High
Medium -
high High High Regional Long term High Low High Low
Health hazard Local Long
term High
Medium -
high High High Local Long term High Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-9
724 Health and safety
Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Long
term
Medium-
high
Medium-
high High High Local Long term
Medium-
high Low High Low
725 Traffic
Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on
the road network
Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak
hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road
network within Zone 6 of the IDZ (Iliso 2011)
Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)
Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of
quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-10
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on traffic and capacity of the N2 Regional Long
term Low High High Low
Impact on traffic and capacity of ring
road 1 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR435 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR450 Local
Long
term Low High High Low
Impact on traffic and capacity of
Neptune road Local
Long
term Low High High Low
726 Noise
Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Long
term Medium High High Medium Local Long term Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-11
727 Socio-economic
Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate
revenue for the municipality and the region as a whole
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Employment and economic growth Regional Short
term Medium High High Medium
73 COMPARATIVE ASSESSMENT OF IMPACTS
During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as
low during operation after mitigation
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 8-1
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
As a tenant operating in the IDZ Casa Steel will be required to comply with all
current and future CDC requirements as well as with the relevant conditions of
permits licences issued to CDC (eg Integrated Stormwater Masterplan for the
eastern side of the Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)
In particular the CDC has its own requirements regarding the monitoring of certain
aspects of the project such as the quality of the effluent and the noise levels These
have been incorporated into the EMP
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 9-1
9 ENVIRONMENTAL IMPACT STATEMENT
All predicted negative impacts can be mitigated to a low significance The only
exceptions are biodiversity as the construction of the plant will result in the
destruction of habitat and loss of fauna and flora and noise impacts inherent to
construction activities Mitigation measures have been included in the EMP for these
impacts and they have a medium significance post-mitigation
Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium to
long term similar impacts are likely to occur due to ongoing developments in the IDZ
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 10-1
10 CONCLUSION AND RECOMMENDATIONS
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as
other infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified
and assessed No fatal flaws have been identified
It is recommended that the project be approved subject to the conditions listed in
chapter 9 and adherence to the EMP requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 11-1
11 REFERENCES
Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ
Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants
Bennie JS (2010) The historical component (built environment) of the Heritage
Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port
Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report
compiled for Eastern Cape Heritage Consultants
Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater
Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay
Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage
Consultants
BKS (2006) Coega Industrial Development Zone Transport Study Volume 3
Demand Modelling Report Final Draft
Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I
Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6
Report compiled for SRK Consulting
Coastal amp Environmental Services (2010) Environmental Impact Assessment for the
Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone
Volume 3 Environmental Impact Assessment Report CES Grahamstown
Coega Development Corporation (2008) Industry Waste Management Plan -
Strategic Master Plan Report
Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants
Report No CDCSHE 03 8122
Department of Water Affairs and Forestry (1998) Waste Management Series
ldquoMinimum Requirements For The Handling Classification And Disposal Of
Hazardous Wasterdquo Second Edition
Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising
Plant in the Coega Industrial Development Zone
Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the
Coega Industrial Development Zone (IDZ) Specialist Water Study
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 11-2
Jacobs E (2008) Final Environmental Impact Report and Draft Environmental
Management Plan Proposed Steel Recycling and Processing Facility within the
Coega IDZ Report compiled for SRK Consulting
Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY
Galvanising Plant in the Coega Industrial Development Zone Waste Management
and Hazardous Substances Report compiled for ILISO Consulting
RSA National air quality standard for thoracic particulates (PM10) SA standards
(Government Gazette No 32816)
von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed
Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape
Report compiled for ILISO Consulting
von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel
Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report
compiled for ILISO Consulting
Additional sources
Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed
Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared
for Coastal Environmental Services
Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed
Kalagadi Manganese smelter in the Coega Industrial Development Zone Port
Elizabeth Eastern Cape Province Report prepared for Coastal Environmental
Services
Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia
steel recycling facility at the Coega Industrial Development Area Port Elizabeth
Prepared for SRK Consulting Port Elizabeth
APPENDIX A
LIST OF INTERESTED AND
AFFECTED PARTIES
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
DEDEARegional Manager
and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza
DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza
DEA Ocean and
CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza
DEA Ocean and
Coast
Oceanographer land-
based sources of
marine pollution
Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza
DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza
CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza
CDCEnvironmental
Project
Manager
Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza
TNPAPort of Ngqura
Environmental
Manager
Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet
NMBMEnvironmental
ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza
NMBMEnvironmental
ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza
DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza
DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza
WESSASenior Conservation
Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza
Zwartkops
ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700
hughlauegmailcom
zwartkopstrustiafricacom
SANParksNational Marine
CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza
Department Of
LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza
NMBM Air Quality
Division
Assistant
DirectorAir
Pollution and Noise
Templeton Titima 079 490 0574 Ttitimamandelametrogovza
NMBM Air Quality
DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza
NUMSARegional
RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
Department of
HealthNadiema
van der
Bergh083 378 2103
nadiemavanderberghimpiloecprovgov
za
DWA Chief Services
Officer
Joseph Jacobs 041 586 4884 jjacobsdwafgovza
EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza
NUMSecretary of union
officesZandile Xhentsa 043 743 6597 zxhentsanumorgza
DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza
Dynamic
CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom
EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza
Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza
UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom
lprincezago2uticom
Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza
Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza
Absa Mr Johann Steyn 082 3775820 johannstabsacoza
Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza
PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza
Universal
EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza
Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza
GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom
Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza
NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom
DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza
DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza
TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet
DWA Mr Landile Jack JackLdwagovza
DWA Ms Lizna Fourie FourieL4dwagovza
APPENDIX B
NOTICE OF ATMOSPHERIC
EMISSIONS LICENCE APPLICATION
AND ADVERTISEMENT
APPENDIX C
NOTICE OF COMMENT PERIOD FOR
DRAFT SCOPING REPORT
APPENDIX D
SUMMARY OF ISSUES RAISED AND
RESPONSES THERETO
April 2012
1
PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL
DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))
IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt
AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt
This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses
provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process
conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the
Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
2
IssueCommentQuestion Date
received Origin Response
1 Please provide more information with respect to the potential
dangers including the toxicity of the proposed project
07032011
By email
Wayne Poulton
(Bosun Brick
tenant at the
IDZ)
An Environmental Impact Assessment (EIA) was undertaken
which assessed the potential toxicity of the emissions and
effluent Mitigation measures were also recommended in the draft
Environmental Management Programme (EMP) to avoid
minimise or compensate any significant impacts The Draft
Environmental Impact Report and draft EMP were made available
to stakeholders for comment in March 2012
2 Do you have a Background Information Document (BID) or
similar that provides more information on the project
27032011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The BID was sent to all registered IampAPs on 4 May 2011
3 The RoD issued to the CDC on 632007 for the change in
land use for the remaining area of the Coega IDZ includes a
number of requirements with respect to
atmospheric emissions that should be considered in the
Atmospheric Emissions Licence (AEL) application such as
prohibiting and monitoring where possible visible emission
plumes to the atmosphere In particular the
recommendations on pp87-91 of the final revised Scoping
Report dated Nov 2006 must be implemented (clause 421)
04042011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
We have obtained copies of the documents referred to and ensure
that these requirements were taken into account in the
environmental assessment and AEL application
4 If the Port of Ngqura is used for import and export the scope
of the traffic impact assessment (TIA) should also include the
port
10052011
By email
Elliot
Motsoahole
(TNPA Port of
Ngqura)
The scope of the TIA was extended to include port related traffic
The TNPA at the Port of Ngqura was consulted and does not
have any objection to the project TNPA has indicated that the
development would require a minimum number of vessels per
year which would have minimal impact on the Port operations
However due notice would have to be given to the Port of Ngqura
before a vessel is scheduled to arrive so that the vessel can be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
3
IssueCommentQuestion Date
received Origin Response
accommodated at an available berth
5 Concerns with respect to potential stormwater pollution
draining into the Coega catchment and the port of Ngqura
The port needs to be dredged and heavy metals present a
risk in that regard
16052011
By
telephone
Andrew Lucas
(Department of
Water Affairs)
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination by effluent waste or
hazardousdangerous substances is very low
Thus no metals oils or other contaminants are expected to be
present in the stormwater
However stormwater pollution can occur in exceptional
circumstances such as accidents and emergencies The
emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
6 All steel sheets bathing unit must be under roof
7 The sludge out of the decreasing bath will be high in Na and
pH Therefore handling and disposal must be clarified up front
in this project
8 Per se the wastewater from decreasing bath will have high
ph and the component from the pickling unit will have low ph
Then it may be assumed that both streams will neutralize
each other Please then clarify proposed sewer discharge
with Nelson Mandela Bay Municipality up-front for acceptance
of influent as per the documented proposal
9 Pickling may result in dissolved metals How does your team
expect to deal with this As it is planned for discharge into
24052011
By email
Landile Jack
(Department of
Water Affairs)
All bathing units will be under roof
Effluent from the degreasing and pickling baths will be discharged
to the wastewater treatment plant The respectively alkaline and
acidic effluents will mix and neutralise each other in the
wastewater treatment plant Calcium or gypsum will be added if
required to complete the neutralisation process Effluent from the
treatment plant will be discharged to sewer Contact has been
made with the relevant officials and the Municipalityrsquos
requirements have been obtained The effluent discharged to
sewer will notably comply with the applicable discharge standards
Traces of metals (eg iron) may be present but will not exceed
prescribed thresholds The necessary authorisation will be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
4
IssueCommentQuestion Date
received Origin Response
sewer Clarity and acceptance needs to be agreed with
Nelson Mandela Bay Municipality Who owns the sewer
10 Quenching unit will results to Zinc particles How will this
affect sewer discharge This again must be dealt with within
the negotiations with the Municipality
11 Once all has been agreed with the Municipality and at the
same time due negotiations must be done with hazardous
waste courier and disposal facility to accept the hazardous
waste identified in all production lines
12 Of note is the low volume of the proposed WWTW facility ie
250 cubmweek And the no discharge of the quenching
water ie over-flow and cooling only Hence Zinc particles
generation
obtained from the municipality
The sludge from the treatment plant will be collected by a licensed
service provider and disposed of at a permitted site
The quenching bath will be periodically emptied (every 6 months)
and the water discharged will go to the water treatment plant Zinc
particles will settle in the sludge which will be disposed of at a
permitted site
Contact has been made with EnviroServ who manages the
Aloes II HH waste site regarding collection and disposal of
hazardous waste (See waste management report)
13 Investigate the potential effects of toxicity andor influence of
emissions waste and hazardous substances both in
terrestrial and marine fauna
14 With regards to water usage where is the plant going to
extract its waters used in galvanization andor waste
management process ie rainfall rivers or even from the
sea) and which avenues would be more environmental
friendly and effective
31052011
By email
A Bewana
(SANPARKS)
Emissions waste and hazardous substances are not expected to
affect terrestrial or marine ecosystems The air quality study
concluded that atmospheric emissions would not be harmful to
human health and by extension terrestrial fauna There are no
standards for air quality for defining faunal impacts therefore by
ensuring that standards for humans are complied with the impact
on fauna is deemed to be acceptable In this case the impact of
emissions on terrestrial and marine fauna are thus not significant
Solid and liquid wastes both general and hazardous as well as
hazardous substances will be stored handled and disposed of
appropriately to as not to cause harm to terrestrial or marine
fauna
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
5
IssueCommentQuestion Date
received Origin Response
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination and hence land-based
marine pollution by effluent waste or hazardousdangerous
substances is very low
The risk of emissions waste and hazardous substances to
terrestrial and marine fauna is thus very low
However pollution of terrestrial and marine ecosystems can occur
in exceptional circumstances such as accidents and emergencies
The emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
The CDC has an agreement with the NMBM to supply potable
water to the Coega IDZ Currently the infrastructure to supply
return effluent (RE) to the IDZ is not in place therefore Casa Steel
will be supplied with potable water up until such time as the
following 2 options of RE are available
1) Upgrading of the existing Fishwater Flats waste water
treatment works (between IDZ amp PE) including RE plant
and infrastructure to pipe RE to the IDZ (EIA for the
upgrade is underway)
2) Construction of a new waste water treatment works
including RE plant in Zone 9 of the Coega IDZ
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option should be investigated further between Agni and Casa The
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
6
IssueCommentQuestion Date
received Origin Response
CDC can facilitate discussions between the 2 investors
Compliance with CDC Permits amp Requirements
15 It should be made clear that tenants will be required to
comply with CDC requirements and the relevant conditions of
permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water
Licence for its Storm Water Systems on the
East Side of the Coega River that tenants will
need to take cognizance of The contents of the
ldquoIntegrated Stormwater Masterplan for the
eastern side of the Coega IDZ Oct 2010rdquo
especially the Table of best practice p53
onwards may need to be taken cognizance of
o CDC is developing an Operations
Environmental Management Plan that will place
certain obligations on tenants
16 Environmental audits and data collected during monitoring
(eg stack emissions stormwater) will need to be shared with
CDC
Air Emissions
17 Presumably permanent in stack monitoring will be required in
terms of AEL permit requirements
18 Abnormal operating conditions resulting in air emissions ndash I
could find nothing in the EIR to indicate under what
circumstances these could occur (eg start-up) potential
frequency and duration and the impact on ambient air quality
ndash these events usually result in the most problems wrt air
emissions
09042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
15 Compliance with the CDCrsquos Permits amp Requirements has
been included explicitly as a requirement in the EIR (p8-1) and
EMP (pp18 and 25) in the following terms
ldquoAs a tenant operating in the IDZ Casa Steel will be required to
comply with all current and future CDC requirements as well as
with the relevant conditions of permits licences issued to CDC
(eg Integrated Stormwater Masterplan for the eastern side of the
Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)rdquo
16 The need to communicate with the CDC on monitoring and
auditing activities was emphasised in Chapter 8 of the EMP The
following paragraphs were added
ldquoDuring construction the environmental officer will be responsible
for monitoring compliance with the EMP and authorisation
conditions and keeping records as required in the EMP andor
authorisation conditions
The ECO will conduct site inspections every two weeks audit the
records kept by the environmental officer and submit an
environmental compliance report every two months to the
authorities and the CDC (via the Environmental Monitoring
Committeersquos ECO)
During operation the health and safety officer will monitor
compliance with the EMP and the conditions of the Environmental
Authorisation Data collected during monitoring activities and any
environmental audits conducted will be shared with authorities
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
7
IssueCommentQuestion Date
received Origin Response
Water
19 Large volumes of (2000 m3mth) of water are required of
which only 400m3 needs to be potable The NMBM return
effluent system will provide non-potable water once it is
constructed What other water recycling initiatives can be
utilized to reduce potable water requirements (the ISWMP for
the eastern side of the Coega IDZ has some best practice
guidelines collecting rainwater from the roof etc)
General
20 There is no mention of how the CDC Architectural Guidelines
will be incorporated into the development (eg to prevent a
stark uniform warehouse type development)
21 Does NMBM have adequate fire services to cover this
development Apart from the large petroleum store are there
any other large fire hazards
22 Reports from the tenantrsquos ECO during construction and from
the SHE Officer during operations should be channeled to the
Coega Environmental Monitoring Committee This can be
directly or preferably via the EMCrsquos ECO (this will be while
the EMC and ECO are in place) A precedent has been set
for this in the Environmental Authorisations for Agni-Steel and
Kalagadi Manganese Smelter
23 All mitigation actions emanating from the EIR should be
summarized (preferably in a table) If compliance with them is
to be part of the Environmental Authorization from DEDEAT
then they (or the ones that DEDEAT deems to be applicable)
and the CDC (via the Environmental Monitoring Committeersquos
ECO)
The ECO (during construction) and the health and safety officer
(during operation) will report to the Coega Environmental
Monitoring Committee (EMC) via the EMCrsquos ECO (this will be
while the EMC and ECO are in place)rdquo
17 The draft EMP recommends regular monitoring of emissions
from the scrubbers and from the chromating process Additional
emissions monitoring requirements will be confirmed once the
AEL is issued Mention has been made in the EMP (pp11 and 19)
that all AEL conditions including monitoring and reporting
requirements should be adhered to
18 Abnormal emissions can occur in exceptional circumstances
Start-up will not cause abnormal emissions as the scrubbers
will be commissioned first and will be functioning once the plant
starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions
would be emitted as a building fugitive
The hourly hydrogen chloride ground level concentrations
(directly offsite) were predicted to be 239 microgmsup3 (based on the
emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits
as stipulated for listed activities for galvanising processes) using a
screen model which assumes worst case meteorological
conditions The health effect screening level for hourly HCl
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
8
IssueCommentQuestion Date
received Origin Response
should be attached to the EA as an Appendix (otherwise no
one knows about them or takes cognizance of them)
concentrations is 2100 microgmsup3 Assuming abnormal emissions
emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset
conditions will still be well within the health effect screening
levels
Similarly the hourly particulate emissions from the building
fugitives during upset conditions would amount to 293 microgmsup3
(based on the emission limits as stipulated for listed activities for
galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1
January 2015) directly off-site
Therefore if emissions are 5 times higher normal they will still be
within health effect screening levels and the daily PM10 NAAQS
levels
In the case of a fire a cocktail of gases and particulates could be
emitted and could be over the recommended levels This
situation will however be dealt with as an emergency and
normalised as quickly as is possible
The above has been added to the impact identificationdescription
and assessment sections of the EIR
19 The CDC has an agreement with the NMBM to supply
potable water to the Coega IDZ Currently the infrastructure to
supply return effluent to the IDZ is not in place therefore Casa
Steel will be supplied with potable water up until such time as the
infrastructure is in place
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
9
IssueCommentQuestion Date
received Origin Response
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option will be investigated further between Agni and Casa The
CDC has come forward to facilitate discussions between the two
investors
Other water recycling initiatives such as rainwater harvesting
have been considered but are not practical
20 The CDCrsquos Architectural and Landscape Design guidelines
contain requirements pertaining to such aspects as the height
orientation and mass and form of buildings as well as guidelines
for landscaping and signage in order to ensure an attractive
development and achieve an architectural integrity within the
Coega IDZ The plans for the proposed galvanizing plant will be
submitted to the Design Review Committee for approval as
required by the CDC
21 Casa Steel will be required to install fire hydrants according
to the NMBMrsquos standardsrequirements The CDC will provide
potable water (up until such time as return effluent is available)
and a connection to the boundary of the site which will be
connected to the fire hydrants The installation of the fire hydrants
will require approval by the Metrorsquos Fire Chief as was done for
Agni-Steel one of the investors in Zone 6
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
10
IssueCommentQuestion Date
received Origin Response
The Coega IDZ falls within the NMBM and therefore the rates and
taxes paid by the CDC covers the fire services for which the Metro
is responsible Currently the Metro has sufficient capacity to
provide fire services to the tenants within the IDZ This was
confirmed in discussion with the CDCrsquos Infrastructure
Development Unit It is however unknown at which point the
Metrorsquos Disaster Management Plan would not be able to
accommodate servicing tenants in the IDZ
The LNG burner is the only major fire hazard on the plant
22 See response to item 16 above
23 Key mitigation and management measures emanating from
the EIR were recapitulated in Chapter 9 of the EIR to form part of
the conditions attached to the Environmental Authorization from
DEDEAT All mitigation measures recommended as a result of the
impact assessment are presented in a table in the draft EMP
which is appended to the EIR (Appendix J)
24 Hydrogen chloride is one of the main emissions There are no
ambient air quality guidelines for HCl and the EIR says
concentrations will be well within health parameters
However the main problem with HCl is its corrosive effect -
there is absolutely no mention of this in the draft EIR nor air
specialist report
There needs to be some sort of comment assessment as to
whether HCl emissions are likely to impact on for example
the adjacent Agni-Steel Plant wrt corrosion - their factory
structure will be made of steel
11042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The atmospheric corrosion of metals is a complex process with
both the extent of deterioration and the mechanisms varying
considerably depending on the metal Depending on the way
pollutants are transported from the atmosphere to the corroding
surface two types of deposition processes are recognized in
atmospheric corrosion ndash dry deposition and wet deposition Wet
deposition refers to precipitation whereas dry deposition refers to
the remaining processes including gas phase deposition and
particle deposition The most important pollutants acting as
corrosive agents are sulphur and nitrogen compounds including
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
11
IssueCommentQuestion Date
received Origin Response
The EIR specialist rpt suggests monitoring HCl at ground
level on the property boundary and this is supported in case
there are complaints from neighbours
secondary pollutants and particulates Pollutants can contribute to
corrosivity individually however there may be a synergistic effect
when more than one of these pollutants is present in the
environment being affected In the field of atmospheric corrosion
sulphur dioxide is the single most investigated gaseous pollutant
and the quantification of the direct contribution of sulphur dioxide
to the corrosion process of metallic materials is comparatively well
understood (Tidblad amp Kucera 1998)
Very little work has reported on the effect of HCl on the
degradation of materials in the environment with no local dose-
response thresholds developed for corrosion occurring due to HCl
exposures This is probably because HCl which is present
outdoors in markedly reduced concentrations when compared
with SO2 has not been considered to contribute to significant
degradation of materials (Syed 2006) For this reason the
incremental corrosion due to HCl from the Coega Galvanising
Plant cannot be quantified
25 It is unacceptable for ILISO to be using CDC maps (see
figure 9 ndash pg5-6) without these maps being referenced
accordingly particularly when it appears that a CDC map has
been used and then overlaid with features by an unknown
author (ie CASA steel site Port (where the boundaries
depicted are incorrect) and a North legend which is out of
keeping with the overall cartographic intent of the original
work
26 Figure 10 is not referenced appropriately and I believe that I
commented previously in respect to references to roads not
12042012
By email
Graham Taylor
(Spatial
Development
Manager -
Infrastructure
Development
CDC)
This has been rectified in the final version of the report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
12
IssueCommentQuestion Date
received Origin Response
yet built As a result Figure 10 is confusing and clarity needs
to be provided in terms of referencing In addition the Port
shape is irregular and similar to the comment above
27 I acknowledge the emergency preparedness and response
plan but please confirm that this includes pro-active routine
monitoring of storm water leaving your premises to verify that
your assumptions of clean storm water are correct
13042012
By post
Andrew Lucas
(Director
WRampU
Department of
Water Affairs)
Pro-active routine monitoring of stormwater leaving the premises
will be undertaken This has been explicitly emphasised in
chapter 8 of the draft EMP
28 Will portablechemical toilets be used during construction
29 What provisions have been made for storm water drainage
during construction
18042012
By
telephone
Department of
Water Affairs
Port Elizabeth
Chemical toilets will be used during construction
The Casa Steel site will be located at the corner of two roads
drainage of stormwater from the site will take place through the
roadsrsquo drainage system
From Lea September [mailtoleailisocom]
Sent 11 March 2011 0935 AM
To Wayne Poulton
Cc Terry Baker
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Wayne
An Environmental Impact Assessment (EIA) will be undertaken for this project during the
next 10 to 12 months
We foresee that some of the key environmental impacts of the project will be in terms of air
quality water quality waste and hazardous substances
At this stage I am not able to give you any details regarding the potential toxicity of the
emissions andor effluent However specialist studies will be conducted as part of the EIA
that will determine the key impacts of the project Mitigation measures will also be identified
to avoid minimise or compensate any significant impacts
You are registered on the stakeholder database and you will be kept informed of progress in
the EIA process you will notably get the opportunity to access the reports produced and
provide any feedback on them
Please feel free to contact me should you need any further information
Best regards
Lea September
From Wayne Poulton [mailtowaynepbosuncoza]
Sent 07 March 2011 1257 PM
To Lea September
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
Please can you provide me with some more information as to the potential dangers including
the toxicity of this
Kind regards
Wayne
From Lea September [mailtoleailisocom]
Sent 04 March 2011 1123
To Lea September
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 March 2011 0745 AM
To Paul Martin
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 05 April 2011 0847 AM
To Paul Martin
Cc Terry Baker Renee von Gruenewaldt
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Thank you Paul for this information
I have downloaded a copy of the RoD and Scoping report you referred to and will make sure
these requirements are taken into account in the environmental assessment
Best regards
Lea September
From Paul Martin [mailtopmartinaxxesscoza]
Sent 04 April 2011 0955 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Further to my comments on 27311
Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in
the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega
IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised
scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions
including prohibiting and monitoring where possible visible emission plumes to the atmosphere
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Paul Martin
Sent Monday March 28 2011 745 AM
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 10 May 2011 0327 PM
To ElliotMotsoaholetransnetnet
Cc Terry Baker
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Mr Motsoahole
Thank you for your input on this issue
The Port of Ngqura will indeed be used for import and export At the moment the scope of
the traffic impact assessment only covers road traffic I have however relayed the matter to
our traffic specialist and we will consider this issue in the finalization of the Scoping Report I
will keep you informed of any developments in that regard
I trust this is acceptable to you
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]
Sent 10 May 2011 0855 AM
To Lea September
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
It has been noted that Casa Steel will source steel coils from various markets internationally and
in South Africa and the bulk of the plantrsquos production output will be exported to African countries
However there is no mention of logistic requirements
Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will
be used the scope of traffic impact assessment should also include the port
Regards
From Lea September [mailtoleailisocom]
Sent 04 May 2011 0747 AM
To Lea September
Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
Please find attached a letter announcing the EIA process underway for the proposed 80 000
tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as
a Background Information Document (BID) outlining the details of the project
Please contact me should you require any further information on this project
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
Elliot Motsoahole
Manager - Environment
Transnet National Ports Authority
Port of Nqqura
Port Control Building Klub Road Port Elizabeth 6212
PO Box 612054 Bluewater Bay 6212
+27 41 507 8450
+27 86 674 7729
Cell +27 83 542 5619
E-mail Elliotmotsoaholetransnetnet
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
DISCLAIMER The information contained in this communication is subject to copyright and
intended only for the use of leailisocom Unauthorised use disclosure or copying is
strictly prohibited Should a virus infection occur as a result of this communication the sender
will not be liable If you have received this communication in error please notify
elliotmotsoaholetransnetnet
From Lea September [mailtoleailisocom]
Sent 25 May 2011 1147 AM
To Jack Landile (ELS)
Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi
Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Landile
Thank you for your input
Contact has been made with the relevant Municipal Directorate and we will follow up with
them to obtain clarifications on all these issues
I have added both Lizna and yourself on the database and will keep you updated on
progress on this project
Best regards
Lea September
From Jack Landile (ELS) [mailtoJackLdwagovza]
Sent 24 May 2011 0524 PM
To Fourie Lizna (ELS)
Cc Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Hi Lizna
I missed you on this sorry
I linked Pieter twice Instead
Regards
Landile
From Jack Landile (ELS)
Sent 24 May 2011 0445 PM
To leailisocom
Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Lea
The e-mail you sent to Mr Kooverji dated 19 May 2011 refer
Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are
All steel sheets bathing unit must be under roof
The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project
Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal
Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer
Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality
Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines
Of note is the low volume of the proposed WWTW facility ie 250 cubmweek
And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles
generation
Regards
Landile
From Lea September [mailtoleailisocom]
Sent 19 May 2011 0947 AM
To Lea September
Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Stakeholder
Please find attached the remaining appendices to the draft Scoping report for the proposed
80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 June 2011 0411 PM
To Aphiwe Bewana
Subject RE Proposed 80 000 TPY Galvanizing plant in Coega
Dear Mr Bewana
Thank you for your input and apologies for the late reply
We have taken note of your comments and are will be taking them forward in the EIA phase
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Aphiwe Bewana [mailtoaphiwebewanagmailcom]
Sent 31 May 2011 1205 PM
To Lea September
Subject Re Proposed 80 000 TPY Galvanizing plant in Coega
Comment
Re Proposed 80 000 TPY Galvanizing plant in Coega
As SANParks we would like the EIA phase to investigate the potential effects of toxicity
andor influence of emissions waste and hazardous substances both in terrestrial and
marine fauna In the draft scoping report reference has been made with regards to the
terrestrial fauna but there is no attention to potential effects to marine fauna
Equally with regards to water usage where is the plant going to extract its waters used in
galvanization andor waste management process ie rainfall rivers or even from the sea)
and which avenues would be more environmental friendly and effective
Regards
Aphiwe Bewana
Marine Planner
South African National Parks
POBox 76693
NMMU
Port Elizabeth
6031
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 06 July 2011 1031 AM
To Lea September
Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Hi Lea
Irsquove reviewed the Final Scoping Report Herewith a few comments
1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the
Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a
revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the
NMBLP Please include only those in the IDZ as part of your IAP list
Regards
Andrea
From Lea September [mailtoleailisocom]
Sent Wednesday July 06 2011 859 AM
To Lea Septemberrsquo
Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Dear Stakeholder
The final scoping report for the above-mentioned project (attached) is available for comment
until 27 July 2011
The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic
commentaryrdquo tab
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 09 April 2012 1159 AM
To Lea September
Subject Comments on Galvanising Plant EIR Coega IDZ
Lea
Attached are my comments on the Draft EIR for the Coega IDZ galvanising
plant
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
Email attachment
COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ
Dr Paul Martin PO Box 61029
Bluewater Bay 6212 Tel 041 4665698
Email pmartinaxxesscoza
Compliance with CDC Permits amp Requirements
It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of
o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants
Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC
Air Emissions
Presumably permanent in stack monitoring will be required in terms of AEL permit requirements
Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions
Water
Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)
General
There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)
Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards
Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter
All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 11 April 2012 1245 PM
To Lea September
Subject Fw Comments on Galvanising Plant EIR Coega IDZ
Lea
One other comment on that I have on the Galvanising Plant Draft EIR
Hydrogen chloride is one of the main emissions There are no ambient air
quality guidelines for HCl and the EIR says concentrations will be well
within health parameters
However the main problem with HCl is its corrosive effect - there is
absolutely no mention of this in the draft EIR nor air specialist report
There needs to be some sort of comment assessment as to whether HCl
emissions are likely to impact on for example the adjacent Agni-Steel
Plant wrt corrosion - their factory structure will be made of steel
The EIR specialist rpt suggests monitoring HCl at ground level on the
property boundary and this is supported in case there are complaints from
neighbours
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Paul Martin ltpmartinaxxesscozagt
To Lea September ltleailisocomgt
Sent Monday April 09 2012 1158 AM
Subject Comments on Galvanising Plant EIR Coega IDZ
gt Lea
gt
gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising
gt plant
gt
gt
gt Dr Paul Martin
gt PO Box 61029
gt Bluewater Bay 6212
gt Tel 041 4665698
gt Cell 0732524111
gt email pmartinaxxesscoza
gt
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 12 April 2012 1139 AM
To Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Hi Lea
Hope yoursquore keeping well
I have requested comments from my colleagues and the CDC Casa team on the Draft EIR
Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report
Regards
Andrea
From Graham Taylor
Sent Thursday April 12 2012 838 AM
To Andrea Von Holdt Firhana Sam
Cc Johan Fourie Maria van Zyl Melikhaya Sihawu
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Andrea Firhana
Firhana if you could please ensure that the co-ordinates provided in the EIR correspond
with our records (pages 4-1 amp 4-2)
My comments are as follows
It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work
Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above
Regards
Graham Taylor
Spatial Development Manager - Infrastructure Development
Mobile 0832283055
Office 0414030454
Facsimile 0865185033
Email GrahamTaylorcoegacoza
Website wwwcoegacom
right PLACE | right TIME | right CHOICE
This email and all contents are subject to the following disclaimer
httpwwwcoegacomemaildisclaimerhtml
From Lea September [mailtoleailisocom]
Sent 04 May 2012 0411 PM
To Andrea Von Holdt
Cc Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Dear Andrea
We have taken note of the comments from the GIS Unit These issues have been rectified in
the final version of the EIR
Please can you forward to the relevant persons at the GIS Unit
Thank you
Best regards
Lea September
APPENDIX E
BACKGROUND INFORMATION
DOCUMENT
APPENDIX F
AIR QUALITY IMPACT ASSESSMENT
APPENDIX G
TRAFFIC IMPACT ASSESSMENT
APPENDIX H
WASTE MANAGEMENT AND HAZARDOUS
SUBSTANCES SPECIALIST STUDY
APPENDIX I
WATER QUALITY SPECIALIST STUDY
APPENDIX J
ENVIRONMENTAL MANAGEMENT
PROGRAMME
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 v
EXECUTIVE SUMMARY
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in Zone 6 of the Coega Industrial Development Zone
(IDZ) near Port Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province
Galvanizing consists of coating steel with zinc in order to protect it from corrosion An
Environmental Impact Assessment (EIA) is required as the proposed project involves several
activities listed in terms of Section 24 of the National Environmental Management Act
(NEMA) 107 of 1998 as amended and requires an environmental authorisation The
project also involves activities listed in terms of the National Environmental Management Air
Quality Act 39 of 2004 and the National Environmental Management Waste Act 59 of 2008
which respectively require an Atmospheric Emissions Licence and a Waste Management
Licence
The Scoping and Environmental Impact Assessment process underway covers all aspects of
the project and informs all three applications
Scoping was the first phase of investigations and aimed to inter alia identify potential key
environmental issues and impacts to be addressed in the EIA phase
The following environmental issues and potential impacts identified in the Scoping Phase
were investigated in the EIA
Air quality
The galvanizing process generates atmospheric emissions which are regulated in terms
of the National Environmental Management Air Quality Act and appropriate measures
are required in order to adhere to the applicable standards Other sources of impact on
air quality include emissions from the LNG burner emissions and dust from the transport
of steel and other materials in trucks as well as dust and gas emissions related to
construction activities Mitigation measures recommended in the EMP will ensure that air
quality impacts are kept to a minimum and compliance with emissions standards is
maintained
Biodiversity and conservation
Certain types of vegetation in the IDZ are of high conservation importance Protected
species will be rescued as per the CDCrsquos requirements
Water quality
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through spills
or leaks This risk can however be minimized if not avoided altogether through design
choices (bunded areas) and the adherence to best practice guidelines for the handling or
the transport of hazardous substances and waste
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vi
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
Waste management and hazardous substances
The plant will generate a relatively small amount of solid waste which will be re-used
recycled or disposed of in accordance with the EMP recommendations
There will be a wastewater treatment plant on site which will neutralise process water
(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer
Hazardous waste from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site
at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and
removed on a monthly basis is limited to 10 m3
A number of substances classified as hazardous are used in the galvanizing process and
the transport and handling of these is subject to certain rules and guidelines
In addition the permanent storage of a high quantity of liquid petroleum on site (20 000
litres at any one time) is subject to certain specifications and requires approval from the
municipality
Health and safety
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling of the various substances used will be done in
accordance with applicable instructions (cf material safety data sheets)
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as provide
site supervision including executing tests (individual test cold run and hot run) during 3
months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the EMP
Traffic
In the operational phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and from
the Port of Ngqura
The traffic expected to be generated during construction as well as operation is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low and
the total traffic generated by Casa Steel is also relatively low
The impact on port traffic is also negligible and well within the portrsquos capacity
Socio-economic aspects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vii
The proposed galvanizing plant will make a positive contribution by creating jobs during
construction and operation and generating business for the various service providers
Fatal flaws
No fatal flaws have been identified
The significance of these potential key environmental impacts were assessed in the EIA
phase and the findings of this phase of investigations are presented in this report
The main findings of the EIA are as follows
During construction impacts post-mitigation are low with the exception of noise and
biodiversity as the construction of the plant will result in the destruction of habitat
and loss of fauna and flora and noise impacts inherent to construction activities
Mitigation measures have been included in the EMP for these impacts and they have
a medium significance post-mitigation
All impacts were assessed as low during operation after mitigation
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium
to long term similar impacts are likely to occur due to ongoing developments in the
IDZ
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
The CDC has its own requirements regarding the monitoring of certain aspects of the
project such as the quality of the effluent and the noise levels These have been
incorporated into the EMP Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as other
infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified and
assessed No fatal flaws have been identified
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 viii
It is recommended that the project be approved subject to the conditions listed above
and adherence to the EMP recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-1
1 INTRODUCTION
11 BACKGROUND
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)
Nelson Mandela Bay Municipality Eastern Cape Province
The demand for galvanised steel products is high in South Africa and Africa and is
expected to increase in the foreseeable future From an economic point of view the
proposed project has therefore been found to be viable
Casa Steel will source the steel coils from various markets internationally and in
South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is
destined to be exported mainly to African countries
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
An Environmental Impact Assessment (EIA) is required as the proposed project
involves several activities listed in terms of Section 24 of the National Environmental
Management Act (NEMA) No 107 of 1998 as amended and requires an
environmental authorisation
The following listed activities requiring environmental authorisation have been
identified
Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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
Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped
land to industrial use greater than 1 ha but less than 20 ha in size outside an
urban area
Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any
process or activity requiring a license in terms of national or provincial legislation
governing the generation or release of emissions
Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5
hectares or more of vegetation where 75 or more of the vegetative cover
constitutes indigenous vegetation except where such removal of vegetation is
required for
(i) purposes of agriculture or afforestation inside areas identified in
spatial instruments adopted by the competent authority for
agriculture or afforestation purposes
(ii) the undertaking of a process or activity included in the list of waste
management activities published in terms of section 19 of the
National Environmental Management Waste Act 2008 (Act No 59
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-2
of 2008) in which case the activity is regarded to be excluded from
this list
(iii) the undertaking of a linear activity falling below the thresholds in
Notice 544 of 2010
Hot dip galvanizing is a listed activity in terms of section 21 of the National
Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires
an Atmospheric Emissions Licence (AEL)
In addition the treatment of wastewater with an annual throughput capacity of more
than 2000 m3 is a listed activity in terms of the National Environmental Management
Waste Act 59 of 2008 and requires a waste management licence
ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental
Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact
Assessment process in terms of section 24 of NEMA for the construction and
operation of the proposed galvanizing plant The EIA process covers all aspects of
the project and informs all three applications (for environmental authorisation waste
management licence and AEL)
13 PURPOSE OF THIS REPORT
This report builds on the scoping report submitted to the Eastern Cape Department of
Economic Development and Environmental Affairs (DEDEA) and the Nelson
Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It
describes the proposed project and presents the findings of the second phase of
investigations (EIA phase)
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP)
The EIA was managed by Ms Terry Baker a certified Environmental Assessment
Practitioner with 20 years of working experience She has a MA in Environmental
Management and specialises in Environmental Impact Assessments and Project
Management She has been involved in a variety of different types of EIAs including
for water supply projects dams transmission lines roads and airports in South
Africa Botswana Uganda Lesotho and Mozambique She has been involved in
water resource management and public participation programmes on a number of
projects Terry has also been involved in the use of Geographic Information Systems
environmental status quo reports water quality assessments socio-economic and
institutional development projects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-3
15 PROJECT TEAM
In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen
(water quality specialist) and Lea September (EAP) with specialist input from Renee
von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous
substances) and Seniel Pillay (Traffic Impact Assessor)
The Business Unit Head of the ILISO Environmental Management Discipline Group
Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is
a Fellow of the South African Institution of Civil Engineers a member of the South
African Society of Aquatic Scientists of the Environmental Scientific Association of
the International Water Association of the Water Institute of South Africa and of the
Vaal River Catchment Association He is a certified Environmental Assessment
Practitioner with 30 years experience who specialises in project management
environmental impact assessments and water resource planning He specifically has
extensive experience in water quality especially water quality management water
quality monitoring and water quality assessment Martin has experience in managing
projects that involve multi-disciplinary teams and public consultation and
participation in South Africa and abroad
Lea September is an Environmental Assessment Practitioner with a Masters degree
in Environmental Management She has experience in impact assessment and
environmental management and has been responsible for drafting impact
assessment reports and Environmental Management Programmes and conducting
public participation processes as well as high level environmental screenings for a
variety of projects in the energy water transport and industrial sectors
Renee von Gruenewaldt has nine-years experience in the field of air pollution
impact assessment and air quality management Prior to becoming involved in air
quality consultation she was part of the Highveld Boundary Layer Wind Research
Group based at the University of Pretoria Since joining Environmental Management
Services (the company now Airshed Planning Professionals) she has undertaken
numerous air pollution impact studies and has provided extensive guidance to both
industry and government on air quality management practices
Pieter Smuts graduated as a Civil Engineer and became involved in the field of
municipal engineering and infrastructure construction He has specialized during the
last twelve years in solid waste management He has completed waste management
plans feasibility studies and final designs of waste management facilities in South
Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and
the review of the Mavoco hazardous waste landfill design in Maputo Mozambique
and completed a study on hazardous waste (textile factory sludge) management in
Maseru Lesotho
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-4
Seniel Pillay is a transportation engineer with over 16 years experience in
transportation planning and traffic engineering He has been involved in a wide
range of projects ranging from developing the Transport Operations Plan for the
FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System
for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller
traffic impact assessments for inter alia road improvement schemes Of particular
relevance to this project his experience includes Heavy Goods Vehicle Study for
eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact
Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash
Preliminary Transportation Assessment
16 STRUCTURE OF THIS REPORT
The proposed project and the alternatives considered are described in Chapter 2
Chapter 3 details the approach adopted for the EIA phase
The biophysical and socio-economic environment affected by the activity is described
in Chapter 4
The environmental impacts identified are discussed in Chapter 5
The EIA methodology is described in Chapter 6 and Chapter 7 presents the results
of the impact assessment
The environmental impact statement is presented in Chapter 8
Finally Chapter 9 spell out the conclusions and recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-1
2 DESCRIPTION OF THE PROPOSED PROJECT
21 TECHNICAL ASPECTS
211 The galvanizing process
Galvanizing consists of coating steel with zinc in order to protect it from corrosion
Before steel strips can be galvanized they undergo a pre-treatment in order to
ensure that the steel sheets are free from any surface oxides as they enter the
molten zinc coating Bath This is done by removing the oil from the steel sheets (in
the degreasing unit) and then removing the rust from the surface of the sheet (in the
pickling unit)
The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The
melting zinc on the strip surface will be cooled and solidified through air cooling in the
cooling tower
Finally the galvanised steel sheets are dipped into a water quenching tank in order to
further cool the sheets from about 150degC to 40degC
It is possible to make galvanised steel more durable by chromating it Approximately
50 of the galvanised steel production output will receive chromate passivation
treatment after quenching the galvanised steel sheets will be sprayed with a chrome
solution (3 kgcm2)
After galvanizing and chromating the steel sheets are cut to achieve the desired coil
size and weight and transported to the storage yard
The process flow diagram below (Figure 1) illustrates the main stages of the
galvanizing process and indicates the major inputs and outputs as well as the
resulting effluent and atmospheric emissions
Draft Environmenal Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-2
Figure 1 Process flow diagram for proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-3
212 Main inputs and outputs in operational phase
In view of the above the main inputs will be as follows
Steel coils 85 000 tonsyear
Zinc 870 tonsyear
Electricity 2500 kVA
Water 2000 m3month (of which 400 m3 will be potable water)
Liquid Natural Gas (LNG) 270 NM3hour
Sodium hydroxide (NaOH) 1000 m3year
Hydrochloric acid (HCl) 800 m3year
Chrome (Cr+3) 10 m3year
The main outputs will be
Galvanized steel 80 000 tonsyear
Scrap metal 20 tonsyear
General waste 65 tonsyear
Hazardous waste 2 m3month
Wastewater 012 Mlweek
Atmospheric emissions lt 5 ppm
213 Installations on site
The bulk of the operations involved in the galvanizing process occur along a
continuous galvanizing line (See Figure 2 below) which is the main piece of
machinery required for the proposed galvanising plant
Figure 2 Continuous Galvanizing Line
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-4
Water is one of the major inputs and is used throughout the galvanizing process notably
for rinsing and cooling purposes and as a mixing agent for the various chemical
solutions The plant will have a water treatment plant on site to treat the water used in
the various processes (approx 250 m3
of wastewater per week) The wastewater
treatment facility will be operated by a professional water treatment company as Casa
Steel does not have the required expertise in house to treat its process water Sulphuric
acid (H2SO4) is used as part of the treatment process to reduce caustic soda The
neutralised water is discharged to the sewer while any sludge is disposed of as
hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)
will be disposed of
Some critical areas of the galvanizing process such as the zinc pot require uninterrupted
power It is therefore proposed to install an LNG burner to maintain the zinc bath at a
temperature of between 450 and 460degC
22 LOCATION OF THE PROPOSED GALVANIZING PLANT
The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast
of Port Elizabeth in the Eastern Cape (Figure 3)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-5
Figure 3 Location of the proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-6
23 NEED AND DESIRABILITY
The profitability of the proposed project has been established by Casa Steel and a
pre-feasibility study has confirmed that the proposed project was feasible from a
technical and financial point of view The Coega IDZ is specifically designed to host
facilities such as a galvanizing plant and can provide the necessary infrastructure
and services to its investors It therefore constitutes a very suitable location for the
project
24 ALTERNATIVES IDENTIFIED
Zone 6 has been specifically earmarked for heavy ferrous metal industries and is
therefore a suitable location for the proposed galvanizing plant as such no site
alternatives have been provided for and assessed in this EIA However prior to the
commencement of the EIA process Casa Steel was presented with a number of
different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the
selection of the site were
(a) The dimensions of the land the site should be at least 200 m long and
50 m wide in order to accommodate the galvanizing line and adjacent lay
down area and additional land should be available next to the site for future
expansion
(b) The fiscal arrangements applying to the site the site should be located
within the future Custom Controlled Area (CCA) as the bulk of the
production output of the plant will be exported
The no-go alternative is assessed in this report
25 CONSTRUCTION ASPECTS
The construction phase of the project will take about 12 months and will essentially
consist of erecting a building to house the galvanizing line and other equipment and
preparing a concrete laydown area adjacent to the building
The CDC will provide an access point from the existing tarred road that will lead to
the site
Approximately 100 workers from the surrounding areas will be contracted for the
construction work
The requirements in terms of services during construction are listed below
Water 1000 m3month
Electricity 2500 kVA
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-7
The CDC will provide temporary services for the construction phase including a
conservancy tank for flush toilets Sewage infrastructure will only be provided for the
operational phase
26 OPERATION ASPECTS
Before the plant can become fully operational the equipment and machinery will be
tested for approximately 3 months The supplier will supervise these tests as part of
the transfer of know-how and training of staff on the plant
Casa Steel will start operating the plant at a reduced capacity (about 50 000
tonsyear) for a period of time (mostly determined by market aspects) before bringing
production to full capacity (80 000 tonsyear) This is done by operating the line for
longer hours
Approximately 50 to 60 people will be working on the plant Approximately 6-10 of
these will be unskilled 40-45 skilled and about 5 people in managerial positions
The requirements in terms of services during operation are as follows
Water 2000 m3month
Electricity 2500 kVA
Effluent discharge 24 m3day
The CDC has entered into agreements with the municipality to secure the provision
of services such as water and electricity to its tenants Tenants in the IDZ have their
own agreements with the NMBM for electricity while the agreements for water and
sewage are with the Facilities Unit of the CDC
Regarding discharge of wastewater to the sewer the municipality indicated that the
only requirement is that the water discharged complies with applicable municipal
discharge standards
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 3-1
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT
31 OBJECTIVES
The main objectives of the EIA phase are to
Assess the significance of the environmental issues and impacts identified in the
scoping phase focusing on key impacts
Recommend appropriate measures to mitigate negative impacts and enhance the
benefits and include them in the draft EMP
Undertake a public participation process that provides opportunities for all
interested and affected parties (IampAPs) to be involved
32 AUTHORITY CONSULTATION
The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental
Liaison Committeersquo (ELC) which comprises representatives of various authorities
including DEDEAT the Department of Environmental Affairs (DEA) and Department
of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the
Coega Development Corporation (CDC) and Transnet National Ports Authority
(TNPA) The ELC has been specifically formed to facilitate EIA applications in the
IDZ
Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to
the clearance of vegetation should be included in the application A formal request
was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the
application and all registered stakeholders were informed of the request in writing on
19 October 2011
33 PUBLIC PARTICIPATION PROCESS CONDUCTED
On-site notices were replaced by a notification displayed on the CDCrsquos digital notice
board at the business centre in Zone 1 of the IDZ The eNotice was placed on
13 April 2011 and will remain for the full duration of the EIA process
Registered stakeholders will be notified in writing of the availability of the draft EIA
report and EMP which will also be advertised in a local newspaper Stakeholders
including state departments and the public will have forty (40) days to comment on
the draft EIA report and EMP The draft EIA report and EMP will be sent by email
where possible and made available for download on the ILISO website
(wwwilisocom)
A summary of all issues and comments received during the stakeholder consultation
process as well as of correspondence in that regard will be captured in an Issues
and Responses Report that will form an Appendix to the EIA Report
The list of registered IampAPs is included in Appendix A
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 3-2
34 LEGISLATION AND GUIDELINES CONSIDERED
The following legislation and guidelines were considered in the preparation of this
report
National Environmental Management Act Act No 107 of 1998
NEMA EIA Regulations 2010
National Environmental Management Air Quality Act Act No 39 of 2004
National Environmental Management Waste Act Act No 59 of 2008
Hazardous Substances Act Act 15 of 1993
Occupational Health and Safety Act Act 85 of 1993
Hazardous Chemical Substances Regulations 1995 (GNR 1179)
Major Hazard Installation Regulations 2001 (GNR 692)
National Water Act Act 36 of 1998
National Heritage Resources Act Act 25 of 1999
DEAT Integrated Environmental Management Information Series 1-5 and 12-15
NEMA draft Implementation Guideline
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Public Participation (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Alternatives (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Draft Guideline for Determining the Scope of Specialist
Involvement in EIA Processes (2005)
IAIA guidelines
National air quality standard for thoracic particulates Government Gazette
No 32816
Listed activities and associated minimum standards identified in terms of section
21 of the National Environmental Management Air Quality Act Act No 39 of
2004 Government Notice 248 of 2009
Minimum Requirements for the Handling Classification and Disposal of
Hazardous Waste DWAF Waste Management Series (1998)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-1
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION
The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega
IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay
to the north of the N2 highway between Port Elizabeth and Grahamstown east of the
Coega River
The co-ordinates of the corners of the site are shown in Table 1
Table 1 Coordinates of site corners for the proposed galvanizing plant
Point Longitude Latitude
A 25deg411126E 33deg45587S
B 25deg411156E 33deg45499S
C 25deg411938E 33deg45131S
D 25deg412174E 33deg45481S
E 25deg412508E 33deg45979S
F 25deg412634E 33deg451160S
G 25deg411782E 33deg451560S
H 25deg411692E 33deg451428S
J 25deg411314E 33deg45868S
Figure 4 Zone layout in the Coega IDZ
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-2
Figure 5 Site location
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-3
42 SOCIO-ECONOMIC CHARACTERISTICS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the
NMBM There are no residents within the IDZ
As far as the broader NMBM and Eastern Cape Province are concerned the
following can be noted The NMBM is located within the Eastern Cape Province the
2nd largest Province in South Africa (3rd in terms of population) characterised by a
predominantly black population with low incomes and high levels of unemployment
(CES 2010)
The NMBM has a population of just above 11 million and covers an area of
1 950 km2 It is the main urban and industrial centre of the province and Port
Elizabeth in particular which forms part of the NMBM is the commercial capital of
the Eastern Cape 52 of the NMBM population is female and 37 is below the
age of 20 these two groups are particularly affected by unemployment
43 BIOPHYSICAL CHARACTERISTICS
431 Surface and ground water
No rivers occur in Zone 6 There is however a natural attenuation pond on the
southern most part of the site which will have to be avoided
The IDZ is underlain by calcrete sand and gravel deposits that overlie low
permeability clays These clays limit the vertical infiltration of rainwater and induce a
horizontal groundwater flow towards the Coega River channel which is the most
significant surface water feature in the Coega IDZ Consequently rapid run-off takes
place following precipitation (Jacobs 2008)
Groundwater levels at Coega are generally about 3 to 5 m below surface ie just
above the contact between the permeable sands and the underlying impermeable
clays The groundwater flow direction is to the southeast following the surface water
drainage direction (Jacobs 2008)
432 Climate and atmospheric conditions
Port Elizabeth has a warm temperate climate and the temperature ranges are not
extreme Exceptionally high temperatures may be experienced during berg wind
conditions which occur frequently during autumn and winter Extreme temperatures
also occur during summer with little accompanying wind
The wind regime for the area largely reflects the synoptic scale circulation with
dominant westerly and northwesterly flow fields representing the pre-frontal
conditions and south-westerly flow fields representing the frontal conditions The
south-easterly and south-westerly wind flow (land breeze) increases during daytime
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-4
conditions with westerly and north-westerly wind flow increasing during the night (sea
breeze)
The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of
Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15
km southwest) and Port Elizabeth (~23 km southwest)
An ambient air monitoring network has been established in the Coega IDZ which
consists of three monitors Saltworks Motherwell and Amsterdamplein Although
NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative
impacts due to the proposed Galvanising Plant is PM10 A maximum daily average
PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed
SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3
was exceeded on 17 days in 2007 and 26 days in 2008
Existing sources of emissions in the vicinity of the proposed galvanizing plant include
industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other
fugitive dust sources (von Gruenewaldt 2011b)
433 Geology and soils
Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel
and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly
limestone and conglomerate
434 Terrestrial ecology
This section draws from the EIA report compiled for the Agni Steel (formerly Afro-
Asia) steel processing facility which is adjacent to the proposed site for the
galvanizing plant (Jacobs 2008)
The area consists largely of grasses succulents and scrubby bush with alien
species making up the greater part of the more dense vegetation
Zone 6 falls within the inland vegetation and is characterised by a vegetation type
referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the
Coega IDZ and has been found to have three times the level of endemism of other
vegetation communities in the Coega IDZ Bontveld therefore has a high
conservation status Two Bontveld conservation areas have been identified within the
IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)
Bontveld that will be destroyed as a result of development in the IDZ will be given
conservation status in these two areas
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-5
Figure 6 Coega IDZ Open Space Management Plan (OSMP)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-6
Certain areas in the IDZ are invaded by alien plant species The most common
invader species is rooikrans (Acacia cyclops) which presently forms large
monospecific stands in areas throughout the Coega IDZ There are several other
aliens present that pose a threat to the flora of this area including the prickly pear
(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)
Loss of vegetation and alien plant invasion due to human activity has resulted in a
reduction in the diversity of terrestrial fauna
The majority of mammals present in the Coega IDZ are small or medium-sized Of
the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed
gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of
Algoa Bay however it is not considered threatened The gerbil is common in
foredune and dune thicket habitat in the Coega region and is therefore unlikely to
occur on the proposed site
A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird
species are resident or common to the area Most diversity occurs in the thicket
although the coastal area also supports specialised avifauna Two species of tern
the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well
as the Cape gannet (Morus capensis) and the African penguin (Spheniscus
demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne
caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant
(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser
flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns
are two of the most endangered coastal species in South Africa Other bird species
of conservation concern include the Whitefronted plover (Charadrius marginatus)
African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus
bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus
ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides
paradisea) Breeding pairs of Damara terns and African black oyster catchers have
been observed in the coastal dunes of the IDZ but should not be affected by
developments that fall outside the dune areas
The Eastern Cape supports nearly a third (approximately 133 species) of the reptile
species recorded in South Africa More than half of the Eastern Capersquos endemic
reptile species occur in the Algoa Bay area giving the region a high conservation
value A total of 63 reptile species are believed to occur within the Coega IDZ The
majority of these are found in Succulent Thicket and riverine habitats Only a few
reptile species occur in the coastal dunes and estuarine habitats More than a third of
the species are described as relatively tolerant of disturbed environments provided
that migration corridors of suitable habitat are maintained to link pristine habitats
Twenty two reptiles are of special concern including five endemic species (two of
which may also be endangered) four endangered sea turtles eight species listed
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-7
with CITES one rare species and four species at the periphery of their range
Fourteen of these species of special concern are confirmed as occurring on or within
2 km of the Coega IDZ
A total of 32 amphibian species and sub-species occur in the Eastern Cape
representing almost a third of the species recorded in South Africa However none of
the species are endemic or Red Data Book species Based on previous studies in the
area it is estimated that approximately 17 amphibian species occur within the Coega
IDZ Four species are listed as peripheral but none are threatened internationally
These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog
(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and
the bubbling kassina (Kassina senegalensis)
The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated
vegetation has not been extensively studied One grasshopper species Acrotylos
hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue
(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis
pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in
four localities in the Eastern Cape one of which is within the Coega IDZ The Coega
copper Aloeides clarki is endemic to this particular region of the Eastern Cape and
is currently known to occur in three localities two of which are in the Coega IDZ The
localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the
Coega IDZ and their distributions were taken into account when defining Coegarsquos
open space system and Development Framework Plan
435 Land use and topography
The land is currently undeveloped and earmarked for industrial development The
site is relatively flat ranging from an elevation of 66 masl on the northern-most
corner to 59 masl at the southern-most corner
436 Heritage and archaeological survey
Extensive studies have been undertaken in Zone 6 with respect to heritage aspects
Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a
2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond
2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is
currently being finalised
Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing
Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha
in extent and was located next to the R102 road to Motherwell Kaplan conducted
HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi
Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will
now be located in Zone 5)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-8
The various archaeological investigations reached similar observations and
conclusions Stone tools of various densities and types were found throughout the
zone The majority of the stone tools were mainly of Earlier and Middle Stone Age
and occasional Later Stone Age origins (Figure 4)
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble
gravels exposed by tracks in Zone 6 (Source Binneman 2010)
The stone tools which comprised of quartzite flakes chunks flaked pebblecobble
and cores were randomly distributed across the landscape and are in secondary
context There were no lsquoconcentrationsrsquo of tools observed which suggested any
spatial patterning or activity areas although these may be present or covered by soil
and vegetation
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 5-1
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED
The following environmental issues and potential impacts were identified in the
Scoping phase
51 AIR QUALITY
The galvanizing process generates atmospheric emissions with particulates and
hydrogen chloride representing the main pollutants of concern The plant is fitted with
air extraction as well as scrubber systems which are designed to retain the bulk of
pollutants and particles for each of the processes in such a way that less than 5 ppm
of gases and particles will be released into the atmosphere after the fume scrubber
Other sources of impact on air quality include emissions from the LNG burner as well
as emissions and dust from the transport of steel and other materials in trucks
Construction activities will also create dust and gas emissions due to the clearing of
groundcover tipping of material to storage pile levelling of area wind erosion from
storage piles vehicle and construction equipment activity and tailpipe emissions
from vehicles and construction equipment such as graders scrapers and dozers
Overall the air quality impact assessment (Gruenewaldt 2011b) found that
The predicted particulate oxides of nitrogen carbon monoxide and sulphur
dioxide concentrations are all below the National Ambient Air Quality Standards
for all averaging periods
The predicted off-site concentrations of hydrogen chloride are well below the
most stringent effect screening levels
No odour threshold exceedances for hydrogen chloride were predicted to occur
due to routine operations at the Steel Galvanising Plant The South Wales
Environmental Protection Authority stipulates that an odour unit of 20 is
acceptable for urban areas The odour unit would be lt10 directly off-site for
hydrogen chloride
Abnormal emissions can occur in exceptional circumstances Start-up will not
cause abnormal emissions as the scrubbers will be commissioned first and will be
functioning once the plant starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions would be emitted as a
building fugitive
The hourly hydrogen chloride ground level concentrations (directly offsite) were
predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based
on the emission limits as stipulated for listed activities for galvanising processes)
using a screen model which assumes worst case meteorological conditions The
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-2
health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming
abnormal emissions emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset conditions will still
be well within the health effect screening levels
Similarly the hourly particulate emissions from the building fugitives during upset
conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for
listed activities for galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly
off-site
Therefore if emissions are 5 times higher normal they will still be within health effect
screening levels and the daily PM10 NAAQS levels
In the case of a fire a cocktail of gases and particulates could be emitted and could
be over the recommended levels This situation will however be dealt with as an
emergency and normalised as quickly as is possible
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS
The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of
its heritage potential and there are no proposed protected geosites in Zone 6
Should any artefacts be discovered during construction procedures stipulated in the
draft EMP will apply
53 BIODIVERSITY AND CONSERVATION
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
In terms of terrestrial fauna the CDCrsquos open space management plan provides for
the preservation of certain corridors The destruction of certain habitats as a result of
the development will therefore not automatically result in the loss of certain species
54 WATER QUALITY
There is a natural attenuation pond on the southern most part of the site which will be
avoided
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through
spills or leaks
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-3
This risk can however be minimized if not avoided altogether The floor of the factory
will be designed as a bunded area to contain any spills and the entire process will be
contained Potential spills or leaks will therefore be contained and will not impact on
water resources Storm water is therefore considered clean water under normal
operational conditions An oil trap will be placed at the exit of the site to ensure that
no grease from the laydown area enters the stormwater system
Spills and leaks can occur during the handling or the transport of hazardous
substances Best practice guidelines will be followed to ensure that this risk is
adequately managed
Wastewater discharged to sewer will be treated to comply with municipal discharge
standards and is not expected to have an impact on the chemical characteristics of
the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be
discharged from the plant is small in relation to the total volume received at the
Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works
(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently
operated at 61 of its capacity which is approximately 80 Mℓday Thus the
0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore
not have any significant impact on the WWTW
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES
The plant will generate a relatively small amount of solid waste in the form of scrap
metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)
The scrap metal may be sold to other steel processing facilities such as Agni Steel
which will be located next to the plant or collected and disposed of with the rest of
the solid waste by a licensed service provider
As mentioned previously there will be a wastewater treatment plant on site which will
neutralise process water (012 Mlweek) in order to ensure it is of a standard
acceptable for discharge to sewer Waste in the form of sludge from the
neutralization or spent acid must be disposed of as a hazardous waste Solid waste
from the filters used for air quality control is also in this category These wastes can
usually be tested and then delisted which means that it can be placed in a general
purpose landfill
Hazardous effluent from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-
site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored
and removed on a monthly basis is limited to 10 m3
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-4
A number of substances classified as hazardous are used in the galvanizing process
(Table 2) and the transport and handling of these is subject to certain rules and
guidelines In particular the material safety data sheets (cf Appendix H) should be
referred to for inter alia hazards identification accidental release measures
handling and storage precautions exposure controlpersonal protection ecological
information and transport information The Hazardous Chemical Substances
Regulations 1995 should also be adhered to in respect of the transport and storage
of hazardous chemical substances
Table 2 Hazardous materials to be used on site
Major Input Materials
Substance
listed in the
SABS 0228
Group II
hazardous
substances
Volumes to be
stored on site at
any one time
Diesel radic 2000 litres
Liquid petroleum radic 20 000 liters
Sodium hydroxide (NaOH)
(used for degreasing) 8 radic 1000m
3
Hydrochloric acid (HCI)
(used for pickling) 8 radic 800m
3
Zinc (used for galvanising) - TBD
Trivalent chromium (CR+3
)
(used for chromating) 8 radic 10m
3
Sulphuric acid (H2SO4) (used for
treatment of waste water on site) 8 radic TBD
Ammonium Hydroxide (NH4OH) 8 radic TBD
TBD ndash To be determined
Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one
time) and is classified as a flammable substance Specification for flammable storage
facilities in accordance with the requirements of the Nelson Mandela Bay
Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for
quantities between 5000 and 20 000 liters the substance must be kept in a
flammable liquid store which complies with the requirements of a specification
obtainable from the Department Some of the requirements are
Flammable liquid and solid storage facilities are only permitted on the ground
floor
Decanting of flammable liquids and solids are not permitted within any building
Due to the fact that there are flammable materials on site a certificate may be
required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and
Emergency Services Department to confirm that facilities for flammable storage
are in accordance with their requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-5
Because of the permanent installation and high quantity of liquid petroleum on site
the Major Hazard Installation Regulations 2001 promulgated under the Occupational
Health and Safety Act No 85 of 1993 applies A written application for approval of
the installation is required to be submitted to the chief inspector Department of
Labour provincial director Department of Labour and NMBM prior to construction
In addition a risk assessment should be formulated covering all hazardous materials
together with an emergency preparedness and response plan
56 HEALTH AND SAFETY
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling instructions as well as occupational exposure limits
are indicated in the material safety data sheets of the various substances used
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as
provide site supervision including executing tests (individual test cold run and hot
run) during 3 months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the
EMP
In addition the emergency preparedness and response plan will cover the health and
safety aspects related to emergency situations
57 TRAFFIC
The volumes of traffic at the IDZ are currently relatively low and variable depending
on the different zones in the IDZ however these volumes will increase as more
developments are implemented
The construction phase of the Casa Steel development will take about 12 months
and will essentially consist of erecting a building to house the galvanizing line and
other equipment and preparing a concrete laydown area adjacent to the building
The traffic that would be generated during the construction phase can be expected to
be less than the traffic that would be generated by the Casa Steel development when
it is fully operational
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-6
In the operation phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and
from the Port of Ngqura
The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the
Casa Steel development would be off Ring Road 1 The other roads of significance
for the Casa Steel development are the N2 Neptune Road MR435 and MR450
Access to the port is given by Neptune Road Road Link NEP-03 has not yet been
built
Figure 8 Coega IDZ road network identification
(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-7
Figure 9 Coega IDZ road network
Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No
01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-8
The distribution of freight trips is fixed as the majority of trips will be made between
the Port of Ngqura and the Casa Steel site With regard to personnel trips there are
various points of origins (the surrounding residential areas) that could be used by
staff going to the Casa Steel site The distribution of personnel trips is based on
existing traffic count information and is shown in Figure 10
Figure 10 Trip distribution for freight and personnel trips
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The resultant expected Casa Steel traffic assignment is shown in Figure 11
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-9
Figure 11 Morning peak hour Casa Steel development traffic
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The traffic that is expected to be generated by the Casa Steel development is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low
and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)
Consultation has taken place with Transnet Port Authority (TPA) to establish the
impact of the galvanizing plant operations on traffic inside the port The additional
ships entering and exiting the port of Ngqura as a result of the proposed development
will have a negligible impact on port traffic and TPA indicated that it would be well
within the portrsquos capacity
58 NOISE
Noise is not foreseen to be a significant issue insofar as the noise levels inside the
plant and at the boundary of the site will not exceed the limits prescribed by the CDC
Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels
during the day and 60 decibels at night
Mitigation of noise impacts will be addressed in the design of the noise-emitting
components of the plant and their enclosures
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-10
59 SOCIO-ECONOMIC ASPECTS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of
NMBM There are no residents within the IDZ
The direct socio-economic impacts of the proposed project are thus limited to the
employment generated by the project during construction and operation Job creation
remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)
and the IDZ and Port of Ngqura are expected to become a significant catalyst to the
economic growth of the Municipality and the region with current investments at
Coega creating more jobs and stimulating the economy
In this context the proposed galvanizing plant will make a positive contribution
towards the achievement of these goals
There will be 50 to 60 employees during operation phase distributed as follows
Figure 12 Casa Steel organisation chart
Even though a large part of the inputs will be imported and the bulk of the production
output will be exported there will be some positive impacts for the economy of the
region and of South Africa in general Notably the requirements of the plant for
water electricity waste collection and disposal waste water treatment and transport
for example will create business for the various service providers and have an
indirect impact on employment and fiscal revenues as a result
From a visual impact point of view it can be anticipated that the landscape in the IDZ
will be significantly affected over time by developments related to the establishment
of the port and various industries
HEAD ( WORKS )
MGR ( COMM) MGR ( ADMNHR ) Manager marketing
MANAGER OPERATION MANAGER MANAGER MANAGER Q C
AC FIN PUR ampSTORE
PPC SH-GALV SH-tech
SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF
1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO
JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF
2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO
WORKERS WORKERS 7NOS
15 7
RAW MAT amp
DESP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 6-1
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
A description of the nature of the impact any specific legal requirements and the
stage (constructiondecommissioning or operation) will be given Impacts are
considered to be the same during construction and decommissioning The
significance of the potential impacts will be considered before and after identified
mitigation is implemented
The following criteria will be used to evaluate significance
Nature The nature of the impact will be classified as positive or negative and
direct or indirect
Extent and location Magnitude of the impact and is classified as
Local the impacted area is only at the site ndash the actual extent of the activity
Regional the impacted area extends to the surrounding immediate and
neighbouring properties
National the impact can be considered to be of national importance
Duration This measures the lifetime of the impact and is classified as
o Short term the impact will be for 0 ndash 3 years or only last for the period of
construction
o Medium term three to ten years
o Long term longer than 10 years or the impact will continue for the entire
operational lifetime of the project
o Permanent this applies to the impact that will remain after the operational
lifetime of the project
Intensity This is the degree to which the project affects or changes the
environment and is classified as
o Low the change is slight and often not noticeable and the natural functioning
of the environment is not affected
o Medium The environment is remarkably altered but still functions in a
modified way
o High Functioning of the affected environment is disturbed and can cease
Probability This is the likelihood or the chances that the impact will occur and
is classified as
o Low during the normal operation of the project no impacts are expected
o Medium the impact is likely to occur if extra care is not taken to mitigate
them
o High the environment will be affected irrespectively in some cases such
impact can be reduced
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 6-2
Confidence This is the level knowledgeinformation the environmental impact
practitioner or a specialist had in hisher judgement and is rated as
o Low the judgement is based on intuition and not on knowledge or
information
o Medium common sense and general knowledge informs the decision
o High Scientific and or proven information has been used to give such a
judgment
Significance Based on the above criteria the significance of issues will be
determined This is the importance of the impact in terms of physical extent and
time scale and is rated as
o Low the impacts are less important
o Medium the impacts are important and require attention mitigation is
required to reduce the negative impacts
o High the impacts are of great importance Mitigation is therefore crucial
Cumulative Impacts The possible cumulative impacts will also be considered
Mitigation Mitigation for significant issues is incorporated into the EMP for
construction
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 7-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS
71 IMPACTS DURING CONSTRUCTION
711 Air quality
Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris
handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine
particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural
operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks
and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)
Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Fugitive particulate emissions (dust)
related to construction activities Regional
Short
term Medium High High Medium Regional
Short
term Low High High Low
Construction vehicle gas emissions Regional Short
term Medium High High Medium Regional
Short
term Low High High Low
712 Heritage and archaeological resources
Naturedescription of impact excavation activities may impact on unidentified heritage resources
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-2
Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based
on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments
Heritage and archaeological
resources Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on unidentified heritage
resources Local
Short
term
Medium -
high Low High Low
713 Biodiversity and conservation
Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation
importance and cause soil contamination
Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species
Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan
and has compiled a list of protected species to be rescued (see draft EMP)
Biodiversity and conservation Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Loss of fauna and flora Local Perma
nent
Medium -
high High High High Local
Permanen
t Medium High High Medium
Soil contamination Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-3
714 Water related impacts
Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater
runoff spills and leaks Soil erosion
Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of
spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste
disposal Stormwater quality monitoring (see draft EMP)
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Soil erosion Local Short
term Medium Medium High Medium Local
Short
term Medium Low High Low
715 Waste management
Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed
Commentmitigation see draft EMP and waste management plan
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-4
Waste management Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Local
Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
716 Health and safety
Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Short
term
Medium -
high
Medium -
high High High Local
Short
term
Medium -
high Low High Low
717 Traffic
Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and
construction workers from surrounding areas and transport of equipment from the port
Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low
Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and
accurate estimates of quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-5
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Increased traffic on N2 and within the
IDZ Regional
Short
term Low High High Low
718 Noise
Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Short
term
Medium-
high High High Medium Local
Short
term Medium High High Medium
719 Socio-economic
Naturedescription of impact temporary employment will be created during the construction phase
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-6
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Temporary employment Regional Short
term Medium High High Medium
72 IMPACTS DURING OPERATION
721 Air quality
NatureDescription of impact gas and particulate emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning
Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local
sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and
veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute
to background fine particulate concentrations (von Gruenewaldt 2011b)
Assumptions and limitations Potential release of CR6+
As no emission factors are available for trivalent chromium processing the
potential impacts due to these activities could not be quantified
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Dust emitted from traffic on paved roads Regional Long Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-7
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
term
Hydrogen chloride emissions from
pickling process Local
Long
term Low High High Low
Particulate emissions (smoke) from
galvanizing process (due to the
volatilization of flux)
Local Long
term Low High High Low
Particulate oxides of nitrogen carbon
monoxide and sulphur dioxide emissions
from LNG burner
Local Long
term Low High High Low
Nuisance related to odour Local Long
term Low Low High Low
Abnormally high hydrogen chloride and
particulate emissions due to scrubber
malfunction
Local Short
term Medium Low High Medium
Gases (eg SOx NOx CO etc) and
smoke emitted in case of a fire Local
Short
term High Low High Medium
722 Water quality
NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks
Commentmitigation see draft EMP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-8
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Stormwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
723 Waste management and hazardous substances
NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous
waste both can affect environmental quality and human health
Commentmitigation see draft EMP and waste management plan
Waste management and hazardous
substances Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Regional
Long
term High
Medium -
high High High Regional Long term High Low High Low
Soilwaterair pollution due to improper
transport storage and handling of
hazardous substances
Regional Long
term High
Medium -
high High High Regional Long term High Low High Low
Health hazard Local Long
term High
Medium -
high High High Local Long term High Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-9
724 Health and safety
Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Long
term
Medium-
high
Medium-
high High High Local Long term
Medium-
high Low High Low
725 Traffic
Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on
the road network
Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak
hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road
network within Zone 6 of the IDZ (Iliso 2011)
Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)
Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of
quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-10
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on traffic and capacity of the N2 Regional Long
term Low High High Low
Impact on traffic and capacity of ring
road 1 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR435 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR450 Local
Long
term Low High High Low
Impact on traffic and capacity of
Neptune road Local
Long
term Low High High Low
726 Noise
Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Long
term Medium High High Medium Local Long term Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-11
727 Socio-economic
Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate
revenue for the municipality and the region as a whole
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Employment and economic growth Regional Short
term Medium High High Medium
73 COMPARATIVE ASSESSMENT OF IMPACTS
During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as
low during operation after mitigation
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 8-1
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
As a tenant operating in the IDZ Casa Steel will be required to comply with all
current and future CDC requirements as well as with the relevant conditions of
permits licences issued to CDC (eg Integrated Stormwater Masterplan for the
eastern side of the Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)
In particular the CDC has its own requirements regarding the monitoring of certain
aspects of the project such as the quality of the effluent and the noise levels These
have been incorporated into the EMP
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 9-1
9 ENVIRONMENTAL IMPACT STATEMENT
All predicted negative impacts can be mitigated to a low significance The only
exceptions are biodiversity as the construction of the plant will result in the
destruction of habitat and loss of fauna and flora and noise impacts inherent to
construction activities Mitigation measures have been included in the EMP for these
impacts and they have a medium significance post-mitigation
Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium to
long term similar impacts are likely to occur due to ongoing developments in the IDZ
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 10-1
10 CONCLUSION AND RECOMMENDATIONS
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as
other infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified
and assessed No fatal flaws have been identified
It is recommended that the project be approved subject to the conditions listed in
chapter 9 and adherence to the EMP requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 11-1
11 REFERENCES
Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ
Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants
Bennie JS (2010) The historical component (built environment) of the Heritage
Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port
Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report
compiled for Eastern Cape Heritage Consultants
Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater
Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay
Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage
Consultants
BKS (2006) Coega Industrial Development Zone Transport Study Volume 3
Demand Modelling Report Final Draft
Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I
Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6
Report compiled for SRK Consulting
Coastal amp Environmental Services (2010) Environmental Impact Assessment for the
Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone
Volume 3 Environmental Impact Assessment Report CES Grahamstown
Coega Development Corporation (2008) Industry Waste Management Plan -
Strategic Master Plan Report
Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants
Report No CDCSHE 03 8122
Department of Water Affairs and Forestry (1998) Waste Management Series
ldquoMinimum Requirements For The Handling Classification And Disposal Of
Hazardous Wasterdquo Second Edition
Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising
Plant in the Coega Industrial Development Zone
Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the
Coega Industrial Development Zone (IDZ) Specialist Water Study
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 11-2
Jacobs E (2008) Final Environmental Impact Report and Draft Environmental
Management Plan Proposed Steel Recycling and Processing Facility within the
Coega IDZ Report compiled for SRK Consulting
Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY
Galvanising Plant in the Coega Industrial Development Zone Waste Management
and Hazardous Substances Report compiled for ILISO Consulting
RSA National air quality standard for thoracic particulates (PM10) SA standards
(Government Gazette No 32816)
von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed
Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape
Report compiled for ILISO Consulting
von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel
Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report
compiled for ILISO Consulting
Additional sources
Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed
Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared
for Coastal Environmental Services
Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed
Kalagadi Manganese smelter in the Coega Industrial Development Zone Port
Elizabeth Eastern Cape Province Report prepared for Coastal Environmental
Services
Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia
steel recycling facility at the Coega Industrial Development Area Port Elizabeth
Prepared for SRK Consulting Port Elizabeth
APPENDIX A
LIST OF INTERESTED AND
AFFECTED PARTIES
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
DEDEARegional Manager
and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza
DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza
DEA Ocean and
CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza
DEA Ocean and
Coast
Oceanographer land-
based sources of
marine pollution
Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza
DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza
CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza
CDCEnvironmental
Project
Manager
Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza
TNPAPort of Ngqura
Environmental
Manager
Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet
NMBMEnvironmental
ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza
NMBMEnvironmental
ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza
DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza
DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza
WESSASenior Conservation
Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza
Zwartkops
ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700
hughlauegmailcom
zwartkopstrustiafricacom
SANParksNational Marine
CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza
Department Of
LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza
NMBM Air Quality
Division
Assistant
DirectorAir
Pollution and Noise
Templeton Titima 079 490 0574 Ttitimamandelametrogovza
NMBM Air Quality
DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza
NUMSARegional
RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
Department of
HealthNadiema
van der
Bergh083 378 2103
nadiemavanderberghimpiloecprovgov
za
DWA Chief Services
Officer
Joseph Jacobs 041 586 4884 jjacobsdwafgovza
EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza
NUMSecretary of union
officesZandile Xhentsa 043 743 6597 zxhentsanumorgza
DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza
Dynamic
CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom
EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza
Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza
UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom
lprincezago2uticom
Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza
Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza
Absa Mr Johann Steyn 082 3775820 johannstabsacoza
Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza
PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza
Universal
EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza
Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza
GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom
Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza
NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom
DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza
DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza
TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet
DWA Mr Landile Jack JackLdwagovza
DWA Ms Lizna Fourie FourieL4dwagovza
APPENDIX B
NOTICE OF ATMOSPHERIC
EMISSIONS LICENCE APPLICATION
AND ADVERTISEMENT
APPENDIX C
NOTICE OF COMMENT PERIOD FOR
DRAFT SCOPING REPORT
APPENDIX D
SUMMARY OF ISSUES RAISED AND
RESPONSES THERETO
April 2012
1
PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL
DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))
IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt
AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt
This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses
provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process
conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the
Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
2
IssueCommentQuestion Date
received Origin Response
1 Please provide more information with respect to the potential
dangers including the toxicity of the proposed project
07032011
By email
Wayne Poulton
(Bosun Brick
tenant at the
IDZ)
An Environmental Impact Assessment (EIA) was undertaken
which assessed the potential toxicity of the emissions and
effluent Mitigation measures were also recommended in the draft
Environmental Management Programme (EMP) to avoid
minimise or compensate any significant impacts The Draft
Environmental Impact Report and draft EMP were made available
to stakeholders for comment in March 2012
2 Do you have a Background Information Document (BID) or
similar that provides more information on the project
27032011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The BID was sent to all registered IampAPs on 4 May 2011
3 The RoD issued to the CDC on 632007 for the change in
land use for the remaining area of the Coega IDZ includes a
number of requirements with respect to
atmospheric emissions that should be considered in the
Atmospheric Emissions Licence (AEL) application such as
prohibiting and monitoring where possible visible emission
plumes to the atmosphere In particular the
recommendations on pp87-91 of the final revised Scoping
Report dated Nov 2006 must be implemented (clause 421)
04042011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
We have obtained copies of the documents referred to and ensure
that these requirements were taken into account in the
environmental assessment and AEL application
4 If the Port of Ngqura is used for import and export the scope
of the traffic impact assessment (TIA) should also include the
port
10052011
By email
Elliot
Motsoahole
(TNPA Port of
Ngqura)
The scope of the TIA was extended to include port related traffic
The TNPA at the Port of Ngqura was consulted and does not
have any objection to the project TNPA has indicated that the
development would require a minimum number of vessels per
year which would have minimal impact on the Port operations
However due notice would have to be given to the Port of Ngqura
before a vessel is scheduled to arrive so that the vessel can be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
3
IssueCommentQuestion Date
received Origin Response
accommodated at an available berth
5 Concerns with respect to potential stormwater pollution
draining into the Coega catchment and the port of Ngqura
The port needs to be dredged and heavy metals present a
risk in that regard
16052011
By
telephone
Andrew Lucas
(Department of
Water Affairs)
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination by effluent waste or
hazardousdangerous substances is very low
Thus no metals oils or other contaminants are expected to be
present in the stormwater
However stormwater pollution can occur in exceptional
circumstances such as accidents and emergencies The
emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
6 All steel sheets bathing unit must be under roof
7 The sludge out of the decreasing bath will be high in Na and
pH Therefore handling and disposal must be clarified up front
in this project
8 Per se the wastewater from decreasing bath will have high
ph and the component from the pickling unit will have low ph
Then it may be assumed that both streams will neutralize
each other Please then clarify proposed sewer discharge
with Nelson Mandela Bay Municipality up-front for acceptance
of influent as per the documented proposal
9 Pickling may result in dissolved metals How does your team
expect to deal with this As it is planned for discharge into
24052011
By email
Landile Jack
(Department of
Water Affairs)
All bathing units will be under roof
Effluent from the degreasing and pickling baths will be discharged
to the wastewater treatment plant The respectively alkaline and
acidic effluents will mix and neutralise each other in the
wastewater treatment plant Calcium or gypsum will be added if
required to complete the neutralisation process Effluent from the
treatment plant will be discharged to sewer Contact has been
made with the relevant officials and the Municipalityrsquos
requirements have been obtained The effluent discharged to
sewer will notably comply with the applicable discharge standards
Traces of metals (eg iron) may be present but will not exceed
prescribed thresholds The necessary authorisation will be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
4
IssueCommentQuestion Date
received Origin Response
sewer Clarity and acceptance needs to be agreed with
Nelson Mandela Bay Municipality Who owns the sewer
10 Quenching unit will results to Zinc particles How will this
affect sewer discharge This again must be dealt with within
the negotiations with the Municipality
11 Once all has been agreed with the Municipality and at the
same time due negotiations must be done with hazardous
waste courier and disposal facility to accept the hazardous
waste identified in all production lines
12 Of note is the low volume of the proposed WWTW facility ie
250 cubmweek And the no discharge of the quenching
water ie over-flow and cooling only Hence Zinc particles
generation
obtained from the municipality
The sludge from the treatment plant will be collected by a licensed
service provider and disposed of at a permitted site
The quenching bath will be periodically emptied (every 6 months)
and the water discharged will go to the water treatment plant Zinc
particles will settle in the sludge which will be disposed of at a
permitted site
Contact has been made with EnviroServ who manages the
Aloes II HH waste site regarding collection and disposal of
hazardous waste (See waste management report)
13 Investigate the potential effects of toxicity andor influence of
emissions waste and hazardous substances both in
terrestrial and marine fauna
14 With regards to water usage where is the plant going to
extract its waters used in galvanization andor waste
management process ie rainfall rivers or even from the
sea) and which avenues would be more environmental
friendly and effective
31052011
By email
A Bewana
(SANPARKS)
Emissions waste and hazardous substances are not expected to
affect terrestrial or marine ecosystems The air quality study
concluded that atmospheric emissions would not be harmful to
human health and by extension terrestrial fauna There are no
standards for air quality for defining faunal impacts therefore by
ensuring that standards for humans are complied with the impact
on fauna is deemed to be acceptable In this case the impact of
emissions on terrestrial and marine fauna are thus not significant
Solid and liquid wastes both general and hazardous as well as
hazardous substances will be stored handled and disposed of
appropriately to as not to cause harm to terrestrial or marine
fauna
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
5
IssueCommentQuestion Date
received Origin Response
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination and hence land-based
marine pollution by effluent waste or hazardousdangerous
substances is very low
The risk of emissions waste and hazardous substances to
terrestrial and marine fauna is thus very low
However pollution of terrestrial and marine ecosystems can occur
in exceptional circumstances such as accidents and emergencies
The emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
The CDC has an agreement with the NMBM to supply potable
water to the Coega IDZ Currently the infrastructure to supply
return effluent (RE) to the IDZ is not in place therefore Casa Steel
will be supplied with potable water up until such time as the
following 2 options of RE are available
1) Upgrading of the existing Fishwater Flats waste water
treatment works (between IDZ amp PE) including RE plant
and infrastructure to pipe RE to the IDZ (EIA for the
upgrade is underway)
2) Construction of a new waste water treatment works
including RE plant in Zone 9 of the Coega IDZ
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option should be investigated further between Agni and Casa The
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
6
IssueCommentQuestion Date
received Origin Response
CDC can facilitate discussions between the 2 investors
Compliance with CDC Permits amp Requirements
15 It should be made clear that tenants will be required to
comply with CDC requirements and the relevant conditions of
permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water
Licence for its Storm Water Systems on the
East Side of the Coega River that tenants will
need to take cognizance of The contents of the
ldquoIntegrated Stormwater Masterplan for the
eastern side of the Coega IDZ Oct 2010rdquo
especially the Table of best practice p53
onwards may need to be taken cognizance of
o CDC is developing an Operations
Environmental Management Plan that will place
certain obligations on tenants
16 Environmental audits and data collected during monitoring
(eg stack emissions stormwater) will need to be shared with
CDC
Air Emissions
17 Presumably permanent in stack monitoring will be required in
terms of AEL permit requirements
18 Abnormal operating conditions resulting in air emissions ndash I
could find nothing in the EIR to indicate under what
circumstances these could occur (eg start-up) potential
frequency and duration and the impact on ambient air quality
ndash these events usually result in the most problems wrt air
emissions
09042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
15 Compliance with the CDCrsquos Permits amp Requirements has
been included explicitly as a requirement in the EIR (p8-1) and
EMP (pp18 and 25) in the following terms
ldquoAs a tenant operating in the IDZ Casa Steel will be required to
comply with all current and future CDC requirements as well as
with the relevant conditions of permits licences issued to CDC
(eg Integrated Stormwater Masterplan for the eastern side of the
Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)rdquo
16 The need to communicate with the CDC on monitoring and
auditing activities was emphasised in Chapter 8 of the EMP The
following paragraphs were added
ldquoDuring construction the environmental officer will be responsible
for monitoring compliance with the EMP and authorisation
conditions and keeping records as required in the EMP andor
authorisation conditions
The ECO will conduct site inspections every two weeks audit the
records kept by the environmental officer and submit an
environmental compliance report every two months to the
authorities and the CDC (via the Environmental Monitoring
Committeersquos ECO)
During operation the health and safety officer will monitor
compliance with the EMP and the conditions of the Environmental
Authorisation Data collected during monitoring activities and any
environmental audits conducted will be shared with authorities
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
7
IssueCommentQuestion Date
received Origin Response
Water
19 Large volumes of (2000 m3mth) of water are required of
which only 400m3 needs to be potable The NMBM return
effluent system will provide non-potable water once it is
constructed What other water recycling initiatives can be
utilized to reduce potable water requirements (the ISWMP for
the eastern side of the Coega IDZ has some best practice
guidelines collecting rainwater from the roof etc)
General
20 There is no mention of how the CDC Architectural Guidelines
will be incorporated into the development (eg to prevent a
stark uniform warehouse type development)
21 Does NMBM have adequate fire services to cover this
development Apart from the large petroleum store are there
any other large fire hazards
22 Reports from the tenantrsquos ECO during construction and from
the SHE Officer during operations should be channeled to the
Coega Environmental Monitoring Committee This can be
directly or preferably via the EMCrsquos ECO (this will be while
the EMC and ECO are in place) A precedent has been set
for this in the Environmental Authorisations for Agni-Steel and
Kalagadi Manganese Smelter
23 All mitigation actions emanating from the EIR should be
summarized (preferably in a table) If compliance with them is
to be part of the Environmental Authorization from DEDEAT
then they (or the ones that DEDEAT deems to be applicable)
and the CDC (via the Environmental Monitoring Committeersquos
ECO)
The ECO (during construction) and the health and safety officer
(during operation) will report to the Coega Environmental
Monitoring Committee (EMC) via the EMCrsquos ECO (this will be
while the EMC and ECO are in place)rdquo
17 The draft EMP recommends regular monitoring of emissions
from the scrubbers and from the chromating process Additional
emissions monitoring requirements will be confirmed once the
AEL is issued Mention has been made in the EMP (pp11 and 19)
that all AEL conditions including monitoring and reporting
requirements should be adhered to
18 Abnormal emissions can occur in exceptional circumstances
Start-up will not cause abnormal emissions as the scrubbers
will be commissioned first and will be functioning once the plant
starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions
would be emitted as a building fugitive
The hourly hydrogen chloride ground level concentrations
(directly offsite) were predicted to be 239 microgmsup3 (based on the
emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits
as stipulated for listed activities for galvanising processes) using a
screen model which assumes worst case meteorological
conditions The health effect screening level for hourly HCl
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
8
IssueCommentQuestion Date
received Origin Response
should be attached to the EA as an Appendix (otherwise no
one knows about them or takes cognizance of them)
concentrations is 2100 microgmsup3 Assuming abnormal emissions
emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset
conditions will still be well within the health effect screening
levels
Similarly the hourly particulate emissions from the building
fugitives during upset conditions would amount to 293 microgmsup3
(based on the emission limits as stipulated for listed activities for
galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1
January 2015) directly off-site
Therefore if emissions are 5 times higher normal they will still be
within health effect screening levels and the daily PM10 NAAQS
levels
In the case of a fire a cocktail of gases and particulates could be
emitted and could be over the recommended levels This
situation will however be dealt with as an emergency and
normalised as quickly as is possible
The above has been added to the impact identificationdescription
and assessment sections of the EIR
19 The CDC has an agreement with the NMBM to supply
potable water to the Coega IDZ Currently the infrastructure to
supply return effluent to the IDZ is not in place therefore Casa
Steel will be supplied with potable water up until such time as the
infrastructure is in place
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
9
IssueCommentQuestion Date
received Origin Response
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option will be investigated further between Agni and Casa The
CDC has come forward to facilitate discussions between the two
investors
Other water recycling initiatives such as rainwater harvesting
have been considered but are not practical
20 The CDCrsquos Architectural and Landscape Design guidelines
contain requirements pertaining to such aspects as the height
orientation and mass and form of buildings as well as guidelines
for landscaping and signage in order to ensure an attractive
development and achieve an architectural integrity within the
Coega IDZ The plans for the proposed galvanizing plant will be
submitted to the Design Review Committee for approval as
required by the CDC
21 Casa Steel will be required to install fire hydrants according
to the NMBMrsquos standardsrequirements The CDC will provide
potable water (up until such time as return effluent is available)
and a connection to the boundary of the site which will be
connected to the fire hydrants The installation of the fire hydrants
will require approval by the Metrorsquos Fire Chief as was done for
Agni-Steel one of the investors in Zone 6
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
10
IssueCommentQuestion Date
received Origin Response
The Coega IDZ falls within the NMBM and therefore the rates and
taxes paid by the CDC covers the fire services for which the Metro
is responsible Currently the Metro has sufficient capacity to
provide fire services to the tenants within the IDZ This was
confirmed in discussion with the CDCrsquos Infrastructure
Development Unit It is however unknown at which point the
Metrorsquos Disaster Management Plan would not be able to
accommodate servicing tenants in the IDZ
The LNG burner is the only major fire hazard on the plant
22 See response to item 16 above
23 Key mitigation and management measures emanating from
the EIR were recapitulated in Chapter 9 of the EIR to form part of
the conditions attached to the Environmental Authorization from
DEDEAT All mitigation measures recommended as a result of the
impact assessment are presented in a table in the draft EMP
which is appended to the EIR (Appendix J)
24 Hydrogen chloride is one of the main emissions There are no
ambient air quality guidelines for HCl and the EIR says
concentrations will be well within health parameters
However the main problem with HCl is its corrosive effect -
there is absolutely no mention of this in the draft EIR nor air
specialist report
There needs to be some sort of comment assessment as to
whether HCl emissions are likely to impact on for example
the adjacent Agni-Steel Plant wrt corrosion - their factory
structure will be made of steel
11042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The atmospheric corrosion of metals is a complex process with
both the extent of deterioration and the mechanisms varying
considerably depending on the metal Depending on the way
pollutants are transported from the atmosphere to the corroding
surface two types of deposition processes are recognized in
atmospheric corrosion ndash dry deposition and wet deposition Wet
deposition refers to precipitation whereas dry deposition refers to
the remaining processes including gas phase deposition and
particle deposition The most important pollutants acting as
corrosive agents are sulphur and nitrogen compounds including
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
11
IssueCommentQuestion Date
received Origin Response
The EIR specialist rpt suggests monitoring HCl at ground
level on the property boundary and this is supported in case
there are complaints from neighbours
secondary pollutants and particulates Pollutants can contribute to
corrosivity individually however there may be a synergistic effect
when more than one of these pollutants is present in the
environment being affected In the field of atmospheric corrosion
sulphur dioxide is the single most investigated gaseous pollutant
and the quantification of the direct contribution of sulphur dioxide
to the corrosion process of metallic materials is comparatively well
understood (Tidblad amp Kucera 1998)
Very little work has reported on the effect of HCl on the
degradation of materials in the environment with no local dose-
response thresholds developed for corrosion occurring due to HCl
exposures This is probably because HCl which is present
outdoors in markedly reduced concentrations when compared
with SO2 has not been considered to contribute to significant
degradation of materials (Syed 2006) For this reason the
incremental corrosion due to HCl from the Coega Galvanising
Plant cannot be quantified
25 It is unacceptable for ILISO to be using CDC maps (see
figure 9 ndash pg5-6) without these maps being referenced
accordingly particularly when it appears that a CDC map has
been used and then overlaid with features by an unknown
author (ie CASA steel site Port (where the boundaries
depicted are incorrect) and a North legend which is out of
keeping with the overall cartographic intent of the original
work
26 Figure 10 is not referenced appropriately and I believe that I
commented previously in respect to references to roads not
12042012
By email
Graham Taylor
(Spatial
Development
Manager -
Infrastructure
Development
CDC)
This has been rectified in the final version of the report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
12
IssueCommentQuestion Date
received Origin Response
yet built As a result Figure 10 is confusing and clarity needs
to be provided in terms of referencing In addition the Port
shape is irregular and similar to the comment above
27 I acknowledge the emergency preparedness and response
plan but please confirm that this includes pro-active routine
monitoring of storm water leaving your premises to verify that
your assumptions of clean storm water are correct
13042012
By post
Andrew Lucas
(Director
WRampU
Department of
Water Affairs)
Pro-active routine monitoring of stormwater leaving the premises
will be undertaken This has been explicitly emphasised in
chapter 8 of the draft EMP
28 Will portablechemical toilets be used during construction
29 What provisions have been made for storm water drainage
during construction
18042012
By
telephone
Department of
Water Affairs
Port Elizabeth
Chemical toilets will be used during construction
The Casa Steel site will be located at the corner of two roads
drainage of stormwater from the site will take place through the
roadsrsquo drainage system
From Lea September [mailtoleailisocom]
Sent 11 March 2011 0935 AM
To Wayne Poulton
Cc Terry Baker
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Wayne
An Environmental Impact Assessment (EIA) will be undertaken for this project during the
next 10 to 12 months
We foresee that some of the key environmental impacts of the project will be in terms of air
quality water quality waste and hazardous substances
At this stage I am not able to give you any details regarding the potential toxicity of the
emissions andor effluent However specialist studies will be conducted as part of the EIA
that will determine the key impacts of the project Mitigation measures will also be identified
to avoid minimise or compensate any significant impacts
You are registered on the stakeholder database and you will be kept informed of progress in
the EIA process you will notably get the opportunity to access the reports produced and
provide any feedback on them
Please feel free to contact me should you need any further information
Best regards
Lea September
From Wayne Poulton [mailtowaynepbosuncoza]
Sent 07 March 2011 1257 PM
To Lea September
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
Please can you provide me with some more information as to the potential dangers including
the toxicity of this
Kind regards
Wayne
From Lea September [mailtoleailisocom]
Sent 04 March 2011 1123
To Lea September
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 March 2011 0745 AM
To Paul Martin
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 05 April 2011 0847 AM
To Paul Martin
Cc Terry Baker Renee von Gruenewaldt
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Thank you Paul for this information
I have downloaded a copy of the RoD and Scoping report you referred to and will make sure
these requirements are taken into account in the environmental assessment
Best regards
Lea September
From Paul Martin [mailtopmartinaxxesscoza]
Sent 04 April 2011 0955 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Further to my comments on 27311
Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in
the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega
IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised
scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions
including prohibiting and monitoring where possible visible emission plumes to the atmosphere
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Paul Martin
Sent Monday March 28 2011 745 AM
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 10 May 2011 0327 PM
To ElliotMotsoaholetransnetnet
Cc Terry Baker
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Mr Motsoahole
Thank you for your input on this issue
The Port of Ngqura will indeed be used for import and export At the moment the scope of
the traffic impact assessment only covers road traffic I have however relayed the matter to
our traffic specialist and we will consider this issue in the finalization of the Scoping Report I
will keep you informed of any developments in that regard
I trust this is acceptable to you
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]
Sent 10 May 2011 0855 AM
To Lea September
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
It has been noted that Casa Steel will source steel coils from various markets internationally and
in South Africa and the bulk of the plantrsquos production output will be exported to African countries
However there is no mention of logistic requirements
Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will
be used the scope of traffic impact assessment should also include the port
Regards
From Lea September [mailtoleailisocom]
Sent 04 May 2011 0747 AM
To Lea September
Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
Please find attached a letter announcing the EIA process underway for the proposed 80 000
tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as
a Background Information Document (BID) outlining the details of the project
Please contact me should you require any further information on this project
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
Elliot Motsoahole
Manager - Environment
Transnet National Ports Authority
Port of Nqqura
Port Control Building Klub Road Port Elizabeth 6212
PO Box 612054 Bluewater Bay 6212
+27 41 507 8450
+27 86 674 7729
Cell +27 83 542 5619
E-mail Elliotmotsoaholetransnetnet
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
DISCLAIMER The information contained in this communication is subject to copyright and
intended only for the use of leailisocom Unauthorised use disclosure or copying is
strictly prohibited Should a virus infection occur as a result of this communication the sender
will not be liable If you have received this communication in error please notify
elliotmotsoaholetransnetnet
From Lea September [mailtoleailisocom]
Sent 25 May 2011 1147 AM
To Jack Landile (ELS)
Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi
Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Landile
Thank you for your input
Contact has been made with the relevant Municipal Directorate and we will follow up with
them to obtain clarifications on all these issues
I have added both Lizna and yourself on the database and will keep you updated on
progress on this project
Best regards
Lea September
From Jack Landile (ELS) [mailtoJackLdwagovza]
Sent 24 May 2011 0524 PM
To Fourie Lizna (ELS)
Cc Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Hi Lizna
I missed you on this sorry
I linked Pieter twice Instead
Regards
Landile
From Jack Landile (ELS)
Sent 24 May 2011 0445 PM
To leailisocom
Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Lea
The e-mail you sent to Mr Kooverji dated 19 May 2011 refer
Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are
All steel sheets bathing unit must be under roof
The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project
Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal
Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer
Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality
Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines
Of note is the low volume of the proposed WWTW facility ie 250 cubmweek
And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles
generation
Regards
Landile
From Lea September [mailtoleailisocom]
Sent 19 May 2011 0947 AM
To Lea September
Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Stakeholder
Please find attached the remaining appendices to the draft Scoping report for the proposed
80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 June 2011 0411 PM
To Aphiwe Bewana
Subject RE Proposed 80 000 TPY Galvanizing plant in Coega
Dear Mr Bewana
Thank you for your input and apologies for the late reply
We have taken note of your comments and are will be taking them forward in the EIA phase
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Aphiwe Bewana [mailtoaphiwebewanagmailcom]
Sent 31 May 2011 1205 PM
To Lea September
Subject Re Proposed 80 000 TPY Galvanizing plant in Coega
Comment
Re Proposed 80 000 TPY Galvanizing plant in Coega
As SANParks we would like the EIA phase to investigate the potential effects of toxicity
andor influence of emissions waste and hazardous substances both in terrestrial and
marine fauna In the draft scoping report reference has been made with regards to the
terrestrial fauna but there is no attention to potential effects to marine fauna
Equally with regards to water usage where is the plant going to extract its waters used in
galvanization andor waste management process ie rainfall rivers or even from the sea)
and which avenues would be more environmental friendly and effective
Regards
Aphiwe Bewana
Marine Planner
South African National Parks
POBox 76693
NMMU
Port Elizabeth
6031
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 06 July 2011 1031 AM
To Lea September
Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Hi Lea
Irsquove reviewed the Final Scoping Report Herewith a few comments
1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the
Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a
revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the
NMBLP Please include only those in the IDZ as part of your IAP list
Regards
Andrea
From Lea September [mailtoleailisocom]
Sent Wednesday July 06 2011 859 AM
To Lea Septemberrsquo
Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Dear Stakeholder
The final scoping report for the above-mentioned project (attached) is available for comment
until 27 July 2011
The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic
commentaryrdquo tab
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 09 April 2012 1159 AM
To Lea September
Subject Comments on Galvanising Plant EIR Coega IDZ
Lea
Attached are my comments on the Draft EIR for the Coega IDZ galvanising
plant
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
Email attachment
COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ
Dr Paul Martin PO Box 61029
Bluewater Bay 6212 Tel 041 4665698
Email pmartinaxxesscoza
Compliance with CDC Permits amp Requirements
It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of
o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants
Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC
Air Emissions
Presumably permanent in stack monitoring will be required in terms of AEL permit requirements
Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions
Water
Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)
General
There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)
Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards
Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter
All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 11 April 2012 1245 PM
To Lea September
Subject Fw Comments on Galvanising Plant EIR Coega IDZ
Lea
One other comment on that I have on the Galvanising Plant Draft EIR
Hydrogen chloride is one of the main emissions There are no ambient air
quality guidelines for HCl and the EIR says concentrations will be well
within health parameters
However the main problem with HCl is its corrosive effect - there is
absolutely no mention of this in the draft EIR nor air specialist report
There needs to be some sort of comment assessment as to whether HCl
emissions are likely to impact on for example the adjacent Agni-Steel
Plant wrt corrosion - their factory structure will be made of steel
The EIR specialist rpt suggests monitoring HCl at ground level on the
property boundary and this is supported in case there are complaints from
neighbours
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Paul Martin ltpmartinaxxesscozagt
To Lea September ltleailisocomgt
Sent Monday April 09 2012 1158 AM
Subject Comments on Galvanising Plant EIR Coega IDZ
gt Lea
gt
gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising
gt plant
gt
gt
gt Dr Paul Martin
gt PO Box 61029
gt Bluewater Bay 6212
gt Tel 041 4665698
gt Cell 0732524111
gt email pmartinaxxesscoza
gt
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 12 April 2012 1139 AM
To Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Hi Lea
Hope yoursquore keeping well
I have requested comments from my colleagues and the CDC Casa team on the Draft EIR
Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report
Regards
Andrea
From Graham Taylor
Sent Thursday April 12 2012 838 AM
To Andrea Von Holdt Firhana Sam
Cc Johan Fourie Maria van Zyl Melikhaya Sihawu
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Andrea Firhana
Firhana if you could please ensure that the co-ordinates provided in the EIR correspond
with our records (pages 4-1 amp 4-2)
My comments are as follows
It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work
Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above
Regards
Graham Taylor
Spatial Development Manager - Infrastructure Development
Mobile 0832283055
Office 0414030454
Facsimile 0865185033
Email GrahamTaylorcoegacoza
Website wwwcoegacom
right PLACE | right TIME | right CHOICE
This email and all contents are subject to the following disclaimer
httpwwwcoegacomemaildisclaimerhtml
From Lea September [mailtoleailisocom]
Sent 04 May 2012 0411 PM
To Andrea Von Holdt
Cc Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Dear Andrea
We have taken note of the comments from the GIS Unit These issues have been rectified in
the final version of the EIR
Please can you forward to the relevant persons at the GIS Unit
Thank you
Best regards
Lea September
APPENDIX E
BACKGROUND INFORMATION
DOCUMENT
APPENDIX F
AIR QUALITY IMPACT ASSESSMENT
APPENDIX G
TRAFFIC IMPACT ASSESSMENT
APPENDIX H
WASTE MANAGEMENT AND HAZARDOUS
SUBSTANCES SPECIALIST STUDY
APPENDIX I
WATER QUALITY SPECIALIST STUDY
APPENDIX J
ENVIRONMENTAL MANAGEMENT
PROGRAMME
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vi
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
Waste management and hazardous substances
The plant will generate a relatively small amount of solid waste which will be re-used
recycled or disposed of in accordance with the EMP recommendations
There will be a wastewater treatment plant on site which will neutralise process water
(012 Mlweek) in order to ensure it is of a standard acceptable for discharge to sewer
Hazardous waste from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-site
at Aloes II Hazardous landfill site The volume of hazardous waste to be stored and
removed on a monthly basis is limited to 10 m3
A number of substances classified as hazardous are used in the galvanizing process and
the transport and handling of these is subject to certain rules and guidelines
In addition the permanent storage of a high quantity of liquid petroleum on site (20 000
litres at any one time) is subject to certain specifications and requires approval from the
municipality
Health and safety
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling of the various substances used will be done in
accordance with applicable instructions (cf material safety data sheets)
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as provide
site supervision including executing tests (individual test cold run and hot run) during 3
months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the EMP
Traffic
In the operational phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and from
the Port of Ngqura
The traffic expected to be generated during construction as well as operation is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low and
the total traffic generated by Casa Steel is also relatively low
The impact on port traffic is also negligible and well within the portrsquos capacity
Socio-economic aspects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vii
The proposed galvanizing plant will make a positive contribution by creating jobs during
construction and operation and generating business for the various service providers
Fatal flaws
No fatal flaws have been identified
The significance of these potential key environmental impacts were assessed in the EIA
phase and the findings of this phase of investigations are presented in this report
The main findings of the EIA are as follows
During construction impacts post-mitigation are low with the exception of noise and
biodiversity as the construction of the plant will result in the destruction of habitat
and loss of fauna and flora and noise impacts inherent to construction activities
Mitigation measures have been included in the EMP for these impacts and they have
a medium significance post-mitigation
All impacts were assessed as low during operation after mitigation
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium
to long term similar impacts are likely to occur due to ongoing developments in the
IDZ
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
The CDC has its own requirements regarding the monitoring of certain aspects of the
project such as the quality of the effluent and the noise levels These have been
incorporated into the EMP Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as other
infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified and
assessed No fatal flaws have been identified
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 viii
It is recommended that the project be approved subject to the conditions listed above
and adherence to the EMP recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-1
1 INTRODUCTION
11 BACKGROUND
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)
Nelson Mandela Bay Municipality Eastern Cape Province
The demand for galvanised steel products is high in South Africa and Africa and is
expected to increase in the foreseeable future From an economic point of view the
proposed project has therefore been found to be viable
Casa Steel will source the steel coils from various markets internationally and in
South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is
destined to be exported mainly to African countries
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
An Environmental Impact Assessment (EIA) is required as the proposed project
involves several activities listed in terms of Section 24 of the National Environmental
Management Act (NEMA) No 107 of 1998 as amended and requires an
environmental authorisation
The following listed activities requiring environmental authorisation have been
identified
Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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
Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped
land to industrial use greater than 1 ha but less than 20 ha in size outside an
urban area
Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any
process or activity requiring a license in terms of national or provincial legislation
governing the generation or release of emissions
Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5
hectares or more of vegetation where 75 or more of the vegetative cover
constitutes indigenous vegetation except where such removal of vegetation is
required for
(i) purposes of agriculture or afforestation inside areas identified in
spatial instruments adopted by the competent authority for
agriculture or afforestation purposes
(ii) the undertaking of a process or activity included in the list of waste
management activities published in terms of section 19 of the
National Environmental Management Waste Act 2008 (Act No 59
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-2
of 2008) in which case the activity is regarded to be excluded from
this list
(iii) the undertaking of a linear activity falling below the thresholds in
Notice 544 of 2010
Hot dip galvanizing is a listed activity in terms of section 21 of the National
Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires
an Atmospheric Emissions Licence (AEL)
In addition the treatment of wastewater with an annual throughput capacity of more
than 2000 m3 is a listed activity in terms of the National Environmental Management
Waste Act 59 of 2008 and requires a waste management licence
ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental
Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact
Assessment process in terms of section 24 of NEMA for the construction and
operation of the proposed galvanizing plant The EIA process covers all aspects of
the project and informs all three applications (for environmental authorisation waste
management licence and AEL)
13 PURPOSE OF THIS REPORT
This report builds on the scoping report submitted to the Eastern Cape Department of
Economic Development and Environmental Affairs (DEDEA) and the Nelson
Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It
describes the proposed project and presents the findings of the second phase of
investigations (EIA phase)
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP)
The EIA was managed by Ms Terry Baker a certified Environmental Assessment
Practitioner with 20 years of working experience She has a MA in Environmental
Management and specialises in Environmental Impact Assessments and Project
Management She has been involved in a variety of different types of EIAs including
for water supply projects dams transmission lines roads and airports in South
Africa Botswana Uganda Lesotho and Mozambique She has been involved in
water resource management and public participation programmes on a number of
projects Terry has also been involved in the use of Geographic Information Systems
environmental status quo reports water quality assessments socio-economic and
institutional development projects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-3
15 PROJECT TEAM
In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen
(water quality specialist) and Lea September (EAP) with specialist input from Renee
von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous
substances) and Seniel Pillay (Traffic Impact Assessor)
The Business Unit Head of the ILISO Environmental Management Discipline Group
Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is
a Fellow of the South African Institution of Civil Engineers a member of the South
African Society of Aquatic Scientists of the Environmental Scientific Association of
the International Water Association of the Water Institute of South Africa and of the
Vaal River Catchment Association He is a certified Environmental Assessment
Practitioner with 30 years experience who specialises in project management
environmental impact assessments and water resource planning He specifically has
extensive experience in water quality especially water quality management water
quality monitoring and water quality assessment Martin has experience in managing
projects that involve multi-disciplinary teams and public consultation and
participation in South Africa and abroad
Lea September is an Environmental Assessment Practitioner with a Masters degree
in Environmental Management She has experience in impact assessment and
environmental management and has been responsible for drafting impact
assessment reports and Environmental Management Programmes and conducting
public participation processes as well as high level environmental screenings for a
variety of projects in the energy water transport and industrial sectors
Renee von Gruenewaldt has nine-years experience in the field of air pollution
impact assessment and air quality management Prior to becoming involved in air
quality consultation she was part of the Highveld Boundary Layer Wind Research
Group based at the University of Pretoria Since joining Environmental Management
Services (the company now Airshed Planning Professionals) she has undertaken
numerous air pollution impact studies and has provided extensive guidance to both
industry and government on air quality management practices
Pieter Smuts graduated as a Civil Engineer and became involved in the field of
municipal engineering and infrastructure construction He has specialized during the
last twelve years in solid waste management He has completed waste management
plans feasibility studies and final designs of waste management facilities in South
Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and
the review of the Mavoco hazardous waste landfill design in Maputo Mozambique
and completed a study on hazardous waste (textile factory sludge) management in
Maseru Lesotho
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-4
Seniel Pillay is a transportation engineer with over 16 years experience in
transportation planning and traffic engineering He has been involved in a wide
range of projects ranging from developing the Transport Operations Plan for the
FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System
for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller
traffic impact assessments for inter alia road improvement schemes Of particular
relevance to this project his experience includes Heavy Goods Vehicle Study for
eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact
Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash
Preliminary Transportation Assessment
16 STRUCTURE OF THIS REPORT
The proposed project and the alternatives considered are described in Chapter 2
Chapter 3 details the approach adopted for the EIA phase
The biophysical and socio-economic environment affected by the activity is described
in Chapter 4
The environmental impacts identified are discussed in Chapter 5
The EIA methodology is described in Chapter 6 and Chapter 7 presents the results
of the impact assessment
The environmental impact statement is presented in Chapter 8
Finally Chapter 9 spell out the conclusions and recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-1
2 DESCRIPTION OF THE PROPOSED PROJECT
21 TECHNICAL ASPECTS
211 The galvanizing process
Galvanizing consists of coating steel with zinc in order to protect it from corrosion
Before steel strips can be galvanized they undergo a pre-treatment in order to
ensure that the steel sheets are free from any surface oxides as they enter the
molten zinc coating Bath This is done by removing the oil from the steel sheets (in
the degreasing unit) and then removing the rust from the surface of the sheet (in the
pickling unit)
The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The
melting zinc on the strip surface will be cooled and solidified through air cooling in the
cooling tower
Finally the galvanised steel sheets are dipped into a water quenching tank in order to
further cool the sheets from about 150degC to 40degC
It is possible to make galvanised steel more durable by chromating it Approximately
50 of the galvanised steel production output will receive chromate passivation
treatment after quenching the galvanised steel sheets will be sprayed with a chrome
solution (3 kgcm2)
After galvanizing and chromating the steel sheets are cut to achieve the desired coil
size and weight and transported to the storage yard
The process flow diagram below (Figure 1) illustrates the main stages of the
galvanizing process and indicates the major inputs and outputs as well as the
resulting effluent and atmospheric emissions
Draft Environmenal Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-2
Figure 1 Process flow diagram for proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-3
212 Main inputs and outputs in operational phase
In view of the above the main inputs will be as follows
Steel coils 85 000 tonsyear
Zinc 870 tonsyear
Electricity 2500 kVA
Water 2000 m3month (of which 400 m3 will be potable water)
Liquid Natural Gas (LNG) 270 NM3hour
Sodium hydroxide (NaOH) 1000 m3year
Hydrochloric acid (HCl) 800 m3year
Chrome (Cr+3) 10 m3year
The main outputs will be
Galvanized steel 80 000 tonsyear
Scrap metal 20 tonsyear
General waste 65 tonsyear
Hazardous waste 2 m3month
Wastewater 012 Mlweek
Atmospheric emissions lt 5 ppm
213 Installations on site
The bulk of the operations involved in the galvanizing process occur along a
continuous galvanizing line (See Figure 2 below) which is the main piece of
machinery required for the proposed galvanising plant
Figure 2 Continuous Galvanizing Line
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-4
Water is one of the major inputs and is used throughout the galvanizing process notably
for rinsing and cooling purposes and as a mixing agent for the various chemical
solutions The plant will have a water treatment plant on site to treat the water used in
the various processes (approx 250 m3
of wastewater per week) The wastewater
treatment facility will be operated by a professional water treatment company as Casa
Steel does not have the required expertise in house to treat its process water Sulphuric
acid (H2SO4) is used as part of the treatment process to reduce caustic soda The
neutralised water is discharged to the sewer while any sludge is disposed of as
hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)
will be disposed of
Some critical areas of the galvanizing process such as the zinc pot require uninterrupted
power It is therefore proposed to install an LNG burner to maintain the zinc bath at a
temperature of between 450 and 460degC
22 LOCATION OF THE PROPOSED GALVANIZING PLANT
The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast
of Port Elizabeth in the Eastern Cape (Figure 3)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-5
Figure 3 Location of the proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-6
23 NEED AND DESIRABILITY
The profitability of the proposed project has been established by Casa Steel and a
pre-feasibility study has confirmed that the proposed project was feasible from a
technical and financial point of view The Coega IDZ is specifically designed to host
facilities such as a galvanizing plant and can provide the necessary infrastructure
and services to its investors It therefore constitutes a very suitable location for the
project
24 ALTERNATIVES IDENTIFIED
Zone 6 has been specifically earmarked for heavy ferrous metal industries and is
therefore a suitable location for the proposed galvanizing plant as such no site
alternatives have been provided for and assessed in this EIA However prior to the
commencement of the EIA process Casa Steel was presented with a number of
different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the
selection of the site were
(a) The dimensions of the land the site should be at least 200 m long and
50 m wide in order to accommodate the galvanizing line and adjacent lay
down area and additional land should be available next to the site for future
expansion
(b) The fiscal arrangements applying to the site the site should be located
within the future Custom Controlled Area (CCA) as the bulk of the
production output of the plant will be exported
The no-go alternative is assessed in this report
25 CONSTRUCTION ASPECTS
The construction phase of the project will take about 12 months and will essentially
consist of erecting a building to house the galvanizing line and other equipment and
preparing a concrete laydown area adjacent to the building
The CDC will provide an access point from the existing tarred road that will lead to
the site
Approximately 100 workers from the surrounding areas will be contracted for the
construction work
The requirements in terms of services during construction are listed below
Water 1000 m3month
Electricity 2500 kVA
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-7
The CDC will provide temporary services for the construction phase including a
conservancy tank for flush toilets Sewage infrastructure will only be provided for the
operational phase
26 OPERATION ASPECTS
Before the plant can become fully operational the equipment and machinery will be
tested for approximately 3 months The supplier will supervise these tests as part of
the transfer of know-how and training of staff on the plant
Casa Steel will start operating the plant at a reduced capacity (about 50 000
tonsyear) for a period of time (mostly determined by market aspects) before bringing
production to full capacity (80 000 tonsyear) This is done by operating the line for
longer hours
Approximately 50 to 60 people will be working on the plant Approximately 6-10 of
these will be unskilled 40-45 skilled and about 5 people in managerial positions
The requirements in terms of services during operation are as follows
Water 2000 m3month
Electricity 2500 kVA
Effluent discharge 24 m3day
The CDC has entered into agreements with the municipality to secure the provision
of services such as water and electricity to its tenants Tenants in the IDZ have their
own agreements with the NMBM for electricity while the agreements for water and
sewage are with the Facilities Unit of the CDC
Regarding discharge of wastewater to the sewer the municipality indicated that the
only requirement is that the water discharged complies with applicable municipal
discharge standards
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 3-1
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT
31 OBJECTIVES
The main objectives of the EIA phase are to
Assess the significance of the environmental issues and impacts identified in the
scoping phase focusing on key impacts
Recommend appropriate measures to mitigate negative impacts and enhance the
benefits and include them in the draft EMP
Undertake a public participation process that provides opportunities for all
interested and affected parties (IampAPs) to be involved
32 AUTHORITY CONSULTATION
The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental
Liaison Committeersquo (ELC) which comprises representatives of various authorities
including DEDEAT the Department of Environmental Affairs (DEA) and Department
of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the
Coega Development Corporation (CDC) and Transnet National Ports Authority
(TNPA) The ELC has been specifically formed to facilitate EIA applications in the
IDZ
Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to
the clearance of vegetation should be included in the application A formal request
was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the
application and all registered stakeholders were informed of the request in writing on
19 October 2011
33 PUBLIC PARTICIPATION PROCESS CONDUCTED
On-site notices were replaced by a notification displayed on the CDCrsquos digital notice
board at the business centre in Zone 1 of the IDZ The eNotice was placed on
13 April 2011 and will remain for the full duration of the EIA process
Registered stakeholders will be notified in writing of the availability of the draft EIA
report and EMP which will also be advertised in a local newspaper Stakeholders
including state departments and the public will have forty (40) days to comment on
the draft EIA report and EMP The draft EIA report and EMP will be sent by email
where possible and made available for download on the ILISO website
(wwwilisocom)
A summary of all issues and comments received during the stakeholder consultation
process as well as of correspondence in that regard will be captured in an Issues
and Responses Report that will form an Appendix to the EIA Report
The list of registered IampAPs is included in Appendix A
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 3-2
34 LEGISLATION AND GUIDELINES CONSIDERED
The following legislation and guidelines were considered in the preparation of this
report
National Environmental Management Act Act No 107 of 1998
NEMA EIA Regulations 2010
National Environmental Management Air Quality Act Act No 39 of 2004
National Environmental Management Waste Act Act No 59 of 2008
Hazardous Substances Act Act 15 of 1993
Occupational Health and Safety Act Act 85 of 1993
Hazardous Chemical Substances Regulations 1995 (GNR 1179)
Major Hazard Installation Regulations 2001 (GNR 692)
National Water Act Act 36 of 1998
National Heritage Resources Act Act 25 of 1999
DEAT Integrated Environmental Management Information Series 1-5 and 12-15
NEMA draft Implementation Guideline
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Public Participation (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Alternatives (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Draft Guideline for Determining the Scope of Specialist
Involvement in EIA Processes (2005)
IAIA guidelines
National air quality standard for thoracic particulates Government Gazette
No 32816
Listed activities and associated minimum standards identified in terms of section
21 of the National Environmental Management Air Quality Act Act No 39 of
2004 Government Notice 248 of 2009
Minimum Requirements for the Handling Classification and Disposal of
Hazardous Waste DWAF Waste Management Series (1998)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-1
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION
The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega
IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay
to the north of the N2 highway between Port Elizabeth and Grahamstown east of the
Coega River
The co-ordinates of the corners of the site are shown in Table 1
Table 1 Coordinates of site corners for the proposed galvanizing plant
Point Longitude Latitude
A 25deg411126E 33deg45587S
B 25deg411156E 33deg45499S
C 25deg411938E 33deg45131S
D 25deg412174E 33deg45481S
E 25deg412508E 33deg45979S
F 25deg412634E 33deg451160S
G 25deg411782E 33deg451560S
H 25deg411692E 33deg451428S
J 25deg411314E 33deg45868S
Figure 4 Zone layout in the Coega IDZ
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-2
Figure 5 Site location
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-3
42 SOCIO-ECONOMIC CHARACTERISTICS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the
NMBM There are no residents within the IDZ
As far as the broader NMBM and Eastern Cape Province are concerned the
following can be noted The NMBM is located within the Eastern Cape Province the
2nd largest Province in South Africa (3rd in terms of population) characterised by a
predominantly black population with low incomes and high levels of unemployment
(CES 2010)
The NMBM has a population of just above 11 million and covers an area of
1 950 km2 It is the main urban and industrial centre of the province and Port
Elizabeth in particular which forms part of the NMBM is the commercial capital of
the Eastern Cape 52 of the NMBM population is female and 37 is below the
age of 20 these two groups are particularly affected by unemployment
43 BIOPHYSICAL CHARACTERISTICS
431 Surface and ground water
No rivers occur in Zone 6 There is however a natural attenuation pond on the
southern most part of the site which will have to be avoided
The IDZ is underlain by calcrete sand and gravel deposits that overlie low
permeability clays These clays limit the vertical infiltration of rainwater and induce a
horizontal groundwater flow towards the Coega River channel which is the most
significant surface water feature in the Coega IDZ Consequently rapid run-off takes
place following precipitation (Jacobs 2008)
Groundwater levels at Coega are generally about 3 to 5 m below surface ie just
above the contact between the permeable sands and the underlying impermeable
clays The groundwater flow direction is to the southeast following the surface water
drainage direction (Jacobs 2008)
432 Climate and atmospheric conditions
Port Elizabeth has a warm temperate climate and the temperature ranges are not
extreme Exceptionally high temperatures may be experienced during berg wind
conditions which occur frequently during autumn and winter Extreme temperatures
also occur during summer with little accompanying wind
The wind regime for the area largely reflects the synoptic scale circulation with
dominant westerly and northwesterly flow fields representing the pre-frontal
conditions and south-westerly flow fields representing the frontal conditions The
south-easterly and south-westerly wind flow (land breeze) increases during daytime
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-4
conditions with westerly and north-westerly wind flow increasing during the night (sea
breeze)
The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of
Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15
km southwest) and Port Elizabeth (~23 km southwest)
An ambient air monitoring network has been established in the Coega IDZ which
consists of three monitors Saltworks Motherwell and Amsterdamplein Although
NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative
impacts due to the proposed Galvanising Plant is PM10 A maximum daily average
PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed
SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3
was exceeded on 17 days in 2007 and 26 days in 2008
Existing sources of emissions in the vicinity of the proposed galvanizing plant include
industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other
fugitive dust sources (von Gruenewaldt 2011b)
433 Geology and soils
Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel
and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly
limestone and conglomerate
434 Terrestrial ecology
This section draws from the EIA report compiled for the Agni Steel (formerly Afro-
Asia) steel processing facility which is adjacent to the proposed site for the
galvanizing plant (Jacobs 2008)
The area consists largely of grasses succulents and scrubby bush with alien
species making up the greater part of the more dense vegetation
Zone 6 falls within the inland vegetation and is characterised by a vegetation type
referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the
Coega IDZ and has been found to have three times the level of endemism of other
vegetation communities in the Coega IDZ Bontveld therefore has a high
conservation status Two Bontveld conservation areas have been identified within the
IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)
Bontveld that will be destroyed as a result of development in the IDZ will be given
conservation status in these two areas
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-5
Figure 6 Coega IDZ Open Space Management Plan (OSMP)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-6
Certain areas in the IDZ are invaded by alien plant species The most common
invader species is rooikrans (Acacia cyclops) which presently forms large
monospecific stands in areas throughout the Coega IDZ There are several other
aliens present that pose a threat to the flora of this area including the prickly pear
(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)
Loss of vegetation and alien plant invasion due to human activity has resulted in a
reduction in the diversity of terrestrial fauna
The majority of mammals present in the Coega IDZ are small or medium-sized Of
the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed
gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of
Algoa Bay however it is not considered threatened The gerbil is common in
foredune and dune thicket habitat in the Coega region and is therefore unlikely to
occur on the proposed site
A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird
species are resident or common to the area Most diversity occurs in the thicket
although the coastal area also supports specialised avifauna Two species of tern
the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well
as the Cape gannet (Morus capensis) and the African penguin (Spheniscus
demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne
caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant
(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser
flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns
are two of the most endangered coastal species in South Africa Other bird species
of conservation concern include the Whitefronted plover (Charadrius marginatus)
African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus
bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus
ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides
paradisea) Breeding pairs of Damara terns and African black oyster catchers have
been observed in the coastal dunes of the IDZ but should not be affected by
developments that fall outside the dune areas
The Eastern Cape supports nearly a third (approximately 133 species) of the reptile
species recorded in South Africa More than half of the Eastern Capersquos endemic
reptile species occur in the Algoa Bay area giving the region a high conservation
value A total of 63 reptile species are believed to occur within the Coega IDZ The
majority of these are found in Succulent Thicket and riverine habitats Only a few
reptile species occur in the coastal dunes and estuarine habitats More than a third of
the species are described as relatively tolerant of disturbed environments provided
that migration corridors of suitable habitat are maintained to link pristine habitats
Twenty two reptiles are of special concern including five endemic species (two of
which may also be endangered) four endangered sea turtles eight species listed
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-7
with CITES one rare species and four species at the periphery of their range
Fourteen of these species of special concern are confirmed as occurring on or within
2 km of the Coega IDZ
A total of 32 amphibian species and sub-species occur in the Eastern Cape
representing almost a third of the species recorded in South Africa However none of
the species are endemic or Red Data Book species Based on previous studies in the
area it is estimated that approximately 17 amphibian species occur within the Coega
IDZ Four species are listed as peripheral but none are threatened internationally
These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog
(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and
the bubbling kassina (Kassina senegalensis)
The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated
vegetation has not been extensively studied One grasshopper species Acrotylos
hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue
(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis
pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in
four localities in the Eastern Cape one of which is within the Coega IDZ The Coega
copper Aloeides clarki is endemic to this particular region of the Eastern Cape and
is currently known to occur in three localities two of which are in the Coega IDZ The
localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the
Coega IDZ and their distributions were taken into account when defining Coegarsquos
open space system and Development Framework Plan
435 Land use and topography
The land is currently undeveloped and earmarked for industrial development The
site is relatively flat ranging from an elevation of 66 masl on the northern-most
corner to 59 masl at the southern-most corner
436 Heritage and archaeological survey
Extensive studies have been undertaken in Zone 6 with respect to heritage aspects
Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a
2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond
2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is
currently being finalised
Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing
Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha
in extent and was located next to the R102 road to Motherwell Kaplan conducted
HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi
Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will
now be located in Zone 5)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-8
The various archaeological investigations reached similar observations and
conclusions Stone tools of various densities and types were found throughout the
zone The majority of the stone tools were mainly of Earlier and Middle Stone Age
and occasional Later Stone Age origins (Figure 4)
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble
gravels exposed by tracks in Zone 6 (Source Binneman 2010)
The stone tools which comprised of quartzite flakes chunks flaked pebblecobble
and cores were randomly distributed across the landscape and are in secondary
context There were no lsquoconcentrationsrsquo of tools observed which suggested any
spatial patterning or activity areas although these may be present or covered by soil
and vegetation
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 5-1
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED
The following environmental issues and potential impacts were identified in the
Scoping phase
51 AIR QUALITY
The galvanizing process generates atmospheric emissions with particulates and
hydrogen chloride representing the main pollutants of concern The plant is fitted with
air extraction as well as scrubber systems which are designed to retain the bulk of
pollutants and particles for each of the processes in such a way that less than 5 ppm
of gases and particles will be released into the atmosphere after the fume scrubber
Other sources of impact on air quality include emissions from the LNG burner as well
as emissions and dust from the transport of steel and other materials in trucks
Construction activities will also create dust and gas emissions due to the clearing of
groundcover tipping of material to storage pile levelling of area wind erosion from
storage piles vehicle and construction equipment activity and tailpipe emissions
from vehicles and construction equipment such as graders scrapers and dozers
Overall the air quality impact assessment (Gruenewaldt 2011b) found that
The predicted particulate oxides of nitrogen carbon monoxide and sulphur
dioxide concentrations are all below the National Ambient Air Quality Standards
for all averaging periods
The predicted off-site concentrations of hydrogen chloride are well below the
most stringent effect screening levels
No odour threshold exceedances for hydrogen chloride were predicted to occur
due to routine operations at the Steel Galvanising Plant The South Wales
Environmental Protection Authority stipulates that an odour unit of 20 is
acceptable for urban areas The odour unit would be lt10 directly off-site for
hydrogen chloride
Abnormal emissions can occur in exceptional circumstances Start-up will not
cause abnormal emissions as the scrubbers will be commissioned first and will be
functioning once the plant starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions would be emitted as a
building fugitive
The hourly hydrogen chloride ground level concentrations (directly offsite) were
predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based
on the emission limits as stipulated for listed activities for galvanising processes)
using a screen model which assumes worst case meteorological conditions The
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-2
health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming
abnormal emissions emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset conditions will still
be well within the health effect screening levels
Similarly the hourly particulate emissions from the building fugitives during upset
conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for
listed activities for galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly
off-site
Therefore if emissions are 5 times higher normal they will still be within health effect
screening levels and the daily PM10 NAAQS levels
In the case of a fire a cocktail of gases and particulates could be emitted and could
be over the recommended levels This situation will however be dealt with as an
emergency and normalised as quickly as is possible
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS
The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of
its heritage potential and there are no proposed protected geosites in Zone 6
Should any artefacts be discovered during construction procedures stipulated in the
draft EMP will apply
53 BIODIVERSITY AND CONSERVATION
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
In terms of terrestrial fauna the CDCrsquos open space management plan provides for
the preservation of certain corridors The destruction of certain habitats as a result of
the development will therefore not automatically result in the loss of certain species
54 WATER QUALITY
There is a natural attenuation pond on the southern most part of the site which will be
avoided
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through
spills or leaks
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-3
This risk can however be minimized if not avoided altogether The floor of the factory
will be designed as a bunded area to contain any spills and the entire process will be
contained Potential spills or leaks will therefore be contained and will not impact on
water resources Storm water is therefore considered clean water under normal
operational conditions An oil trap will be placed at the exit of the site to ensure that
no grease from the laydown area enters the stormwater system
Spills and leaks can occur during the handling or the transport of hazardous
substances Best practice guidelines will be followed to ensure that this risk is
adequately managed
Wastewater discharged to sewer will be treated to comply with municipal discharge
standards and is not expected to have an impact on the chemical characteristics of
the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be
discharged from the plant is small in relation to the total volume received at the
Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works
(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently
operated at 61 of its capacity which is approximately 80 Mℓday Thus the
0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore
not have any significant impact on the WWTW
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES
The plant will generate a relatively small amount of solid waste in the form of scrap
metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)
The scrap metal may be sold to other steel processing facilities such as Agni Steel
which will be located next to the plant or collected and disposed of with the rest of
the solid waste by a licensed service provider
As mentioned previously there will be a wastewater treatment plant on site which will
neutralise process water (012 Mlweek) in order to ensure it is of a standard
acceptable for discharge to sewer Waste in the form of sludge from the
neutralization or spent acid must be disposed of as a hazardous waste Solid waste
from the filters used for air quality control is also in this category These wastes can
usually be tested and then delisted which means that it can be placed in a general
purpose landfill
Hazardous effluent from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-
site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored
and removed on a monthly basis is limited to 10 m3
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-4
A number of substances classified as hazardous are used in the galvanizing process
(Table 2) and the transport and handling of these is subject to certain rules and
guidelines In particular the material safety data sheets (cf Appendix H) should be
referred to for inter alia hazards identification accidental release measures
handling and storage precautions exposure controlpersonal protection ecological
information and transport information The Hazardous Chemical Substances
Regulations 1995 should also be adhered to in respect of the transport and storage
of hazardous chemical substances
Table 2 Hazardous materials to be used on site
Major Input Materials
Substance
listed in the
SABS 0228
Group II
hazardous
substances
Volumes to be
stored on site at
any one time
Diesel radic 2000 litres
Liquid petroleum radic 20 000 liters
Sodium hydroxide (NaOH)
(used for degreasing) 8 radic 1000m
3
Hydrochloric acid (HCI)
(used for pickling) 8 radic 800m
3
Zinc (used for galvanising) - TBD
Trivalent chromium (CR+3
)
(used for chromating) 8 radic 10m
3
Sulphuric acid (H2SO4) (used for
treatment of waste water on site) 8 radic TBD
Ammonium Hydroxide (NH4OH) 8 radic TBD
TBD ndash To be determined
Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one
time) and is classified as a flammable substance Specification for flammable storage
facilities in accordance with the requirements of the Nelson Mandela Bay
Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for
quantities between 5000 and 20 000 liters the substance must be kept in a
flammable liquid store which complies with the requirements of a specification
obtainable from the Department Some of the requirements are
Flammable liquid and solid storage facilities are only permitted on the ground
floor
Decanting of flammable liquids and solids are not permitted within any building
Due to the fact that there are flammable materials on site a certificate may be
required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and
Emergency Services Department to confirm that facilities for flammable storage
are in accordance with their requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-5
Because of the permanent installation and high quantity of liquid petroleum on site
the Major Hazard Installation Regulations 2001 promulgated under the Occupational
Health and Safety Act No 85 of 1993 applies A written application for approval of
the installation is required to be submitted to the chief inspector Department of
Labour provincial director Department of Labour and NMBM prior to construction
In addition a risk assessment should be formulated covering all hazardous materials
together with an emergency preparedness and response plan
56 HEALTH AND SAFETY
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling instructions as well as occupational exposure limits
are indicated in the material safety data sheets of the various substances used
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as
provide site supervision including executing tests (individual test cold run and hot
run) during 3 months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the
EMP
In addition the emergency preparedness and response plan will cover the health and
safety aspects related to emergency situations
57 TRAFFIC
The volumes of traffic at the IDZ are currently relatively low and variable depending
on the different zones in the IDZ however these volumes will increase as more
developments are implemented
The construction phase of the Casa Steel development will take about 12 months
and will essentially consist of erecting a building to house the galvanizing line and
other equipment and preparing a concrete laydown area adjacent to the building
The traffic that would be generated during the construction phase can be expected to
be less than the traffic that would be generated by the Casa Steel development when
it is fully operational
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-6
In the operation phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and
from the Port of Ngqura
The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the
Casa Steel development would be off Ring Road 1 The other roads of significance
for the Casa Steel development are the N2 Neptune Road MR435 and MR450
Access to the port is given by Neptune Road Road Link NEP-03 has not yet been
built
Figure 8 Coega IDZ road network identification
(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-7
Figure 9 Coega IDZ road network
Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No
01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-8
The distribution of freight trips is fixed as the majority of trips will be made between
the Port of Ngqura and the Casa Steel site With regard to personnel trips there are
various points of origins (the surrounding residential areas) that could be used by
staff going to the Casa Steel site The distribution of personnel trips is based on
existing traffic count information and is shown in Figure 10
Figure 10 Trip distribution for freight and personnel trips
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The resultant expected Casa Steel traffic assignment is shown in Figure 11
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-9
Figure 11 Morning peak hour Casa Steel development traffic
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The traffic that is expected to be generated by the Casa Steel development is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low
and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)
Consultation has taken place with Transnet Port Authority (TPA) to establish the
impact of the galvanizing plant operations on traffic inside the port The additional
ships entering and exiting the port of Ngqura as a result of the proposed development
will have a negligible impact on port traffic and TPA indicated that it would be well
within the portrsquos capacity
58 NOISE
Noise is not foreseen to be a significant issue insofar as the noise levels inside the
plant and at the boundary of the site will not exceed the limits prescribed by the CDC
Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels
during the day and 60 decibels at night
Mitigation of noise impacts will be addressed in the design of the noise-emitting
components of the plant and their enclosures
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-10
59 SOCIO-ECONOMIC ASPECTS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of
NMBM There are no residents within the IDZ
The direct socio-economic impacts of the proposed project are thus limited to the
employment generated by the project during construction and operation Job creation
remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)
and the IDZ and Port of Ngqura are expected to become a significant catalyst to the
economic growth of the Municipality and the region with current investments at
Coega creating more jobs and stimulating the economy
In this context the proposed galvanizing plant will make a positive contribution
towards the achievement of these goals
There will be 50 to 60 employees during operation phase distributed as follows
Figure 12 Casa Steel organisation chart
Even though a large part of the inputs will be imported and the bulk of the production
output will be exported there will be some positive impacts for the economy of the
region and of South Africa in general Notably the requirements of the plant for
water electricity waste collection and disposal waste water treatment and transport
for example will create business for the various service providers and have an
indirect impact on employment and fiscal revenues as a result
From a visual impact point of view it can be anticipated that the landscape in the IDZ
will be significantly affected over time by developments related to the establishment
of the port and various industries
HEAD ( WORKS )
MGR ( COMM) MGR ( ADMNHR ) Manager marketing
MANAGER OPERATION MANAGER MANAGER MANAGER Q C
AC FIN PUR ampSTORE
PPC SH-GALV SH-tech
SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF
1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO
JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF
2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO
WORKERS WORKERS 7NOS
15 7
RAW MAT amp
DESP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 6-1
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
A description of the nature of the impact any specific legal requirements and the
stage (constructiondecommissioning or operation) will be given Impacts are
considered to be the same during construction and decommissioning The
significance of the potential impacts will be considered before and after identified
mitigation is implemented
The following criteria will be used to evaluate significance
Nature The nature of the impact will be classified as positive or negative and
direct or indirect
Extent and location Magnitude of the impact and is classified as
Local the impacted area is only at the site ndash the actual extent of the activity
Regional the impacted area extends to the surrounding immediate and
neighbouring properties
National the impact can be considered to be of national importance
Duration This measures the lifetime of the impact and is classified as
o Short term the impact will be for 0 ndash 3 years or only last for the period of
construction
o Medium term three to ten years
o Long term longer than 10 years or the impact will continue for the entire
operational lifetime of the project
o Permanent this applies to the impact that will remain after the operational
lifetime of the project
Intensity This is the degree to which the project affects or changes the
environment and is classified as
o Low the change is slight and often not noticeable and the natural functioning
of the environment is not affected
o Medium The environment is remarkably altered but still functions in a
modified way
o High Functioning of the affected environment is disturbed and can cease
Probability This is the likelihood or the chances that the impact will occur and
is classified as
o Low during the normal operation of the project no impacts are expected
o Medium the impact is likely to occur if extra care is not taken to mitigate
them
o High the environment will be affected irrespectively in some cases such
impact can be reduced
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 6-2
Confidence This is the level knowledgeinformation the environmental impact
practitioner or a specialist had in hisher judgement and is rated as
o Low the judgement is based on intuition and not on knowledge or
information
o Medium common sense and general knowledge informs the decision
o High Scientific and or proven information has been used to give such a
judgment
Significance Based on the above criteria the significance of issues will be
determined This is the importance of the impact in terms of physical extent and
time scale and is rated as
o Low the impacts are less important
o Medium the impacts are important and require attention mitigation is
required to reduce the negative impacts
o High the impacts are of great importance Mitigation is therefore crucial
Cumulative Impacts The possible cumulative impacts will also be considered
Mitigation Mitigation for significant issues is incorporated into the EMP for
construction
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 7-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS
71 IMPACTS DURING CONSTRUCTION
711 Air quality
Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris
handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine
particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural
operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks
and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)
Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Fugitive particulate emissions (dust)
related to construction activities Regional
Short
term Medium High High Medium Regional
Short
term Low High High Low
Construction vehicle gas emissions Regional Short
term Medium High High Medium Regional
Short
term Low High High Low
712 Heritage and archaeological resources
Naturedescription of impact excavation activities may impact on unidentified heritage resources
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-2
Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based
on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments
Heritage and archaeological
resources Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on unidentified heritage
resources Local
Short
term
Medium -
high Low High Low
713 Biodiversity and conservation
Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation
importance and cause soil contamination
Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species
Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan
and has compiled a list of protected species to be rescued (see draft EMP)
Biodiversity and conservation Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Loss of fauna and flora Local Perma
nent
Medium -
high High High High Local
Permanen
t Medium High High Medium
Soil contamination Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-3
714 Water related impacts
Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater
runoff spills and leaks Soil erosion
Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of
spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste
disposal Stormwater quality monitoring (see draft EMP)
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Soil erosion Local Short
term Medium Medium High Medium Local
Short
term Medium Low High Low
715 Waste management
Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed
Commentmitigation see draft EMP and waste management plan
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-4
Waste management Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Local
Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
716 Health and safety
Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Short
term
Medium -
high
Medium -
high High High Local
Short
term
Medium -
high Low High Low
717 Traffic
Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and
construction workers from surrounding areas and transport of equipment from the port
Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low
Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and
accurate estimates of quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-5
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Increased traffic on N2 and within the
IDZ Regional
Short
term Low High High Low
718 Noise
Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Short
term
Medium-
high High High Medium Local
Short
term Medium High High Medium
719 Socio-economic
Naturedescription of impact temporary employment will be created during the construction phase
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-6
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Temporary employment Regional Short
term Medium High High Medium
72 IMPACTS DURING OPERATION
721 Air quality
NatureDescription of impact gas and particulate emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning
Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local
sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and
veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute
to background fine particulate concentrations (von Gruenewaldt 2011b)
Assumptions and limitations Potential release of CR6+
As no emission factors are available for trivalent chromium processing the
potential impacts due to these activities could not be quantified
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Dust emitted from traffic on paved roads Regional Long Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-7
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
term
Hydrogen chloride emissions from
pickling process Local
Long
term Low High High Low
Particulate emissions (smoke) from
galvanizing process (due to the
volatilization of flux)
Local Long
term Low High High Low
Particulate oxides of nitrogen carbon
monoxide and sulphur dioxide emissions
from LNG burner
Local Long
term Low High High Low
Nuisance related to odour Local Long
term Low Low High Low
Abnormally high hydrogen chloride and
particulate emissions due to scrubber
malfunction
Local Short
term Medium Low High Medium
Gases (eg SOx NOx CO etc) and
smoke emitted in case of a fire Local
Short
term High Low High Medium
722 Water quality
NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks
Commentmitigation see draft EMP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-8
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Stormwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
723 Waste management and hazardous substances
NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous
waste both can affect environmental quality and human health
Commentmitigation see draft EMP and waste management plan
Waste management and hazardous
substances Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Regional
Long
term High
Medium -
high High High Regional Long term High Low High Low
Soilwaterair pollution due to improper
transport storage and handling of
hazardous substances
Regional Long
term High
Medium -
high High High Regional Long term High Low High Low
Health hazard Local Long
term High
Medium -
high High High Local Long term High Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-9
724 Health and safety
Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Long
term
Medium-
high
Medium-
high High High Local Long term
Medium-
high Low High Low
725 Traffic
Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on
the road network
Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak
hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road
network within Zone 6 of the IDZ (Iliso 2011)
Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)
Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of
quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-10
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on traffic and capacity of the N2 Regional Long
term Low High High Low
Impact on traffic and capacity of ring
road 1 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR435 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR450 Local
Long
term Low High High Low
Impact on traffic and capacity of
Neptune road Local
Long
term Low High High Low
726 Noise
Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Long
term Medium High High Medium Local Long term Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-11
727 Socio-economic
Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate
revenue for the municipality and the region as a whole
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Employment and economic growth Regional Short
term Medium High High Medium
73 COMPARATIVE ASSESSMENT OF IMPACTS
During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as
low during operation after mitigation
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 8-1
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
As a tenant operating in the IDZ Casa Steel will be required to comply with all
current and future CDC requirements as well as with the relevant conditions of
permits licences issued to CDC (eg Integrated Stormwater Masterplan for the
eastern side of the Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)
In particular the CDC has its own requirements regarding the monitoring of certain
aspects of the project such as the quality of the effluent and the noise levels These
have been incorporated into the EMP
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 9-1
9 ENVIRONMENTAL IMPACT STATEMENT
All predicted negative impacts can be mitigated to a low significance The only
exceptions are biodiversity as the construction of the plant will result in the
destruction of habitat and loss of fauna and flora and noise impacts inherent to
construction activities Mitigation measures have been included in the EMP for these
impacts and they have a medium significance post-mitigation
Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium to
long term similar impacts are likely to occur due to ongoing developments in the IDZ
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 10-1
10 CONCLUSION AND RECOMMENDATIONS
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as
other infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified
and assessed No fatal flaws have been identified
It is recommended that the project be approved subject to the conditions listed in
chapter 9 and adherence to the EMP requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 11-1
11 REFERENCES
Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ
Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants
Bennie JS (2010) The historical component (built environment) of the Heritage
Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port
Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report
compiled for Eastern Cape Heritage Consultants
Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater
Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay
Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage
Consultants
BKS (2006) Coega Industrial Development Zone Transport Study Volume 3
Demand Modelling Report Final Draft
Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I
Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6
Report compiled for SRK Consulting
Coastal amp Environmental Services (2010) Environmental Impact Assessment for the
Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone
Volume 3 Environmental Impact Assessment Report CES Grahamstown
Coega Development Corporation (2008) Industry Waste Management Plan -
Strategic Master Plan Report
Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants
Report No CDCSHE 03 8122
Department of Water Affairs and Forestry (1998) Waste Management Series
ldquoMinimum Requirements For The Handling Classification And Disposal Of
Hazardous Wasterdquo Second Edition
Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising
Plant in the Coega Industrial Development Zone
Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the
Coega Industrial Development Zone (IDZ) Specialist Water Study
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 11-2
Jacobs E (2008) Final Environmental Impact Report and Draft Environmental
Management Plan Proposed Steel Recycling and Processing Facility within the
Coega IDZ Report compiled for SRK Consulting
Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY
Galvanising Plant in the Coega Industrial Development Zone Waste Management
and Hazardous Substances Report compiled for ILISO Consulting
RSA National air quality standard for thoracic particulates (PM10) SA standards
(Government Gazette No 32816)
von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed
Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape
Report compiled for ILISO Consulting
von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel
Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report
compiled for ILISO Consulting
Additional sources
Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed
Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared
for Coastal Environmental Services
Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed
Kalagadi Manganese smelter in the Coega Industrial Development Zone Port
Elizabeth Eastern Cape Province Report prepared for Coastal Environmental
Services
Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia
steel recycling facility at the Coega Industrial Development Area Port Elizabeth
Prepared for SRK Consulting Port Elizabeth
APPENDIX A
LIST OF INTERESTED AND
AFFECTED PARTIES
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
DEDEARegional Manager
and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza
DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza
DEA Ocean and
CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza
DEA Ocean and
Coast
Oceanographer land-
based sources of
marine pollution
Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza
DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza
CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza
CDCEnvironmental
Project
Manager
Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza
TNPAPort of Ngqura
Environmental
Manager
Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet
NMBMEnvironmental
ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza
NMBMEnvironmental
ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza
DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza
DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza
WESSASenior Conservation
Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza
Zwartkops
ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700
hughlauegmailcom
zwartkopstrustiafricacom
SANParksNational Marine
CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza
Department Of
LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza
NMBM Air Quality
Division
Assistant
DirectorAir
Pollution and Noise
Templeton Titima 079 490 0574 Ttitimamandelametrogovza
NMBM Air Quality
DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza
NUMSARegional
RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
Department of
HealthNadiema
van der
Bergh083 378 2103
nadiemavanderberghimpiloecprovgov
za
DWA Chief Services
Officer
Joseph Jacobs 041 586 4884 jjacobsdwafgovza
EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza
NUMSecretary of union
officesZandile Xhentsa 043 743 6597 zxhentsanumorgza
DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza
Dynamic
CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom
EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza
Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza
UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom
lprincezago2uticom
Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza
Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza
Absa Mr Johann Steyn 082 3775820 johannstabsacoza
Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza
PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza
Universal
EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza
Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza
GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom
Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza
NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom
DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza
DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza
TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet
DWA Mr Landile Jack JackLdwagovza
DWA Ms Lizna Fourie FourieL4dwagovza
APPENDIX B
NOTICE OF ATMOSPHERIC
EMISSIONS LICENCE APPLICATION
AND ADVERTISEMENT
APPENDIX C
NOTICE OF COMMENT PERIOD FOR
DRAFT SCOPING REPORT
APPENDIX D
SUMMARY OF ISSUES RAISED AND
RESPONSES THERETO
April 2012
1
PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL
DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))
IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt
AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt
This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses
provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process
conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the
Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
2
IssueCommentQuestion Date
received Origin Response
1 Please provide more information with respect to the potential
dangers including the toxicity of the proposed project
07032011
By email
Wayne Poulton
(Bosun Brick
tenant at the
IDZ)
An Environmental Impact Assessment (EIA) was undertaken
which assessed the potential toxicity of the emissions and
effluent Mitigation measures were also recommended in the draft
Environmental Management Programme (EMP) to avoid
minimise or compensate any significant impacts The Draft
Environmental Impact Report and draft EMP were made available
to stakeholders for comment in March 2012
2 Do you have a Background Information Document (BID) or
similar that provides more information on the project
27032011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The BID was sent to all registered IampAPs on 4 May 2011
3 The RoD issued to the CDC on 632007 for the change in
land use for the remaining area of the Coega IDZ includes a
number of requirements with respect to
atmospheric emissions that should be considered in the
Atmospheric Emissions Licence (AEL) application such as
prohibiting and monitoring where possible visible emission
plumes to the atmosphere In particular the
recommendations on pp87-91 of the final revised Scoping
Report dated Nov 2006 must be implemented (clause 421)
04042011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
We have obtained copies of the documents referred to and ensure
that these requirements were taken into account in the
environmental assessment and AEL application
4 If the Port of Ngqura is used for import and export the scope
of the traffic impact assessment (TIA) should also include the
port
10052011
By email
Elliot
Motsoahole
(TNPA Port of
Ngqura)
The scope of the TIA was extended to include port related traffic
The TNPA at the Port of Ngqura was consulted and does not
have any objection to the project TNPA has indicated that the
development would require a minimum number of vessels per
year which would have minimal impact on the Port operations
However due notice would have to be given to the Port of Ngqura
before a vessel is scheduled to arrive so that the vessel can be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
3
IssueCommentQuestion Date
received Origin Response
accommodated at an available berth
5 Concerns with respect to potential stormwater pollution
draining into the Coega catchment and the port of Ngqura
The port needs to be dredged and heavy metals present a
risk in that regard
16052011
By
telephone
Andrew Lucas
(Department of
Water Affairs)
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination by effluent waste or
hazardousdangerous substances is very low
Thus no metals oils or other contaminants are expected to be
present in the stormwater
However stormwater pollution can occur in exceptional
circumstances such as accidents and emergencies The
emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
6 All steel sheets bathing unit must be under roof
7 The sludge out of the decreasing bath will be high in Na and
pH Therefore handling and disposal must be clarified up front
in this project
8 Per se the wastewater from decreasing bath will have high
ph and the component from the pickling unit will have low ph
Then it may be assumed that both streams will neutralize
each other Please then clarify proposed sewer discharge
with Nelson Mandela Bay Municipality up-front for acceptance
of influent as per the documented proposal
9 Pickling may result in dissolved metals How does your team
expect to deal with this As it is planned for discharge into
24052011
By email
Landile Jack
(Department of
Water Affairs)
All bathing units will be under roof
Effluent from the degreasing and pickling baths will be discharged
to the wastewater treatment plant The respectively alkaline and
acidic effluents will mix and neutralise each other in the
wastewater treatment plant Calcium or gypsum will be added if
required to complete the neutralisation process Effluent from the
treatment plant will be discharged to sewer Contact has been
made with the relevant officials and the Municipalityrsquos
requirements have been obtained The effluent discharged to
sewer will notably comply with the applicable discharge standards
Traces of metals (eg iron) may be present but will not exceed
prescribed thresholds The necessary authorisation will be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
4
IssueCommentQuestion Date
received Origin Response
sewer Clarity and acceptance needs to be agreed with
Nelson Mandela Bay Municipality Who owns the sewer
10 Quenching unit will results to Zinc particles How will this
affect sewer discharge This again must be dealt with within
the negotiations with the Municipality
11 Once all has been agreed with the Municipality and at the
same time due negotiations must be done with hazardous
waste courier and disposal facility to accept the hazardous
waste identified in all production lines
12 Of note is the low volume of the proposed WWTW facility ie
250 cubmweek And the no discharge of the quenching
water ie over-flow and cooling only Hence Zinc particles
generation
obtained from the municipality
The sludge from the treatment plant will be collected by a licensed
service provider and disposed of at a permitted site
The quenching bath will be periodically emptied (every 6 months)
and the water discharged will go to the water treatment plant Zinc
particles will settle in the sludge which will be disposed of at a
permitted site
Contact has been made with EnviroServ who manages the
Aloes II HH waste site regarding collection and disposal of
hazardous waste (See waste management report)
13 Investigate the potential effects of toxicity andor influence of
emissions waste and hazardous substances both in
terrestrial and marine fauna
14 With regards to water usage where is the plant going to
extract its waters used in galvanization andor waste
management process ie rainfall rivers or even from the
sea) and which avenues would be more environmental
friendly and effective
31052011
By email
A Bewana
(SANPARKS)
Emissions waste and hazardous substances are not expected to
affect terrestrial or marine ecosystems The air quality study
concluded that atmospheric emissions would not be harmful to
human health and by extension terrestrial fauna There are no
standards for air quality for defining faunal impacts therefore by
ensuring that standards for humans are complied with the impact
on fauna is deemed to be acceptable In this case the impact of
emissions on terrestrial and marine fauna are thus not significant
Solid and liquid wastes both general and hazardous as well as
hazardous substances will be stored handled and disposed of
appropriately to as not to cause harm to terrestrial or marine
fauna
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
5
IssueCommentQuestion Date
received Origin Response
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination and hence land-based
marine pollution by effluent waste or hazardousdangerous
substances is very low
The risk of emissions waste and hazardous substances to
terrestrial and marine fauna is thus very low
However pollution of terrestrial and marine ecosystems can occur
in exceptional circumstances such as accidents and emergencies
The emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
The CDC has an agreement with the NMBM to supply potable
water to the Coega IDZ Currently the infrastructure to supply
return effluent (RE) to the IDZ is not in place therefore Casa Steel
will be supplied with potable water up until such time as the
following 2 options of RE are available
1) Upgrading of the existing Fishwater Flats waste water
treatment works (between IDZ amp PE) including RE plant
and infrastructure to pipe RE to the IDZ (EIA for the
upgrade is underway)
2) Construction of a new waste water treatment works
including RE plant in Zone 9 of the Coega IDZ
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option should be investigated further between Agni and Casa The
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
6
IssueCommentQuestion Date
received Origin Response
CDC can facilitate discussions between the 2 investors
Compliance with CDC Permits amp Requirements
15 It should be made clear that tenants will be required to
comply with CDC requirements and the relevant conditions of
permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water
Licence for its Storm Water Systems on the
East Side of the Coega River that tenants will
need to take cognizance of The contents of the
ldquoIntegrated Stormwater Masterplan for the
eastern side of the Coega IDZ Oct 2010rdquo
especially the Table of best practice p53
onwards may need to be taken cognizance of
o CDC is developing an Operations
Environmental Management Plan that will place
certain obligations on tenants
16 Environmental audits and data collected during monitoring
(eg stack emissions stormwater) will need to be shared with
CDC
Air Emissions
17 Presumably permanent in stack monitoring will be required in
terms of AEL permit requirements
18 Abnormal operating conditions resulting in air emissions ndash I
could find nothing in the EIR to indicate under what
circumstances these could occur (eg start-up) potential
frequency and duration and the impact on ambient air quality
ndash these events usually result in the most problems wrt air
emissions
09042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
15 Compliance with the CDCrsquos Permits amp Requirements has
been included explicitly as a requirement in the EIR (p8-1) and
EMP (pp18 and 25) in the following terms
ldquoAs a tenant operating in the IDZ Casa Steel will be required to
comply with all current and future CDC requirements as well as
with the relevant conditions of permits licences issued to CDC
(eg Integrated Stormwater Masterplan for the eastern side of the
Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)rdquo
16 The need to communicate with the CDC on monitoring and
auditing activities was emphasised in Chapter 8 of the EMP The
following paragraphs were added
ldquoDuring construction the environmental officer will be responsible
for monitoring compliance with the EMP and authorisation
conditions and keeping records as required in the EMP andor
authorisation conditions
The ECO will conduct site inspections every two weeks audit the
records kept by the environmental officer and submit an
environmental compliance report every two months to the
authorities and the CDC (via the Environmental Monitoring
Committeersquos ECO)
During operation the health and safety officer will monitor
compliance with the EMP and the conditions of the Environmental
Authorisation Data collected during monitoring activities and any
environmental audits conducted will be shared with authorities
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
7
IssueCommentQuestion Date
received Origin Response
Water
19 Large volumes of (2000 m3mth) of water are required of
which only 400m3 needs to be potable The NMBM return
effluent system will provide non-potable water once it is
constructed What other water recycling initiatives can be
utilized to reduce potable water requirements (the ISWMP for
the eastern side of the Coega IDZ has some best practice
guidelines collecting rainwater from the roof etc)
General
20 There is no mention of how the CDC Architectural Guidelines
will be incorporated into the development (eg to prevent a
stark uniform warehouse type development)
21 Does NMBM have adequate fire services to cover this
development Apart from the large petroleum store are there
any other large fire hazards
22 Reports from the tenantrsquos ECO during construction and from
the SHE Officer during operations should be channeled to the
Coega Environmental Monitoring Committee This can be
directly or preferably via the EMCrsquos ECO (this will be while
the EMC and ECO are in place) A precedent has been set
for this in the Environmental Authorisations for Agni-Steel and
Kalagadi Manganese Smelter
23 All mitigation actions emanating from the EIR should be
summarized (preferably in a table) If compliance with them is
to be part of the Environmental Authorization from DEDEAT
then they (or the ones that DEDEAT deems to be applicable)
and the CDC (via the Environmental Monitoring Committeersquos
ECO)
The ECO (during construction) and the health and safety officer
(during operation) will report to the Coega Environmental
Monitoring Committee (EMC) via the EMCrsquos ECO (this will be
while the EMC and ECO are in place)rdquo
17 The draft EMP recommends regular monitoring of emissions
from the scrubbers and from the chromating process Additional
emissions monitoring requirements will be confirmed once the
AEL is issued Mention has been made in the EMP (pp11 and 19)
that all AEL conditions including monitoring and reporting
requirements should be adhered to
18 Abnormal emissions can occur in exceptional circumstances
Start-up will not cause abnormal emissions as the scrubbers
will be commissioned first and will be functioning once the plant
starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions
would be emitted as a building fugitive
The hourly hydrogen chloride ground level concentrations
(directly offsite) were predicted to be 239 microgmsup3 (based on the
emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits
as stipulated for listed activities for galvanising processes) using a
screen model which assumes worst case meteorological
conditions The health effect screening level for hourly HCl
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
8
IssueCommentQuestion Date
received Origin Response
should be attached to the EA as an Appendix (otherwise no
one knows about them or takes cognizance of them)
concentrations is 2100 microgmsup3 Assuming abnormal emissions
emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset
conditions will still be well within the health effect screening
levels
Similarly the hourly particulate emissions from the building
fugitives during upset conditions would amount to 293 microgmsup3
(based on the emission limits as stipulated for listed activities for
galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1
January 2015) directly off-site
Therefore if emissions are 5 times higher normal they will still be
within health effect screening levels and the daily PM10 NAAQS
levels
In the case of a fire a cocktail of gases and particulates could be
emitted and could be over the recommended levels This
situation will however be dealt with as an emergency and
normalised as quickly as is possible
The above has been added to the impact identificationdescription
and assessment sections of the EIR
19 The CDC has an agreement with the NMBM to supply
potable water to the Coega IDZ Currently the infrastructure to
supply return effluent to the IDZ is not in place therefore Casa
Steel will be supplied with potable water up until such time as the
infrastructure is in place
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
9
IssueCommentQuestion Date
received Origin Response
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option will be investigated further between Agni and Casa The
CDC has come forward to facilitate discussions between the two
investors
Other water recycling initiatives such as rainwater harvesting
have been considered but are not practical
20 The CDCrsquos Architectural and Landscape Design guidelines
contain requirements pertaining to such aspects as the height
orientation and mass and form of buildings as well as guidelines
for landscaping and signage in order to ensure an attractive
development and achieve an architectural integrity within the
Coega IDZ The plans for the proposed galvanizing plant will be
submitted to the Design Review Committee for approval as
required by the CDC
21 Casa Steel will be required to install fire hydrants according
to the NMBMrsquos standardsrequirements The CDC will provide
potable water (up until such time as return effluent is available)
and a connection to the boundary of the site which will be
connected to the fire hydrants The installation of the fire hydrants
will require approval by the Metrorsquos Fire Chief as was done for
Agni-Steel one of the investors in Zone 6
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
10
IssueCommentQuestion Date
received Origin Response
The Coega IDZ falls within the NMBM and therefore the rates and
taxes paid by the CDC covers the fire services for which the Metro
is responsible Currently the Metro has sufficient capacity to
provide fire services to the tenants within the IDZ This was
confirmed in discussion with the CDCrsquos Infrastructure
Development Unit It is however unknown at which point the
Metrorsquos Disaster Management Plan would not be able to
accommodate servicing tenants in the IDZ
The LNG burner is the only major fire hazard on the plant
22 See response to item 16 above
23 Key mitigation and management measures emanating from
the EIR were recapitulated in Chapter 9 of the EIR to form part of
the conditions attached to the Environmental Authorization from
DEDEAT All mitigation measures recommended as a result of the
impact assessment are presented in a table in the draft EMP
which is appended to the EIR (Appendix J)
24 Hydrogen chloride is one of the main emissions There are no
ambient air quality guidelines for HCl and the EIR says
concentrations will be well within health parameters
However the main problem with HCl is its corrosive effect -
there is absolutely no mention of this in the draft EIR nor air
specialist report
There needs to be some sort of comment assessment as to
whether HCl emissions are likely to impact on for example
the adjacent Agni-Steel Plant wrt corrosion - their factory
structure will be made of steel
11042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The atmospheric corrosion of metals is a complex process with
both the extent of deterioration and the mechanisms varying
considerably depending on the metal Depending on the way
pollutants are transported from the atmosphere to the corroding
surface two types of deposition processes are recognized in
atmospheric corrosion ndash dry deposition and wet deposition Wet
deposition refers to precipitation whereas dry deposition refers to
the remaining processes including gas phase deposition and
particle deposition The most important pollutants acting as
corrosive agents are sulphur and nitrogen compounds including
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
11
IssueCommentQuestion Date
received Origin Response
The EIR specialist rpt suggests monitoring HCl at ground
level on the property boundary and this is supported in case
there are complaints from neighbours
secondary pollutants and particulates Pollutants can contribute to
corrosivity individually however there may be a synergistic effect
when more than one of these pollutants is present in the
environment being affected In the field of atmospheric corrosion
sulphur dioxide is the single most investigated gaseous pollutant
and the quantification of the direct contribution of sulphur dioxide
to the corrosion process of metallic materials is comparatively well
understood (Tidblad amp Kucera 1998)
Very little work has reported on the effect of HCl on the
degradation of materials in the environment with no local dose-
response thresholds developed for corrosion occurring due to HCl
exposures This is probably because HCl which is present
outdoors in markedly reduced concentrations when compared
with SO2 has not been considered to contribute to significant
degradation of materials (Syed 2006) For this reason the
incremental corrosion due to HCl from the Coega Galvanising
Plant cannot be quantified
25 It is unacceptable for ILISO to be using CDC maps (see
figure 9 ndash pg5-6) without these maps being referenced
accordingly particularly when it appears that a CDC map has
been used and then overlaid with features by an unknown
author (ie CASA steel site Port (where the boundaries
depicted are incorrect) and a North legend which is out of
keeping with the overall cartographic intent of the original
work
26 Figure 10 is not referenced appropriately and I believe that I
commented previously in respect to references to roads not
12042012
By email
Graham Taylor
(Spatial
Development
Manager -
Infrastructure
Development
CDC)
This has been rectified in the final version of the report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
12
IssueCommentQuestion Date
received Origin Response
yet built As a result Figure 10 is confusing and clarity needs
to be provided in terms of referencing In addition the Port
shape is irregular and similar to the comment above
27 I acknowledge the emergency preparedness and response
plan but please confirm that this includes pro-active routine
monitoring of storm water leaving your premises to verify that
your assumptions of clean storm water are correct
13042012
By post
Andrew Lucas
(Director
WRampU
Department of
Water Affairs)
Pro-active routine monitoring of stormwater leaving the premises
will be undertaken This has been explicitly emphasised in
chapter 8 of the draft EMP
28 Will portablechemical toilets be used during construction
29 What provisions have been made for storm water drainage
during construction
18042012
By
telephone
Department of
Water Affairs
Port Elizabeth
Chemical toilets will be used during construction
The Casa Steel site will be located at the corner of two roads
drainage of stormwater from the site will take place through the
roadsrsquo drainage system
From Lea September [mailtoleailisocom]
Sent 11 March 2011 0935 AM
To Wayne Poulton
Cc Terry Baker
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Wayne
An Environmental Impact Assessment (EIA) will be undertaken for this project during the
next 10 to 12 months
We foresee that some of the key environmental impacts of the project will be in terms of air
quality water quality waste and hazardous substances
At this stage I am not able to give you any details regarding the potential toxicity of the
emissions andor effluent However specialist studies will be conducted as part of the EIA
that will determine the key impacts of the project Mitigation measures will also be identified
to avoid minimise or compensate any significant impacts
You are registered on the stakeholder database and you will be kept informed of progress in
the EIA process you will notably get the opportunity to access the reports produced and
provide any feedback on them
Please feel free to contact me should you need any further information
Best regards
Lea September
From Wayne Poulton [mailtowaynepbosuncoza]
Sent 07 March 2011 1257 PM
To Lea September
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
Please can you provide me with some more information as to the potential dangers including
the toxicity of this
Kind regards
Wayne
From Lea September [mailtoleailisocom]
Sent 04 March 2011 1123
To Lea September
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 March 2011 0745 AM
To Paul Martin
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 05 April 2011 0847 AM
To Paul Martin
Cc Terry Baker Renee von Gruenewaldt
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Thank you Paul for this information
I have downloaded a copy of the RoD and Scoping report you referred to and will make sure
these requirements are taken into account in the environmental assessment
Best regards
Lea September
From Paul Martin [mailtopmartinaxxesscoza]
Sent 04 April 2011 0955 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Further to my comments on 27311
Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in
the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega
IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised
scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions
including prohibiting and monitoring where possible visible emission plumes to the atmosphere
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Paul Martin
Sent Monday March 28 2011 745 AM
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 10 May 2011 0327 PM
To ElliotMotsoaholetransnetnet
Cc Terry Baker
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Mr Motsoahole
Thank you for your input on this issue
The Port of Ngqura will indeed be used for import and export At the moment the scope of
the traffic impact assessment only covers road traffic I have however relayed the matter to
our traffic specialist and we will consider this issue in the finalization of the Scoping Report I
will keep you informed of any developments in that regard
I trust this is acceptable to you
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]
Sent 10 May 2011 0855 AM
To Lea September
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
It has been noted that Casa Steel will source steel coils from various markets internationally and
in South Africa and the bulk of the plantrsquos production output will be exported to African countries
However there is no mention of logistic requirements
Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will
be used the scope of traffic impact assessment should also include the port
Regards
From Lea September [mailtoleailisocom]
Sent 04 May 2011 0747 AM
To Lea September
Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
Please find attached a letter announcing the EIA process underway for the proposed 80 000
tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as
a Background Information Document (BID) outlining the details of the project
Please contact me should you require any further information on this project
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
Elliot Motsoahole
Manager - Environment
Transnet National Ports Authority
Port of Nqqura
Port Control Building Klub Road Port Elizabeth 6212
PO Box 612054 Bluewater Bay 6212
+27 41 507 8450
+27 86 674 7729
Cell +27 83 542 5619
E-mail Elliotmotsoaholetransnetnet
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
DISCLAIMER The information contained in this communication is subject to copyright and
intended only for the use of leailisocom Unauthorised use disclosure or copying is
strictly prohibited Should a virus infection occur as a result of this communication the sender
will not be liable If you have received this communication in error please notify
elliotmotsoaholetransnetnet
From Lea September [mailtoleailisocom]
Sent 25 May 2011 1147 AM
To Jack Landile (ELS)
Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi
Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Landile
Thank you for your input
Contact has been made with the relevant Municipal Directorate and we will follow up with
them to obtain clarifications on all these issues
I have added both Lizna and yourself on the database and will keep you updated on
progress on this project
Best regards
Lea September
From Jack Landile (ELS) [mailtoJackLdwagovza]
Sent 24 May 2011 0524 PM
To Fourie Lizna (ELS)
Cc Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Hi Lizna
I missed you on this sorry
I linked Pieter twice Instead
Regards
Landile
From Jack Landile (ELS)
Sent 24 May 2011 0445 PM
To leailisocom
Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Lea
The e-mail you sent to Mr Kooverji dated 19 May 2011 refer
Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are
All steel sheets bathing unit must be under roof
The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project
Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal
Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer
Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality
Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines
Of note is the low volume of the proposed WWTW facility ie 250 cubmweek
And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles
generation
Regards
Landile
From Lea September [mailtoleailisocom]
Sent 19 May 2011 0947 AM
To Lea September
Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Stakeholder
Please find attached the remaining appendices to the draft Scoping report for the proposed
80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 June 2011 0411 PM
To Aphiwe Bewana
Subject RE Proposed 80 000 TPY Galvanizing plant in Coega
Dear Mr Bewana
Thank you for your input and apologies for the late reply
We have taken note of your comments and are will be taking them forward in the EIA phase
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Aphiwe Bewana [mailtoaphiwebewanagmailcom]
Sent 31 May 2011 1205 PM
To Lea September
Subject Re Proposed 80 000 TPY Galvanizing plant in Coega
Comment
Re Proposed 80 000 TPY Galvanizing plant in Coega
As SANParks we would like the EIA phase to investigate the potential effects of toxicity
andor influence of emissions waste and hazardous substances both in terrestrial and
marine fauna In the draft scoping report reference has been made with regards to the
terrestrial fauna but there is no attention to potential effects to marine fauna
Equally with regards to water usage where is the plant going to extract its waters used in
galvanization andor waste management process ie rainfall rivers or even from the sea)
and which avenues would be more environmental friendly and effective
Regards
Aphiwe Bewana
Marine Planner
South African National Parks
POBox 76693
NMMU
Port Elizabeth
6031
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 06 July 2011 1031 AM
To Lea September
Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Hi Lea
Irsquove reviewed the Final Scoping Report Herewith a few comments
1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the
Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a
revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the
NMBLP Please include only those in the IDZ as part of your IAP list
Regards
Andrea
From Lea September [mailtoleailisocom]
Sent Wednesday July 06 2011 859 AM
To Lea Septemberrsquo
Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Dear Stakeholder
The final scoping report for the above-mentioned project (attached) is available for comment
until 27 July 2011
The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic
commentaryrdquo tab
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 09 April 2012 1159 AM
To Lea September
Subject Comments on Galvanising Plant EIR Coega IDZ
Lea
Attached are my comments on the Draft EIR for the Coega IDZ galvanising
plant
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
Email attachment
COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ
Dr Paul Martin PO Box 61029
Bluewater Bay 6212 Tel 041 4665698
Email pmartinaxxesscoza
Compliance with CDC Permits amp Requirements
It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of
o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants
Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC
Air Emissions
Presumably permanent in stack monitoring will be required in terms of AEL permit requirements
Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions
Water
Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)
General
There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)
Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards
Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter
All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 11 April 2012 1245 PM
To Lea September
Subject Fw Comments on Galvanising Plant EIR Coega IDZ
Lea
One other comment on that I have on the Galvanising Plant Draft EIR
Hydrogen chloride is one of the main emissions There are no ambient air
quality guidelines for HCl and the EIR says concentrations will be well
within health parameters
However the main problem with HCl is its corrosive effect - there is
absolutely no mention of this in the draft EIR nor air specialist report
There needs to be some sort of comment assessment as to whether HCl
emissions are likely to impact on for example the adjacent Agni-Steel
Plant wrt corrosion - their factory structure will be made of steel
The EIR specialist rpt suggests monitoring HCl at ground level on the
property boundary and this is supported in case there are complaints from
neighbours
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Paul Martin ltpmartinaxxesscozagt
To Lea September ltleailisocomgt
Sent Monday April 09 2012 1158 AM
Subject Comments on Galvanising Plant EIR Coega IDZ
gt Lea
gt
gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising
gt plant
gt
gt
gt Dr Paul Martin
gt PO Box 61029
gt Bluewater Bay 6212
gt Tel 041 4665698
gt Cell 0732524111
gt email pmartinaxxesscoza
gt
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 12 April 2012 1139 AM
To Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Hi Lea
Hope yoursquore keeping well
I have requested comments from my colleagues and the CDC Casa team on the Draft EIR
Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report
Regards
Andrea
From Graham Taylor
Sent Thursday April 12 2012 838 AM
To Andrea Von Holdt Firhana Sam
Cc Johan Fourie Maria van Zyl Melikhaya Sihawu
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Andrea Firhana
Firhana if you could please ensure that the co-ordinates provided in the EIR correspond
with our records (pages 4-1 amp 4-2)
My comments are as follows
It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work
Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above
Regards
Graham Taylor
Spatial Development Manager - Infrastructure Development
Mobile 0832283055
Office 0414030454
Facsimile 0865185033
Email GrahamTaylorcoegacoza
Website wwwcoegacom
right PLACE | right TIME | right CHOICE
This email and all contents are subject to the following disclaimer
httpwwwcoegacomemaildisclaimerhtml
From Lea September [mailtoleailisocom]
Sent 04 May 2012 0411 PM
To Andrea Von Holdt
Cc Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Dear Andrea
We have taken note of the comments from the GIS Unit These issues have been rectified in
the final version of the EIR
Please can you forward to the relevant persons at the GIS Unit
Thank you
Best regards
Lea September
APPENDIX E
BACKGROUND INFORMATION
DOCUMENT
APPENDIX F
AIR QUALITY IMPACT ASSESSMENT
APPENDIX G
TRAFFIC IMPACT ASSESSMENT
APPENDIX H
WASTE MANAGEMENT AND HAZARDOUS
SUBSTANCES SPECIALIST STUDY
APPENDIX I
WATER QUALITY SPECIALIST STUDY
APPENDIX J
ENVIRONMENTAL MANAGEMENT
PROGRAMME
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 vii
The proposed galvanizing plant will make a positive contribution by creating jobs during
construction and operation and generating business for the various service providers
Fatal flaws
No fatal flaws have been identified
The significance of these potential key environmental impacts were assessed in the EIA
phase and the findings of this phase of investigations are presented in this report
The main findings of the EIA are as follows
During construction impacts post-mitigation are low with the exception of noise and
biodiversity as the construction of the plant will result in the destruction of habitat
and loss of fauna and flora and noise impacts inherent to construction activities
Mitigation measures have been included in the EMP for these impacts and they have
a medium significance post-mitigation
All impacts were assessed as low during operation after mitigation
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium
to long term similar impacts are likely to occur due to ongoing developments in the
IDZ
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
The CDC has its own requirements regarding the monitoring of certain aspects of the
project such as the quality of the effluent and the noise levels These have been
incorporated into the EMP Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as other
infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified and
assessed No fatal flaws have been identified
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 viii
It is recommended that the project be approved subject to the conditions listed above
and adherence to the EMP recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-1
1 INTRODUCTION
11 BACKGROUND
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)
Nelson Mandela Bay Municipality Eastern Cape Province
The demand for galvanised steel products is high in South Africa and Africa and is
expected to increase in the foreseeable future From an economic point of view the
proposed project has therefore been found to be viable
Casa Steel will source the steel coils from various markets internationally and in
South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is
destined to be exported mainly to African countries
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
An Environmental Impact Assessment (EIA) is required as the proposed project
involves several activities listed in terms of Section 24 of the National Environmental
Management Act (NEMA) No 107 of 1998 as amended and requires an
environmental authorisation
The following listed activities requiring environmental authorisation have been
identified
Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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
Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped
land to industrial use greater than 1 ha but less than 20 ha in size outside an
urban area
Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any
process or activity requiring a license in terms of national or provincial legislation
governing the generation or release of emissions
Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5
hectares or more of vegetation where 75 or more of the vegetative cover
constitutes indigenous vegetation except where such removal of vegetation is
required for
(i) purposes of agriculture or afforestation inside areas identified in
spatial instruments adopted by the competent authority for
agriculture or afforestation purposes
(ii) the undertaking of a process or activity included in the list of waste
management activities published in terms of section 19 of the
National Environmental Management Waste Act 2008 (Act No 59
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-2
of 2008) in which case the activity is regarded to be excluded from
this list
(iii) the undertaking of a linear activity falling below the thresholds in
Notice 544 of 2010
Hot dip galvanizing is a listed activity in terms of section 21 of the National
Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires
an Atmospheric Emissions Licence (AEL)
In addition the treatment of wastewater with an annual throughput capacity of more
than 2000 m3 is a listed activity in terms of the National Environmental Management
Waste Act 59 of 2008 and requires a waste management licence
ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental
Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact
Assessment process in terms of section 24 of NEMA for the construction and
operation of the proposed galvanizing plant The EIA process covers all aspects of
the project and informs all three applications (for environmental authorisation waste
management licence and AEL)
13 PURPOSE OF THIS REPORT
This report builds on the scoping report submitted to the Eastern Cape Department of
Economic Development and Environmental Affairs (DEDEA) and the Nelson
Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It
describes the proposed project and presents the findings of the second phase of
investigations (EIA phase)
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP)
The EIA was managed by Ms Terry Baker a certified Environmental Assessment
Practitioner with 20 years of working experience She has a MA in Environmental
Management and specialises in Environmental Impact Assessments and Project
Management She has been involved in a variety of different types of EIAs including
for water supply projects dams transmission lines roads and airports in South
Africa Botswana Uganda Lesotho and Mozambique She has been involved in
water resource management and public participation programmes on a number of
projects Terry has also been involved in the use of Geographic Information Systems
environmental status quo reports water quality assessments socio-economic and
institutional development projects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-3
15 PROJECT TEAM
In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen
(water quality specialist) and Lea September (EAP) with specialist input from Renee
von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous
substances) and Seniel Pillay (Traffic Impact Assessor)
The Business Unit Head of the ILISO Environmental Management Discipline Group
Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is
a Fellow of the South African Institution of Civil Engineers a member of the South
African Society of Aquatic Scientists of the Environmental Scientific Association of
the International Water Association of the Water Institute of South Africa and of the
Vaal River Catchment Association He is a certified Environmental Assessment
Practitioner with 30 years experience who specialises in project management
environmental impact assessments and water resource planning He specifically has
extensive experience in water quality especially water quality management water
quality monitoring and water quality assessment Martin has experience in managing
projects that involve multi-disciplinary teams and public consultation and
participation in South Africa and abroad
Lea September is an Environmental Assessment Practitioner with a Masters degree
in Environmental Management She has experience in impact assessment and
environmental management and has been responsible for drafting impact
assessment reports and Environmental Management Programmes and conducting
public participation processes as well as high level environmental screenings for a
variety of projects in the energy water transport and industrial sectors
Renee von Gruenewaldt has nine-years experience in the field of air pollution
impact assessment and air quality management Prior to becoming involved in air
quality consultation she was part of the Highveld Boundary Layer Wind Research
Group based at the University of Pretoria Since joining Environmental Management
Services (the company now Airshed Planning Professionals) she has undertaken
numerous air pollution impact studies and has provided extensive guidance to both
industry and government on air quality management practices
Pieter Smuts graduated as a Civil Engineer and became involved in the field of
municipal engineering and infrastructure construction He has specialized during the
last twelve years in solid waste management He has completed waste management
plans feasibility studies and final designs of waste management facilities in South
Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and
the review of the Mavoco hazardous waste landfill design in Maputo Mozambique
and completed a study on hazardous waste (textile factory sludge) management in
Maseru Lesotho
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-4
Seniel Pillay is a transportation engineer with over 16 years experience in
transportation planning and traffic engineering He has been involved in a wide
range of projects ranging from developing the Transport Operations Plan for the
FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System
for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller
traffic impact assessments for inter alia road improvement schemes Of particular
relevance to this project his experience includes Heavy Goods Vehicle Study for
eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact
Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash
Preliminary Transportation Assessment
16 STRUCTURE OF THIS REPORT
The proposed project and the alternatives considered are described in Chapter 2
Chapter 3 details the approach adopted for the EIA phase
The biophysical and socio-economic environment affected by the activity is described
in Chapter 4
The environmental impacts identified are discussed in Chapter 5
The EIA methodology is described in Chapter 6 and Chapter 7 presents the results
of the impact assessment
The environmental impact statement is presented in Chapter 8
Finally Chapter 9 spell out the conclusions and recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-1
2 DESCRIPTION OF THE PROPOSED PROJECT
21 TECHNICAL ASPECTS
211 The galvanizing process
Galvanizing consists of coating steel with zinc in order to protect it from corrosion
Before steel strips can be galvanized they undergo a pre-treatment in order to
ensure that the steel sheets are free from any surface oxides as they enter the
molten zinc coating Bath This is done by removing the oil from the steel sheets (in
the degreasing unit) and then removing the rust from the surface of the sheet (in the
pickling unit)
The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The
melting zinc on the strip surface will be cooled and solidified through air cooling in the
cooling tower
Finally the galvanised steel sheets are dipped into a water quenching tank in order to
further cool the sheets from about 150degC to 40degC
It is possible to make galvanised steel more durable by chromating it Approximately
50 of the galvanised steel production output will receive chromate passivation
treatment after quenching the galvanised steel sheets will be sprayed with a chrome
solution (3 kgcm2)
After galvanizing and chromating the steel sheets are cut to achieve the desired coil
size and weight and transported to the storage yard
The process flow diagram below (Figure 1) illustrates the main stages of the
galvanizing process and indicates the major inputs and outputs as well as the
resulting effluent and atmospheric emissions
Draft Environmenal Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-2
Figure 1 Process flow diagram for proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-3
212 Main inputs and outputs in operational phase
In view of the above the main inputs will be as follows
Steel coils 85 000 tonsyear
Zinc 870 tonsyear
Electricity 2500 kVA
Water 2000 m3month (of which 400 m3 will be potable water)
Liquid Natural Gas (LNG) 270 NM3hour
Sodium hydroxide (NaOH) 1000 m3year
Hydrochloric acid (HCl) 800 m3year
Chrome (Cr+3) 10 m3year
The main outputs will be
Galvanized steel 80 000 tonsyear
Scrap metal 20 tonsyear
General waste 65 tonsyear
Hazardous waste 2 m3month
Wastewater 012 Mlweek
Atmospheric emissions lt 5 ppm
213 Installations on site
The bulk of the operations involved in the galvanizing process occur along a
continuous galvanizing line (See Figure 2 below) which is the main piece of
machinery required for the proposed galvanising plant
Figure 2 Continuous Galvanizing Line
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-4
Water is one of the major inputs and is used throughout the galvanizing process notably
for rinsing and cooling purposes and as a mixing agent for the various chemical
solutions The plant will have a water treatment plant on site to treat the water used in
the various processes (approx 250 m3
of wastewater per week) The wastewater
treatment facility will be operated by a professional water treatment company as Casa
Steel does not have the required expertise in house to treat its process water Sulphuric
acid (H2SO4) is used as part of the treatment process to reduce caustic soda The
neutralised water is discharged to the sewer while any sludge is disposed of as
hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)
will be disposed of
Some critical areas of the galvanizing process such as the zinc pot require uninterrupted
power It is therefore proposed to install an LNG burner to maintain the zinc bath at a
temperature of between 450 and 460degC
22 LOCATION OF THE PROPOSED GALVANIZING PLANT
The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast
of Port Elizabeth in the Eastern Cape (Figure 3)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-5
Figure 3 Location of the proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-6
23 NEED AND DESIRABILITY
The profitability of the proposed project has been established by Casa Steel and a
pre-feasibility study has confirmed that the proposed project was feasible from a
technical and financial point of view The Coega IDZ is specifically designed to host
facilities such as a galvanizing plant and can provide the necessary infrastructure
and services to its investors It therefore constitutes a very suitable location for the
project
24 ALTERNATIVES IDENTIFIED
Zone 6 has been specifically earmarked for heavy ferrous metal industries and is
therefore a suitable location for the proposed galvanizing plant as such no site
alternatives have been provided for and assessed in this EIA However prior to the
commencement of the EIA process Casa Steel was presented with a number of
different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the
selection of the site were
(a) The dimensions of the land the site should be at least 200 m long and
50 m wide in order to accommodate the galvanizing line and adjacent lay
down area and additional land should be available next to the site for future
expansion
(b) The fiscal arrangements applying to the site the site should be located
within the future Custom Controlled Area (CCA) as the bulk of the
production output of the plant will be exported
The no-go alternative is assessed in this report
25 CONSTRUCTION ASPECTS
The construction phase of the project will take about 12 months and will essentially
consist of erecting a building to house the galvanizing line and other equipment and
preparing a concrete laydown area adjacent to the building
The CDC will provide an access point from the existing tarred road that will lead to
the site
Approximately 100 workers from the surrounding areas will be contracted for the
construction work
The requirements in terms of services during construction are listed below
Water 1000 m3month
Electricity 2500 kVA
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-7
The CDC will provide temporary services for the construction phase including a
conservancy tank for flush toilets Sewage infrastructure will only be provided for the
operational phase
26 OPERATION ASPECTS
Before the plant can become fully operational the equipment and machinery will be
tested for approximately 3 months The supplier will supervise these tests as part of
the transfer of know-how and training of staff on the plant
Casa Steel will start operating the plant at a reduced capacity (about 50 000
tonsyear) for a period of time (mostly determined by market aspects) before bringing
production to full capacity (80 000 tonsyear) This is done by operating the line for
longer hours
Approximately 50 to 60 people will be working on the plant Approximately 6-10 of
these will be unskilled 40-45 skilled and about 5 people in managerial positions
The requirements in terms of services during operation are as follows
Water 2000 m3month
Electricity 2500 kVA
Effluent discharge 24 m3day
The CDC has entered into agreements with the municipality to secure the provision
of services such as water and electricity to its tenants Tenants in the IDZ have their
own agreements with the NMBM for electricity while the agreements for water and
sewage are with the Facilities Unit of the CDC
Regarding discharge of wastewater to the sewer the municipality indicated that the
only requirement is that the water discharged complies with applicable municipal
discharge standards
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 3-1
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT
31 OBJECTIVES
The main objectives of the EIA phase are to
Assess the significance of the environmental issues and impacts identified in the
scoping phase focusing on key impacts
Recommend appropriate measures to mitigate negative impacts and enhance the
benefits and include them in the draft EMP
Undertake a public participation process that provides opportunities for all
interested and affected parties (IampAPs) to be involved
32 AUTHORITY CONSULTATION
The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental
Liaison Committeersquo (ELC) which comprises representatives of various authorities
including DEDEAT the Department of Environmental Affairs (DEA) and Department
of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the
Coega Development Corporation (CDC) and Transnet National Ports Authority
(TNPA) The ELC has been specifically formed to facilitate EIA applications in the
IDZ
Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to
the clearance of vegetation should be included in the application A formal request
was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the
application and all registered stakeholders were informed of the request in writing on
19 October 2011
33 PUBLIC PARTICIPATION PROCESS CONDUCTED
On-site notices were replaced by a notification displayed on the CDCrsquos digital notice
board at the business centre in Zone 1 of the IDZ The eNotice was placed on
13 April 2011 and will remain for the full duration of the EIA process
Registered stakeholders will be notified in writing of the availability of the draft EIA
report and EMP which will also be advertised in a local newspaper Stakeholders
including state departments and the public will have forty (40) days to comment on
the draft EIA report and EMP The draft EIA report and EMP will be sent by email
where possible and made available for download on the ILISO website
(wwwilisocom)
A summary of all issues and comments received during the stakeholder consultation
process as well as of correspondence in that regard will be captured in an Issues
and Responses Report that will form an Appendix to the EIA Report
The list of registered IampAPs is included in Appendix A
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 3-2
34 LEGISLATION AND GUIDELINES CONSIDERED
The following legislation and guidelines were considered in the preparation of this
report
National Environmental Management Act Act No 107 of 1998
NEMA EIA Regulations 2010
National Environmental Management Air Quality Act Act No 39 of 2004
National Environmental Management Waste Act Act No 59 of 2008
Hazardous Substances Act Act 15 of 1993
Occupational Health and Safety Act Act 85 of 1993
Hazardous Chemical Substances Regulations 1995 (GNR 1179)
Major Hazard Installation Regulations 2001 (GNR 692)
National Water Act Act 36 of 1998
National Heritage Resources Act Act 25 of 1999
DEAT Integrated Environmental Management Information Series 1-5 and 12-15
NEMA draft Implementation Guideline
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Public Participation (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Alternatives (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Draft Guideline for Determining the Scope of Specialist
Involvement in EIA Processes (2005)
IAIA guidelines
National air quality standard for thoracic particulates Government Gazette
No 32816
Listed activities and associated minimum standards identified in terms of section
21 of the National Environmental Management Air Quality Act Act No 39 of
2004 Government Notice 248 of 2009
Minimum Requirements for the Handling Classification and Disposal of
Hazardous Waste DWAF Waste Management Series (1998)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-1
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION
The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega
IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay
to the north of the N2 highway between Port Elizabeth and Grahamstown east of the
Coega River
The co-ordinates of the corners of the site are shown in Table 1
Table 1 Coordinates of site corners for the proposed galvanizing plant
Point Longitude Latitude
A 25deg411126E 33deg45587S
B 25deg411156E 33deg45499S
C 25deg411938E 33deg45131S
D 25deg412174E 33deg45481S
E 25deg412508E 33deg45979S
F 25deg412634E 33deg451160S
G 25deg411782E 33deg451560S
H 25deg411692E 33deg451428S
J 25deg411314E 33deg45868S
Figure 4 Zone layout in the Coega IDZ
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-2
Figure 5 Site location
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-3
42 SOCIO-ECONOMIC CHARACTERISTICS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the
NMBM There are no residents within the IDZ
As far as the broader NMBM and Eastern Cape Province are concerned the
following can be noted The NMBM is located within the Eastern Cape Province the
2nd largest Province in South Africa (3rd in terms of population) characterised by a
predominantly black population with low incomes and high levels of unemployment
(CES 2010)
The NMBM has a population of just above 11 million and covers an area of
1 950 km2 It is the main urban and industrial centre of the province and Port
Elizabeth in particular which forms part of the NMBM is the commercial capital of
the Eastern Cape 52 of the NMBM population is female and 37 is below the
age of 20 these two groups are particularly affected by unemployment
43 BIOPHYSICAL CHARACTERISTICS
431 Surface and ground water
No rivers occur in Zone 6 There is however a natural attenuation pond on the
southern most part of the site which will have to be avoided
The IDZ is underlain by calcrete sand and gravel deposits that overlie low
permeability clays These clays limit the vertical infiltration of rainwater and induce a
horizontal groundwater flow towards the Coega River channel which is the most
significant surface water feature in the Coega IDZ Consequently rapid run-off takes
place following precipitation (Jacobs 2008)
Groundwater levels at Coega are generally about 3 to 5 m below surface ie just
above the contact between the permeable sands and the underlying impermeable
clays The groundwater flow direction is to the southeast following the surface water
drainage direction (Jacobs 2008)
432 Climate and atmospheric conditions
Port Elizabeth has a warm temperate climate and the temperature ranges are not
extreme Exceptionally high temperatures may be experienced during berg wind
conditions which occur frequently during autumn and winter Extreme temperatures
also occur during summer with little accompanying wind
The wind regime for the area largely reflects the synoptic scale circulation with
dominant westerly and northwesterly flow fields representing the pre-frontal
conditions and south-westerly flow fields representing the frontal conditions The
south-easterly and south-westerly wind flow (land breeze) increases during daytime
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-4
conditions with westerly and north-westerly wind flow increasing during the night (sea
breeze)
The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of
Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15
km southwest) and Port Elizabeth (~23 km southwest)
An ambient air monitoring network has been established in the Coega IDZ which
consists of three monitors Saltworks Motherwell and Amsterdamplein Although
NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative
impacts due to the proposed Galvanising Plant is PM10 A maximum daily average
PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed
SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3
was exceeded on 17 days in 2007 and 26 days in 2008
Existing sources of emissions in the vicinity of the proposed galvanizing plant include
industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other
fugitive dust sources (von Gruenewaldt 2011b)
433 Geology and soils
Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel
and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly
limestone and conglomerate
434 Terrestrial ecology
This section draws from the EIA report compiled for the Agni Steel (formerly Afro-
Asia) steel processing facility which is adjacent to the proposed site for the
galvanizing plant (Jacobs 2008)
The area consists largely of grasses succulents and scrubby bush with alien
species making up the greater part of the more dense vegetation
Zone 6 falls within the inland vegetation and is characterised by a vegetation type
referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the
Coega IDZ and has been found to have three times the level of endemism of other
vegetation communities in the Coega IDZ Bontveld therefore has a high
conservation status Two Bontveld conservation areas have been identified within the
IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)
Bontveld that will be destroyed as a result of development in the IDZ will be given
conservation status in these two areas
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-5
Figure 6 Coega IDZ Open Space Management Plan (OSMP)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-6
Certain areas in the IDZ are invaded by alien plant species The most common
invader species is rooikrans (Acacia cyclops) which presently forms large
monospecific stands in areas throughout the Coega IDZ There are several other
aliens present that pose a threat to the flora of this area including the prickly pear
(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)
Loss of vegetation and alien plant invasion due to human activity has resulted in a
reduction in the diversity of terrestrial fauna
The majority of mammals present in the Coega IDZ are small or medium-sized Of
the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed
gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of
Algoa Bay however it is not considered threatened The gerbil is common in
foredune and dune thicket habitat in the Coega region and is therefore unlikely to
occur on the proposed site
A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird
species are resident or common to the area Most diversity occurs in the thicket
although the coastal area also supports specialised avifauna Two species of tern
the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well
as the Cape gannet (Morus capensis) and the African penguin (Spheniscus
demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne
caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant
(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser
flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns
are two of the most endangered coastal species in South Africa Other bird species
of conservation concern include the Whitefronted plover (Charadrius marginatus)
African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus
bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus
ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides
paradisea) Breeding pairs of Damara terns and African black oyster catchers have
been observed in the coastal dunes of the IDZ but should not be affected by
developments that fall outside the dune areas
The Eastern Cape supports nearly a third (approximately 133 species) of the reptile
species recorded in South Africa More than half of the Eastern Capersquos endemic
reptile species occur in the Algoa Bay area giving the region a high conservation
value A total of 63 reptile species are believed to occur within the Coega IDZ The
majority of these are found in Succulent Thicket and riverine habitats Only a few
reptile species occur in the coastal dunes and estuarine habitats More than a third of
the species are described as relatively tolerant of disturbed environments provided
that migration corridors of suitable habitat are maintained to link pristine habitats
Twenty two reptiles are of special concern including five endemic species (two of
which may also be endangered) four endangered sea turtles eight species listed
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-7
with CITES one rare species and four species at the periphery of their range
Fourteen of these species of special concern are confirmed as occurring on or within
2 km of the Coega IDZ
A total of 32 amphibian species and sub-species occur in the Eastern Cape
representing almost a third of the species recorded in South Africa However none of
the species are endemic or Red Data Book species Based on previous studies in the
area it is estimated that approximately 17 amphibian species occur within the Coega
IDZ Four species are listed as peripheral but none are threatened internationally
These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog
(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and
the bubbling kassina (Kassina senegalensis)
The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated
vegetation has not been extensively studied One grasshopper species Acrotylos
hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue
(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis
pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in
four localities in the Eastern Cape one of which is within the Coega IDZ The Coega
copper Aloeides clarki is endemic to this particular region of the Eastern Cape and
is currently known to occur in three localities two of which are in the Coega IDZ The
localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the
Coega IDZ and their distributions were taken into account when defining Coegarsquos
open space system and Development Framework Plan
435 Land use and topography
The land is currently undeveloped and earmarked for industrial development The
site is relatively flat ranging from an elevation of 66 masl on the northern-most
corner to 59 masl at the southern-most corner
436 Heritage and archaeological survey
Extensive studies have been undertaken in Zone 6 with respect to heritage aspects
Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a
2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond
2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is
currently being finalised
Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing
Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha
in extent and was located next to the R102 road to Motherwell Kaplan conducted
HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi
Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will
now be located in Zone 5)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-8
The various archaeological investigations reached similar observations and
conclusions Stone tools of various densities and types were found throughout the
zone The majority of the stone tools were mainly of Earlier and Middle Stone Age
and occasional Later Stone Age origins (Figure 4)
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble
gravels exposed by tracks in Zone 6 (Source Binneman 2010)
The stone tools which comprised of quartzite flakes chunks flaked pebblecobble
and cores were randomly distributed across the landscape and are in secondary
context There were no lsquoconcentrationsrsquo of tools observed which suggested any
spatial patterning or activity areas although these may be present or covered by soil
and vegetation
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 5-1
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED
The following environmental issues and potential impacts were identified in the
Scoping phase
51 AIR QUALITY
The galvanizing process generates atmospheric emissions with particulates and
hydrogen chloride representing the main pollutants of concern The plant is fitted with
air extraction as well as scrubber systems which are designed to retain the bulk of
pollutants and particles for each of the processes in such a way that less than 5 ppm
of gases and particles will be released into the atmosphere after the fume scrubber
Other sources of impact on air quality include emissions from the LNG burner as well
as emissions and dust from the transport of steel and other materials in trucks
Construction activities will also create dust and gas emissions due to the clearing of
groundcover tipping of material to storage pile levelling of area wind erosion from
storage piles vehicle and construction equipment activity and tailpipe emissions
from vehicles and construction equipment such as graders scrapers and dozers
Overall the air quality impact assessment (Gruenewaldt 2011b) found that
The predicted particulate oxides of nitrogen carbon monoxide and sulphur
dioxide concentrations are all below the National Ambient Air Quality Standards
for all averaging periods
The predicted off-site concentrations of hydrogen chloride are well below the
most stringent effect screening levels
No odour threshold exceedances for hydrogen chloride were predicted to occur
due to routine operations at the Steel Galvanising Plant The South Wales
Environmental Protection Authority stipulates that an odour unit of 20 is
acceptable for urban areas The odour unit would be lt10 directly off-site for
hydrogen chloride
Abnormal emissions can occur in exceptional circumstances Start-up will not
cause abnormal emissions as the scrubbers will be commissioned first and will be
functioning once the plant starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions would be emitted as a
building fugitive
The hourly hydrogen chloride ground level concentrations (directly offsite) were
predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based
on the emission limits as stipulated for listed activities for galvanising processes)
using a screen model which assumes worst case meteorological conditions The
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-2
health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming
abnormal emissions emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset conditions will still
be well within the health effect screening levels
Similarly the hourly particulate emissions from the building fugitives during upset
conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for
listed activities for galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly
off-site
Therefore if emissions are 5 times higher normal they will still be within health effect
screening levels and the daily PM10 NAAQS levels
In the case of a fire a cocktail of gases and particulates could be emitted and could
be over the recommended levels This situation will however be dealt with as an
emergency and normalised as quickly as is possible
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS
The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of
its heritage potential and there are no proposed protected geosites in Zone 6
Should any artefacts be discovered during construction procedures stipulated in the
draft EMP will apply
53 BIODIVERSITY AND CONSERVATION
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
In terms of terrestrial fauna the CDCrsquos open space management plan provides for
the preservation of certain corridors The destruction of certain habitats as a result of
the development will therefore not automatically result in the loss of certain species
54 WATER QUALITY
There is a natural attenuation pond on the southern most part of the site which will be
avoided
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through
spills or leaks
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-3
This risk can however be minimized if not avoided altogether The floor of the factory
will be designed as a bunded area to contain any spills and the entire process will be
contained Potential spills or leaks will therefore be contained and will not impact on
water resources Storm water is therefore considered clean water under normal
operational conditions An oil trap will be placed at the exit of the site to ensure that
no grease from the laydown area enters the stormwater system
Spills and leaks can occur during the handling or the transport of hazardous
substances Best practice guidelines will be followed to ensure that this risk is
adequately managed
Wastewater discharged to sewer will be treated to comply with municipal discharge
standards and is not expected to have an impact on the chemical characteristics of
the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be
discharged from the plant is small in relation to the total volume received at the
Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works
(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently
operated at 61 of its capacity which is approximately 80 Mℓday Thus the
0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore
not have any significant impact on the WWTW
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES
The plant will generate a relatively small amount of solid waste in the form of scrap
metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)
The scrap metal may be sold to other steel processing facilities such as Agni Steel
which will be located next to the plant or collected and disposed of with the rest of
the solid waste by a licensed service provider
As mentioned previously there will be a wastewater treatment plant on site which will
neutralise process water (012 Mlweek) in order to ensure it is of a standard
acceptable for discharge to sewer Waste in the form of sludge from the
neutralization or spent acid must be disposed of as a hazardous waste Solid waste
from the filters used for air quality control is also in this category These wastes can
usually be tested and then delisted which means that it can be placed in a general
purpose landfill
Hazardous effluent from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-
site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored
and removed on a monthly basis is limited to 10 m3
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-4
A number of substances classified as hazardous are used in the galvanizing process
(Table 2) and the transport and handling of these is subject to certain rules and
guidelines In particular the material safety data sheets (cf Appendix H) should be
referred to for inter alia hazards identification accidental release measures
handling and storage precautions exposure controlpersonal protection ecological
information and transport information The Hazardous Chemical Substances
Regulations 1995 should also be adhered to in respect of the transport and storage
of hazardous chemical substances
Table 2 Hazardous materials to be used on site
Major Input Materials
Substance
listed in the
SABS 0228
Group II
hazardous
substances
Volumes to be
stored on site at
any one time
Diesel radic 2000 litres
Liquid petroleum radic 20 000 liters
Sodium hydroxide (NaOH)
(used for degreasing) 8 radic 1000m
3
Hydrochloric acid (HCI)
(used for pickling) 8 radic 800m
3
Zinc (used for galvanising) - TBD
Trivalent chromium (CR+3
)
(used for chromating) 8 radic 10m
3
Sulphuric acid (H2SO4) (used for
treatment of waste water on site) 8 radic TBD
Ammonium Hydroxide (NH4OH) 8 radic TBD
TBD ndash To be determined
Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one
time) and is classified as a flammable substance Specification for flammable storage
facilities in accordance with the requirements of the Nelson Mandela Bay
Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for
quantities between 5000 and 20 000 liters the substance must be kept in a
flammable liquid store which complies with the requirements of a specification
obtainable from the Department Some of the requirements are
Flammable liquid and solid storage facilities are only permitted on the ground
floor
Decanting of flammable liquids and solids are not permitted within any building
Due to the fact that there are flammable materials on site a certificate may be
required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and
Emergency Services Department to confirm that facilities for flammable storage
are in accordance with their requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-5
Because of the permanent installation and high quantity of liquid petroleum on site
the Major Hazard Installation Regulations 2001 promulgated under the Occupational
Health and Safety Act No 85 of 1993 applies A written application for approval of
the installation is required to be submitted to the chief inspector Department of
Labour provincial director Department of Labour and NMBM prior to construction
In addition a risk assessment should be formulated covering all hazardous materials
together with an emergency preparedness and response plan
56 HEALTH AND SAFETY
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling instructions as well as occupational exposure limits
are indicated in the material safety data sheets of the various substances used
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as
provide site supervision including executing tests (individual test cold run and hot
run) during 3 months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the
EMP
In addition the emergency preparedness and response plan will cover the health and
safety aspects related to emergency situations
57 TRAFFIC
The volumes of traffic at the IDZ are currently relatively low and variable depending
on the different zones in the IDZ however these volumes will increase as more
developments are implemented
The construction phase of the Casa Steel development will take about 12 months
and will essentially consist of erecting a building to house the galvanizing line and
other equipment and preparing a concrete laydown area adjacent to the building
The traffic that would be generated during the construction phase can be expected to
be less than the traffic that would be generated by the Casa Steel development when
it is fully operational
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-6
In the operation phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and
from the Port of Ngqura
The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the
Casa Steel development would be off Ring Road 1 The other roads of significance
for the Casa Steel development are the N2 Neptune Road MR435 and MR450
Access to the port is given by Neptune Road Road Link NEP-03 has not yet been
built
Figure 8 Coega IDZ road network identification
(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-7
Figure 9 Coega IDZ road network
Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No
01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-8
The distribution of freight trips is fixed as the majority of trips will be made between
the Port of Ngqura and the Casa Steel site With regard to personnel trips there are
various points of origins (the surrounding residential areas) that could be used by
staff going to the Casa Steel site The distribution of personnel trips is based on
existing traffic count information and is shown in Figure 10
Figure 10 Trip distribution for freight and personnel trips
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The resultant expected Casa Steel traffic assignment is shown in Figure 11
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-9
Figure 11 Morning peak hour Casa Steel development traffic
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The traffic that is expected to be generated by the Casa Steel development is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low
and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)
Consultation has taken place with Transnet Port Authority (TPA) to establish the
impact of the galvanizing plant operations on traffic inside the port The additional
ships entering and exiting the port of Ngqura as a result of the proposed development
will have a negligible impact on port traffic and TPA indicated that it would be well
within the portrsquos capacity
58 NOISE
Noise is not foreseen to be a significant issue insofar as the noise levels inside the
plant and at the boundary of the site will not exceed the limits prescribed by the CDC
Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels
during the day and 60 decibels at night
Mitigation of noise impacts will be addressed in the design of the noise-emitting
components of the plant and their enclosures
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-10
59 SOCIO-ECONOMIC ASPECTS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of
NMBM There are no residents within the IDZ
The direct socio-economic impacts of the proposed project are thus limited to the
employment generated by the project during construction and operation Job creation
remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)
and the IDZ and Port of Ngqura are expected to become a significant catalyst to the
economic growth of the Municipality and the region with current investments at
Coega creating more jobs and stimulating the economy
In this context the proposed galvanizing plant will make a positive contribution
towards the achievement of these goals
There will be 50 to 60 employees during operation phase distributed as follows
Figure 12 Casa Steel organisation chart
Even though a large part of the inputs will be imported and the bulk of the production
output will be exported there will be some positive impacts for the economy of the
region and of South Africa in general Notably the requirements of the plant for
water electricity waste collection and disposal waste water treatment and transport
for example will create business for the various service providers and have an
indirect impact on employment and fiscal revenues as a result
From a visual impact point of view it can be anticipated that the landscape in the IDZ
will be significantly affected over time by developments related to the establishment
of the port and various industries
HEAD ( WORKS )
MGR ( COMM) MGR ( ADMNHR ) Manager marketing
MANAGER OPERATION MANAGER MANAGER MANAGER Q C
AC FIN PUR ampSTORE
PPC SH-GALV SH-tech
SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF
1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO
JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF
2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO
WORKERS WORKERS 7NOS
15 7
RAW MAT amp
DESP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 6-1
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
A description of the nature of the impact any specific legal requirements and the
stage (constructiondecommissioning or operation) will be given Impacts are
considered to be the same during construction and decommissioning The
significance of the potential impacts will be considered before and after identified
mitigation is implemented
The following criteria will be used to evaluate significance
Nature The nature of the impact will be classified as positive or negative and
direct or indirect
Extent and location Magnitude of the impact and is classified as
Local the impacted area is only at the site ndash the actual extent of the activity
Regional the impacted area extends to the surrounding immediate and
neighbouring properties
National the impact can be considered to be of national importance
Duration This measures the lifetime of the impact and is classified as
o Short term the impact will be for 0 ndash 3 years or only last for the period of
construction
o Medium term three to ten years
o Long term longer than 10 years or the impact will continue for the entire
operational lifetime of the project
o Permanent this applies to the impact that will remain after the operational
lifetime of the project
Intensity This is the degree to which the project affects or changes the
environment and is classified as
o Low the change is slight and often not noticeable and the natural functioning
of the environment is not affected
o Medium The environment is remarkably altered but still functions in a
modified way
o High Functioning of the affected environment is disturbed and can cease
Probability This is the likelihood or the chances that the impact will occur and
is classified as
o Low during the normal operation of the project no impacts are expected
o Medium the impact is likely to occur if extra care is not taken to mitigate
them
o High the environment will be affected irrespectively in some cases such
impact can be reduced
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 6-2
Confidence This is the level knowledgeinformation the environmental impact
practitioner or a specialist had in hisher judgement and is rated as
o Low the judgement is based on intuition and not on knowledge or
information
o Medium common sense and general knowledge informs the decision
o High Scientific and or proven information has been used to give such a
judgment
Significance Based on the above criteria the significance of issues will be
determined This is the importance of the impact in terms of physical extent and
time scale and is rated as
o Low the impacts are less important
o Medium the impacts are important and require attention mitigation is
required to reduce the negative impacts
o High the impacts are of great importance Mitigation is therefore crucial
Cumulative Impacts The possible cumulative impacts will also be considered
Mitigation Mitigation for significant issues is incorporated into the EMP for
construction
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 7-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS
71 IMPACTS DURING CONSTRUCTION
711 Air quality
Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris
handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine
particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural
operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks
and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)
Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Fugitive particulate emissions (dust)
related to construction activities Regional
Short
term Medium High High Medium Regional
Short
term Low High High Low
Construction vehicle gas emissions Regional Short
term Medium High High Medium Regional
Short
term Low High High Low
712 Heritage and archaeological resources
Naturedescription of impact excavation activities may impact on unidentified heritage resources
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-2
Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based
on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments
Heritage and archaeological
resources Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on unidentified heritage
resources Local
Short
term
Medium -
high Low High Low
713 Biodiversity and conservation
Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation
importance and cause soil contamination
Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species
Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan
and has compiled a list of protected species to be rescued (see draft EMP)
Biodiversity and conservation Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Loss of fauna and flora Local Perma
nent
Medium -
high High High High Local
Permanen
t Medium High High Medium
Soil contamination Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-3
714 Water related impacts
Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater
runoff spills and leaks Soil erosion
Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of
spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste
disposal Stormwater quality monitoring (see draft EMP)
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Soil erosion Local Short
term Medium Medium High Medium Local
Short
term Medium Low High Low
715 Waste management
Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed
Commentmitigation see draft EMP and waste management plan
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-4
Waste management Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Local
Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
716 Health and safety
Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Short
term
Medium -
high
Medium -
high High High Local
Short
term
Medium -
high Low High Low
717 Traffic
Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and
construction workers from surrounding areas and transport of equipment from the port
Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low
Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and
accurate estimates of quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-5
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Increased traffic on N2 and within the
IDZ Regional
Short
term Low High High Low
718 Noise
Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Short
term
Medium-
high High High Medium Local
Short
term Medium High High Medium
719 Socio-economic
Naturedescription of impact temporary employment will be created during the construction phase
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-6
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Temporary employment Regional Short
term Medium High High Medium
72 IMPACTS DURING OPERATION
721 Air quality
NatureDescription of impact gas and particulate emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning
Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local
sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and
veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute
to background fine particulate concentrations (von Gruenewaldt 2011b)
Assumptions and limitations Potential release of CR6+
As no emission factors are available for trivalent chromium processing the
potential impacts due to these activities could not be quantified
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Dust emitted from traffic on paved roads Regional Long Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-7
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
term
Hydrogen chloride emissions from
pickling process Local
Long
term Low High High Low
Particulate emissions (smoke) from
galvanizing process (due to the
volatilization of flux)
Local Long
term Low High High Low
Particulate oxides of nitrogen carbon
monoxide and sulphur dioxide emissions
from LNG burner
Local Long
term Low High High Low
Nuisance related to odour Local Long
term Low Low High Low
Abnormally high hydrogen chloride and
particulate emissions due to scrubber
malfunction
Local Short
term Medium Low High Medium
Gases (eg SOx NOx CO etc) and
smoke emitted in case of a fire Local
Short
term High Low High Medium
722 Water quality
NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks
Commentmitigation see draft EMP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-8
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Stormwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
723 Waste management and hazardous substances
NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous
waste both can affect environmental quality and human health
Commentmitigation see draft EMP and waste management plan
Waste management and hazardous
substances Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Regional
Long
term High
Medium -
high High High Regional Long term High Low High Low
Soilwaterair pollution due to improper
transport storage and handling of
hazardous substances
Regional Long
term High
Medium -
high High High Regional Long term High Low High Low
Health hazard Local Long
term High
Medium -
high High High Local Long term High Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-9
724 Health and safety
Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Long
term
Medium-
high
Medium-
high High High Local Long term
Medium-
high Low High Low
725 Traffic
Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on
the road network
Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak
hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road
network within Zone 6 of the IDZ (Iliso 2011)
Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)
Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of
quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-10
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on traffic and capacity of the N2 Regional Long
term Low High High Low
Impact on traffic and capacity of ring
road 1 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR435 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR450 Local
Long
term Low High High Low
Impact on traffic and capacity of
Neptune road Local
Long
term Low High High Low
726 Noise
Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Long
term Medium High High Medium Local Long term Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-11
727 Socio-economic
Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate
revenue for the municipality and the region as a whole
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Employment and economic growth Regional Short
term Medium High High Medium
73 COMPARATIVE ASSESSMENT OF IMPACTS
During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as
low during operation after mitigation
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 8-1
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
As a tenant operating in the IDZ Casa Steel will be required to comply with all
current and future CDC requirements as well as with the relevant conditions of
permits licences issued to CDC (eg Integrated Stormwater Masterplan for the
eastern side of the Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)
In particular the CDC has its own requirements regarding the monitoring of certain
aspects of the project such as the quality of the effluent and the noise levels These
have been incorporated into the EMP
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 9-1
9 ENVIRONMENTAL IMPACT STATEMENT
All predicted negative impacts can be mitigated to a low significance The only
exceptions are biodiversity as the construction of the plant will result in the
destruction of habitat and loss of fauna and flora and noise impacts inherent to
construction activities Mitigation measures have been included in the EMP for these
impacts and they have a medium significance post-mitigation
Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium to
long term similar impacts are likely to occur due to ongoing developments in the IDZ
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 10-1
10 CONCLUSION AND RECOMMENDATIONS
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as
other infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified
and assessed No fatal flaws have been identified
It is recommended that the project be approved subject to the conditions listed in
chapter 9 and adherence to the EMP requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 11-1
11 REFERENCES
Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ
Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants
Bennie JS (2010) The historical component (built environment) of the Heritage
Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port
Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report
compiled for Eastern Cape Heritage Consultants
Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater
Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay
Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage
Consultants
BKS (2006) Coega Industrial Development Zone Transport Study Volume 3
Demand Modelling Report Final Draft
Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I
Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6
Report compiled for SRK Consulting
Coastal amp Environmental Services (2010) Environmental Impact Assessment for the
Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone
Volume 3 Environmental Impact Assessment Report CES Grahamstown
Coega Development Corporation (2008) Industry Waste Management Plan -
Strategic Master Plan Report
Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants
Report No CDCSHE 03 8122
Department of Water Affairs and Forestry (1998) Waste Management Series
ldquoMinimum Requirements For The Handling Classification And Disposal Of
Hazardous Wasterdquo Second Edition
Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising
Plant in the Coega Industrial Development Zone
Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the
Coega Industrial Development Zone (IDZ) Specialist Water Study
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 11-2
Jacobs E (2008) Final Environmental Impact Report and Draft Environmental
Management Plan Proposed Steel Recycling and Processing Facility within the
Coega IDZ Report compiled for SRK Consulting
Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY
Galvanising Plant in the Coega Industrial Development Zone Waste Management
and Hazardous Substances Report compiled for ILISO Consulting
RSA National air quality standard for thoracic particulates (PM10) SA standards
(Government Gazette No 32816)
von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed
Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape
Report compiled for ILISO Consulting
von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel
Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report
compiled for ILISO Consulting
Additional sources
Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed
Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared
for Coastal Environmental Services
Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed
Kalagadi Manganese smelter in the Coega Industrial Development Zone Port
Elizabeth Eastern Cape Province Report prepared for Coastal Environmental
Services
Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia
steel recycling facility at the Coega Industrial Development Area Port Elizabeth
Prepared for SRK Consulting Port Elizabeth
APPENDIX A
LIST OF INTERESTED AND
AFFECTED PARTIES
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
DEDEARegional Manager
and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza
DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza
DEA Ocean and
CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza
DEA Ocean and
Coast
Oceanographer land-
based sources of
marine pollution
Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza
DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza
CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza
CDCEnvironmental
Project
Manager
Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza
TNPAPort of Ngqura
Environmental
Manager
Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet
NMBMEnvironmental
ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza
NMBMEnvironmental
ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza
DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza
DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza
WESSASenior Conservation
Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza
Zwartkops
ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700
hughlauegmailcom
zwartkopstrustiafricacom
SANParksNational Marine
CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza
Department Of
LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza
NMBM Air Quality
Division
Assistant
DirectorAir
Pollution and Noise
Templeton Titima 079 490 0574 Ttitimamandelametrogovza
NMBM Air Quality
DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza
NUMSARegional
RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
Department of
HealthNadiema
van der
Bergh083 378 2103
nadiemavanderberghimpiloecprovgov
za
DWA Chief Services
Officer
Joseph Jacobs 041 586 4884 jjacobsdwafgovza
EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza
NUMSecretary of union
officesZandile Xhentsa 043 743 6597 zxhentsanumorgza
DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza
Dynamic
CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom
EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza
Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza
UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom
lprincezago2uticom
Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza
Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza
Absa Mr Johann Steyn 082 3775820 johannstabsacoza
Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza
PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza
Universal
EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza
Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza
GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom
Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza
NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom
DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza
DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza
TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet
DWA Mr Landile Jack JackLdwagovza
DWA Ms Lizna Fourie FourieL4dwagovza
APPENDIX B
NOTICE OF ATMOSPHERIC
EMISSIONS LICENCE APPLICATION
AND ADVERTISEMENT
APPENDIX C
NOTICE OF COMMENT PERIOD FOR
DRAFT SCOPING REPORT
APPENDIX D
SUMMARY OF ISSUES RAISED AND
RESPONSES THERETO
April 2012
1
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This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses
provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process
conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the
Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
2
IssueCommentQuestion Date
received Origin Response
1 Please provide more information with respect to the potential
dangers including the toxicity of the proposed project
07032011
By email
Wayne Poulton
(Bosun Brick
tenant at the
IDZ)
An Environmental Impact Assessment (EIA) was undertaken
which assessed the potential toxicity of the emissions and
effluent Mitigation measures were also recommended in the draft
Environmental Management Programme (EMP) to avoid
minimise or compensate any significant impacts The Draft
Environmental Impact Report and draft EMP were made available
to stakeholders for comment in March 2012
2 Do you have a Background Information Document (BID) or
similar that provides more information on the project
27032011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The BID was sent to all registered IampAPs on 4 May 2011
3 The RoD issued to the CDC on 632007 for the change in
land use for the remaining area of the Coega IDZ includes a
number of requirements with respect to
atmospheric emissions that should be considered in the
Atmospheric Emissions Licence (AEL) application such as
prohibiting and monitoring where possible visible emission
plumes to the atmosphere In particular the
recommendations on pp87-91 of the final revised Scoping
Report dated Nov 2006 must be implemented (clause 421)
04042011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
We have obtained copies of the documents referred to and ensure
that these requirements were taken into account in the
environmental assessment and AEL application
4 If the Port of Ngqura is used for import and export the scope
of the traffic impact assessment (TIA) should also include the
port
10052011
By email
Elliot
Motsoahole
(TNPA Port of
Ngqura)
The scope of the TIA was extended to include port related traffic
The TNPA at the Port of Ngqura was consulted and does not
have any objection to the project TNPA has indicated that the
development would require a minimum number of vessels per
year which would have minimal impact on the Port operations
However due notice would have to be given to the Port of Ngqura
before a vessel is scheduled to arrive so that the vessel can be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
3
IssueCommentQuestion Date
received Origin Response
accommodated at an available berth
5 Concerns with respect to potential stormwater pollution
draining into the Coega catchment and the port of Ngqura
The port needs to be dredged and heavy metals present a
risk in that regard
16052011
By
telephone
Andrew Lucas
(Department of
Water Affairs)
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination by effluent waste or
hazardousdangerous substances is very low
Thus no metals oils or other contaminants are expected to be
present in the stormwater
However stormwater pollution can occur in exceptional
circumstances such as accidents and emergencies The
emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
6 All steel sheets bathing unit must be under roof
7 The sludge out of the decreasing bath will be high in Na and
pH Therefore handling and disposal must be clarified up front
in this project
8 Per se the wastewater from decreasing bath will have high
ph and the component from the pickling unit will have low ph
Then it may be assumed that both streams will neutralize
each other Please then clarify proposed sewer discharge
with Nelson Mandela Bay Municipality up-front for acceptance
of influent as per the documented proposal
9 Pickling may result in dissolved metals How does your team
expect to deal with this As it is planned for discharge into
24052011
By email
Landile Jack
(Department of
Water Affairs)
All bathing units will be under roof
Effluent from the degreasing and pickling baths will be discharged
to the wastewater treatment plant The respectively alkaline and
acidic effluents will mix and neutralise each other in the
wastewater treatment plant Calcium or gypsum will be added if
required to complete the neutralisation process Effluent from the
treatment plant will be discharged to sewer Contact has been
made with the relevant officials and the Municipalityrsquos
requirements have been obtained The effluent discharged to
sewer will notably comply with the applicable discharge standards
Traces of metals (eg iron) may be present but will not exceed
prescribed thresholds The necessary authorisation will be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
4
IssueCommentQuestion Date
received Origin Response
sewer Clarity and acceptance needs to be agreed with
Nelson Mandela Bay Municipality Who owns the sewer
10 Quenching unit will results to Zinc particles How will this
affect sewer discharge This again must be dealt with within
the negotiations with the Municipality
11 Once all has been agreed with the Municipality and at the
same time due negotiations must be done with hazardous
waste courier and disposal facility to accept the hazardous
waste identified in all production lines
12 Of note is the low volume of the proposed WWTW facility ie
250 cubmweek And the no discharge of the quenching
water ie over-flow and cooling only Hence Zinc particles
generation
obtained from the municipality
The sludge from the treatment plant will be collected by a licensed
service provider and disposed of at a permitted site
The quenching bath will be periodically emptied (every 6 months)
and the water discharged will go to the water treatment plant Zinc
particles will settle in the sludge which will be disposed of at a
permitted site
Contact has been made with EnviroServ who manages the
Aloes II HH waste site regarding collection and disposal of
hazardous waste (See waste management report)
13 Investigate the potential effects of toxicity andor influence of
emissions waste and hazardous substances both in
terrestrial and marine fauna
14 With regards to water usage where is the plant going to
extract its waters used in galvanization andor waste
management process ie rainfall rivers or even from the
sea) and which avenues would be more environmental
friendly and effective
31052011
By email
A Bewana
(SANPARKS)
Emissions waste and hazardous substances are not expected to
affect terrestrial or marine ecosystems The air quality study
concluded that atmospheric emissions would not be harmful to
human health and by extension terrestrial fauna There are no
standards for air quality for defining faunal impacts therefore by
ensuring that standards for humans are complied with the impact
on fauna is deemed to be acceptable In this case the impact of
emissions on terrestrial and marine fauna are thus not significant
Solid and liquid wastes both general and hazardous as well as
hazardous substances will be stored handled and disposed of
appropriately to as not to cause harm to terrestrial or marine
fauna
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
5
IssueCommentQuestion Date
received Origin Response
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination and hence land-based
marine pollution by effluent waste or hazardousdangerous
substances is very low
The risk of emissions waste and hazardous substances to
terrestrial and marine fauna is thus very low
However pollution of terrestrial and marine ecosystems can occur
in exceptional circumstances such as accidents and emergencies
The emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
The CDC has an agreement with the NMBM to supply potable
water to the Coega IDZ Currently the infrastructure to supply
return effluent (RE) to the IDZ is not in place therefore Casa Steel
will be supplied with potable water up until such time as the
following 2 options of RE are available
1) Upgrading of the existing Fishwater Flats waste water
treatment works (between IDZ amp PE) including RE plant
and infrastructure to pipe RE to the IDZ (EIA for the
upgrade is underway)
2) Construction of a new waste water treatment works
including RE plant in Zone 9 of the Coega IDZ
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option should be investigated further between Agni and Casa The
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
6
IssueCommentQuestion Date
received Origin Response
CDC can facilitate discussions between the 2 investors
Compliance with CDC Permits amp Requirements
15 It should be made clear that tenants will be required to
comply with CDC requirements and the relevant conditions of
permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water
Licence for its Storm Water Systems on the
East Side of the Coega River that tenants will
need to take cognizance of The contents of the
ldquoIntegrated Stormwater Masterplan for the
eastern side of the Coega IDZ Oct 2010rdquo
especially the Table of best practice p53
onwards may need to be taken cognizance of
o CDC is developing an Operations
Environmental Management Plan that will place
certain obligations on tenants
16 Environmental audits and data collected during monitoring
(eg stack emissions stormwater) will need to be shared with
CDC
Air Emissions
17 Presumably permanent in stack monitoring will be required in
terms of AEL permit requirements
18 Abnormal operating conditions resulting in air emissions ndash I
could find nothing in the EIR to indicate under what
circumstances these could occur (eg start-up) potential
frequency and duration and the impact on ambient air quality
ndash these events usually result in the most problems wrt air
emissions
09042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
15 Compliance with the CDCrsquos Permits amp Requirements has
been included explicitly as a requirement in the EIR (p8-1) and
EMP (pp18 and 25) in the following terms
ldquoAs a tenant operating in the IDZ Casa Steel will be required to
comply with all current and future CDC requirements as well as
with the relevant conditions of permits licences issued to CDC
(eg Integrated Stormwater Masterplan for the eastern side of the
Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)rdquo
16 The need to communicate with the CDC on monitoring and
auditing activities was emphasised in Chapter 8 of the EMP The
following paragraphs were added
ldquoDuring construction the environmental officer will be responsible
for monitoring compliance with the EMP and authorisation
conditions and keeping records as required in the EMP andor
authorisation conditions
The ECO will conduct site inspections every two weeks audit the
records kept by the environmental officer and submit an
environmental compliance report every two months to the
authorities and the CDC (via the Environmental Monitoring
Committeersquos ECO)
During operation the health and safety officer will monitor
compliance with the EMP and the conditions of the Environmental
Authorisation Data collected during monitoring activities and any
environmental audits conducted will be shared with authorities
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
7
IssueCommentQuestion Date
received Origin Response
Water
19 Large volumes of (2000 m3mth) of water are required of
which only 400m3 needs to be potable The NMBM return
effluent system will provide non-potable water once it is
constructed What other water recycling initiatives can be
utilized to reduce potable water requirements (the ISWMP for
the eastern side of the Coega IDZ has some best practice
guidelines collecting rainwater from the roof etc)
General
20 There is no mention of how the CDC Architectural Guidelines
will be incorporated into the development (eg to prevent a
stark uniform warehouse type development)
21 Does NMBM have adequate fire services to cover this
development Apart from the large petroleum store are there
any other large fire hazards
22 Reports from the tenantrsquos ECO during construction and from
the SHE Officer during operations should be channeled to the
Coega Environmental Monitoring Committee This can be
directly or preferably via the EMCrsquos ECO (this will be while
the EMC and ECO are in place) A precedent has been set
for this in the Environmental Authorisations for Agni-Steel and
Kalagadi Manganese Smelter
23 All mitigation actions emanating from the EIR should be
summarized (preferably in a table) If compliance with them is
to be part of the Environmental Authorization from DEDEAT
then they (or the ones that DEDEAT deems to be applicable)
and the CDC (via the Environmental Monitoring Committeersquos
ECO)
The ECO (during construction) and the health and safety officer
(during operation) will report to the Coega Environmental
Monitoring Committee (EMC) via the EMCrsquos ECO (this will be
while the EMC and ECO are in place)rdquo
17 The draft EMP recommends regular monitoring of emissions
from the scrubbers and from the chromating process Additional
emissions monitoring requirements will be confirmed once the
AEL is issued Mention has been made in the EMP (pp11 and 19)
that all AEL conditions including monitoring and reporting
requirements should be adhered to
18 Abnormal emissions can occur in exceptional circumstances
Start-up will not cause abnormal emissions as the scrubbers
will be commissioned first and will be functioning once the plant
starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions
would be emitted as a building fugitive
The hourly hydrogen chloride ground level concentrations
(directly offsite) were predicted to be 239 microgmsup3 (based on the
emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits
as stipulated for listed activities for galvanising processes) using a
screen model which assumes worst case meteorological
conditions The health effect screening level for hourly HCl
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
8
IssueCommentQuestion Date
received Origin Response
should be attached to the EA as an Appendix (otherwise no
one knows about them or takes cognizance of them)
concentrations is 2100 microgmsup3 Assuming abnormal emissions
emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset
conditions will still be well within the health effect screening
levels
Similarly the hourly particulate emissions from the building
fugitives during upset conditions would amount to 293 microgmsup3
(based on the emission limits as stipulated for listed activities for
galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1
January 2015) directly off-site
Therefore if emissions are 5 times higher normal they will still be
within health effect screening levels and the daily PM10 NAAQS
levels
In the case of a fire a cocktail of gases and particulates could be
emitted and could be over the recommended levels This
situation will however be dealt with as an emergency and
normalised as quickly as is possible
The above has been added to the impact identificationdescription
and assessment sections of the EIR
19 The CDC has an agreement with the NMBM to supply
potable water to the Coega IDZ Currently the infrastructure to
supply return effluent to the IDZ is not in place therefore Casa
Steel will be supplied with potable water up until such time as the
infrastructure is in place
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
9
IssueCommentQuestion Date
received Origin Response
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option will be investigated further between Agni and Casa The
CDC has come forward to facilitate discussions between the two
investors
Other water recycling initiatives such as rainwater harvesting
have been considered but are not practical
20 The CDCrsquos Architectural and Landscape Design guidelines
contain requirements pertaining to such aspects as the height
orientation and mass and form of buildings as well as guidelines
for landscaping and signage in order to ensure an attractive
development and achieve an architectural integrity within the
Coega IDZ The plans for the proposed galvanizing plant will be
submitted to the Design Review Committee for approval as
required by the CDC
21 Casa Steel will be required to install fire hydrants according
to the NMBMrsquos standardsrequirements The CDC will provide
potable water (up until such time as return effluent is available)
and a connection to the boundary of the site which will be
connected to the fire hydrants The installation of the fire hydrants
will require approval by the Metrorsquos Fire Chief as was done for
Agni-Steel one of the investors in Zone 6
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
10
IssueCommentQuestion Date
received Origin Response
The Coega IDZ falls within the NMBM and therefore the rates and
taxes paid by the CDC covers the fire services for which the Metro
is responsible Currently the Metro has sufficient capacity to
provide fire services to the tenants within the IDZ This was
confirmed in discussion with the CDCrsquos Infrastructure
Development Unit It is however unknown at which point the
Metrorsquos Disaster Management Plan would not be able to
accommodate servicing tenants in the IDZ
The LNG burner is the only major fire hazard on the plant
22 See response to item 16 above
23 Key mitigation and management measures emanating from
the EIR were recapitulated in Chapter 9 of the EIR to form part of
the conditions attached to the Environmental Authorization from
DEDEAT All mitigation measures recommended as a result of the
impact assessment are presented in a table in the draft EMP
which is appended to the EIR (Appendix J)
24 Hydrogen chloride is one of the main emissions There are no
ambient air quality guidelines for HCl and the EIR says
concentrations will be well within health parameters
However the main problem with HCl is its corrosive effect -
there is absolutely no mention of this in the draft EIR nor air
specialist report
There needs to be some sort of comment assessment as to
whether HCl emissions are likely to impact on for example
the adjacent Agni-Steel Plant wrt corrosion - their factory
structure will be made of steel
11042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The atmospheric corrosion of metals is a complex process with
both the extent of deterioration and the mechanisms varying
considerably depending on the metal Depending on the way
pollutants are transported from the atmosphere to the corroding
surface two types of deposition processes are recognized in
atmospheric corrosion ndash dry deposition and wet deposition Wet
deposition refers to precipitation whereas dry deposition refers to
the remaining processes including gas phase deposition and
particle deposition The most important pollutants acting as
corrosive agents are sulphur and nitrogen compounds including
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
11
IssueCommentQuestion Date
received Origin Response
The EIR specialist rpt suggests monitoring HCl at ground
level on the property boundary and this is supported in case
there are complaints from neighbours
secondary pollutants and particulates Pollutants can contribute to
corrosivity individually however there may be a synergistic effect
when more than one of these pollutants is present in the
environment being affected In the field of atmospheric corrosion
sulphur dioxide is the single most investigated gaseous pollutant
and the quantification of the direct contribution of sulphur dioxide
to the corrosion process of metallic materials is comparatively well
understood (Tidblad amp Kucera 1998)
Very little work has reported on the effect of HCl on the
degradation of materials in the environment with no local dose-
response thresholds developed for corrosion occurring due to HCl
exposures This is probably because HCl which is present
outdoors in markedly reduced concentrations when compared
with SO2 has not been considered to contribute to significant
degradation of materials (Syed 2006) For this reason the
incremental corrosion due to HCl from the Coega Galvanising
Plant cannot be quantified
25 It is unacceptable for ILISO to be using CDC maps (see
figure 9 ndash pg5-6) without these maps being referenced
accordingly particularly when it appears that a CDC map has
been used and then overlaid with features by an unknown
author (ie CASA steel site Port (where the boundaries
depicted are incorrect) and a North legend which is out of
keeping with the overall cartographic intent of the original
work
26 Figure 10 is not referenced appropriately and I believe that I
commented previously in respect to references to roads not
12042012
By email
Graham Taylor
(Spatial
Development
Manager -
Infrastructure
Development
CDC)
This has been rectified in the final version of the report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
12
IssueCommentQuestion Date
received Origin Response
yet built As a result Figure 10 is confusing and clarity needs
to be provided in terms of referencing In addition the Port
shape is irregular and similar to the comment above
27 I acknowledge the emergency preparedness and response
plan but please confirm that this includes pro-active routine
monitoring of storm water leaving your premises to verify that
your assumptions of clean storm water are correct
13042012
By post
Andrew Lucas
(Director
WRampU
Department of
Water Affairs)
Pro-active routine monitoring of stormwater leaving the premises
will be undertaken This has been explicitly emphasised in
chapter 8 of the draft EMP
28 Will portablechemical toilets be used during construction
29 What provisions have been made for storm water drainage
during construction
18042012
By
telephone
Department of
Water Affairs
Port Elizabeth
Chemical toilets will be used during construction
The Casa Steel site will be located at the corner of two roads
drainage of stormwater from the site will take place through the
roadsrsquo drainage system
From Lea September [mailtoleailisocom]
Sent 11 March 2011 0935 AM
To Wayne Poulton
Cc Terry Baker
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Wayne
An Environmental Impact Assessment (EIA) will be undertaken for this project during the
next 10 to 12 months
We foresee that some of the key environmental impacts of the project will be in terms of air
quality water quality waste and hazardous substances
At this stage I am not able to give you any details regarding the potential toxicity of the
emissions andor effluent However specialist studies will be conducted as part of the EIA
that will determine the key impacts of the project Mitigation measures will also be identified
to avoid minimise or compensate any significant impacts
You are registered on the stakeholder database and you will be kept informed of progress in
the EIA process you will notably get the opportunity to access the reports produced and
provide any feedback on them
Please feel free to contact me should you need any further information
Best regards
Lea September
From Wayne Poulton [mailtowaynepbosuncoza]
Sent 07 March 2011 1257 PM
To Lea September
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
Please can you provide me with some more information as to the potential dangers including
the toxicity of this
Kind regards
Wayne
From Lea September [mailtoleailisocom]
Sent 04 March 2011 1123
To Lea September
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 March 2011 0745 AM
To Paul Martin
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 05 April 2011 0847 AM
To Paul Martin
Cc Terry Baker Renee von Gruenewaldt
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Thank you Paul for this information
I have downloaded a copy of the RoD and Scoping report you referred to and will make sure
these requirements are taken into account in the environmental assessment
Best regards
Lea September
From Paul Martin [mailtopmartinaxxesscoza]
Sent 04 April 2011 0955 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Further to my comments on 27311
Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in
the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega
IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised
scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions
including prohibiting and monitoring where possible visible emission plumes to the atmosphere
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Paul Martin
Sent Monday March 28 2011 745 AM
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 10 May 2011 0327 PM
To ElliotMotsoaholetransnetnet
Cc Terry Baker
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Mr Motsoahole
Thank you for your input on this issue
The Port of Ngqura will indeed be used for import and export At the moment the scope of
the traffic impact assessment only covers road traffic I have however relayed the matter to
our traffic specialist and we will consider this issue in the finalization of the Scoping Report I
will keep you informed of any developments in that regard
I trust this is acceptable to you
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]
Sent 10 May 2011 0855 AM
To Lea September
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
It has been noted that Casa Steel will source steel coils from various markets internationally and
in South Africa and the bulk of the plantrsquos production output will be exported to African countries
However there is no mention of logistic requirements
Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will
be used the scope of traffic impact assessment should also include the port
Regards
From Lea September [mailtoleailisocom]
Sent 04 May 2011 0747 AM
To Lea September
Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
Please find attached a letter announcing the EIA process underway for the proposed 80 000
tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as
a Background Information Document (BID) outlining the details of the project
Please contact me should you require any further information on this project
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
Elliot Motsoahole
Manager - Environment
Transnet National Ports Authority
Port of Nqqura
Port Control Building Klub Road Port Elizabeth 6212
PO Box 612054 Bluewater Bay 6212
+27 41 507 8450
+27 86 674 7729
Cell +27 83 542 5619
E-mail Elliotmotsoaholetransnetnet
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
DISCLAIMER The information contained in this communication is subject to copyright and
intended only for the use of leailisocom Unauthorised use disclosure or copying is
strictly prohibited Should a virus infection occur as a result of this communication the sender
will not be liable If you have received this communication in error please notify
elliotmotsoaholetransnetnet
From Lea September [mailtoleailisocom]
Sent 25 May 2011 1147 AM
To Jack Landile (ELS)
Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi
Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Landile
Thank you for your input
Contact has been made with the relevant Municipal Directorate and we will follow up with
them to obtain clarifications on all these issues
I have added both Lizna and yourself on the database and will keep you updated on
progress on this project
Best regards
Lea September
From Jack Landile (ELS) [mailtoJackLdwagovza]
Sent 24 May 2011 0524 PM
To Fourie Lizna (ELS)
Cc Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Hi Lizna
I missed you on this sorry
I linked Pieter twice Instead
Regards
Landile
From Jack Landile (ELS)
Sent 24 May 2011 0445 PM
To leailisocom
Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Lea
The e-mail you sent to Mr Kooverji dated 19 May 2011 refer
Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are
All steel sheets bathing unit must be under roof
The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project
Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal
Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer
Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality
Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines
Of note is the low volume of the proposed WWTW facility ie 250 cubmweek
And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles
generation
Regards
Landile
From Lea September [mailtoleailisocom]
Sent 19 May 2011 0947 AM
To Lea September
Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Stakeholder
Please find attached the remaining appendices to the draft Scoping report for the proposed
80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 June 2011 0411 PM
To Aphiwe Bewana
Subject RE Proposed 80 000 TPY Galvanizing plant in Coega
Dear Mr Bewana
Thank you for your input and apologies for the late reply
We have taken note of your comments and are will be taking them forward in the EIA phase
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Aphiwe Bewana [mailtoaphiwebewanagmailcom]
Sent 31 May 2011 1205 PM
To Lea September
Subject Re Proposed 80 000 TPY Galvanizing plant in Coega
Comment
Re Proposed 80 000 TPY Galvanizing plant in Coega
As SANParks we would like the EIA phase to investigate the potential effects of toxicity
andor influence of emissions waste and hazardous substances both in terrestrial and
marine fauna In the draft scoping report reference has been made with regards to the
terrestrial fauna but there is no attention to potential effects to marine fauna
Equally with regards to water usage where is the plant going to extract its waters used in
galvanization andor waste management process ie rainfall rivers or even from the sea)
and which avenues would be more environmental friendly and effective
Regards
Aphiwe Bewana
Marine Planner
South African National Parks
POBox 76693
NMMU
Port Elizabeth
6031
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 06 July 2011 1031 AM
To Lea September
Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Hi Lea
Irsquove reviewed the Final Scoping Report Herewith a few comments
1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the
Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a
revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the
NMBLP Please include only those in the IDZ as part of your IAP list
Regards
Andrea
From Lea September [mailtoleailisocom]
Sent Wednesday July 06 2011 859 AM
To Lea Septemberrsquo
Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Dear Stakeholder
The final scoping report for the above-mentioned project (attached) is available for comment
until 27 July 2011
The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic
commentaryrdquo tab
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 09 April 2012 1159 AM
To Lea September
Subject Comments on Galvanising Plant EIR Coega IDZ
Lea
Attached are my comments on the Draft EIR for the Coega IDZ galvanising
plant
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
Email attachment
COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ
Dr Paul Martin PO Box 61029
Bluewater Bay 6212 Tel 041 4665698
Email pmartinaxxesscoza
Compliance with CDC Permits amp Requirements
It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of
o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants
Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC
Air Emissions
Presumably permanent in stack monitoring will be required in terms of AEL permit requirements
Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions
Water
Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)
General
There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)
Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards
Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter
All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 11 April 2012 1245 PM
To Lea September
Subject Fw Comments on Galvanising Plant EIR Coega IDZ
Lea
One other comment on that I have on the Galvanising Plant Draft EIR
Hydrogen chloride is one of the main emissions There are no ambient air
quality guidelines for HCl and the EIR says concentrations will be well
within health parameters
However the main problem with HCl is its corrosive effect - there is
absolutely no mention of this in the draft EIR nor air specialist report
There needs to be some sort of comment assessment as to whether HCl
emissions are likely to impact on for example the adjacent Agni-Steel
Plant wrt corrosion - their factory structure will be made of steel
The EIR specialist rpt suggests monitoring HCl at ground level on the
property boundary and this is supported in case there are complaints from
neighbours
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Paul Martin ltpmartinaxxesscozagt
To Lea September ltleailisocomgt
Sent Monday April 09 2012 1158 AM
Subject Comments on Galvanising Plant EIR Coega IDZ
gt Lea
gt
gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising
gt plant
gt
gt
gt Dr Paul Martin
gt PO Box 61029
gt Bluewater Bay 6212
gt Tel 041 4665698
gt Cell 0732524111
gt email pmartinaxxesscoza
gt
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 12 April 2012 1139 AM
To Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Hi Lea
Hope yoursquore keeping well
I have requested comments from my colleagues and the CDC Casa team on the Draft EIR
Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report
Regards
Andrea
From Graham Taylor
Sent Thursday April 12 2012 838 AM
To Andrea Von Holdt Firhana Sam
Cc Johan Fourie Maria van Zyl Melikhaya Sihawu
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Andrea Firhana
Firhana if you could please ensure that the co-ordinates provided in the EIR correspond
with our records (pages 4-1 amp 4-2)
My comments are as follows
It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work
Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above
Regards
Graham Taylor
Spatial Development Manager - Infrastructure Development
Mobile 0832283055
Office 0414030454
Facsimile 0865185033
Email GrahamTaylorcoegacoza
Website wwwcoegacom
right PLACE | right TIME | right CHOICE
This email and all contents are subject to the following disclaimer
httpwwwcoegacomemaildisclaimerhtml
From Lea September [mailtoleailisocom]
Sent 04 May 2012 0411 PM
To Andrea Von Holdt
Cc Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Dear Andrea
We have taken note of the comments from the GIS Unit These issues have been rectified in
the final version of the EIR
Please can you forward to the relevant persons at the GIS Unit
Thank you
Best regards
Lea September
APPENDIX E
BACKGROUND INFORMATION
DOCUMENT
APPENDIX F
AIR QUALITY IMPACT ASSESSMENT
APPENDIX G
TRAFFIC IMPACT ASSESSMENT
APPENDIX H
WASTE MANAGEMENT AND HAZARDOUS
SUBSTANCES SPECIALIST STUDY
APPENDIX I
WATER QUALITY SPECIALIST STUDY
APPENDIX J
ENVIRONMENTAL MANAGEMENT
PROGRAMME
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 viii
It is recommended that the project be approved subject to the conditions listed above
and adherence to the EMP recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-1
1 INTRODUCTION
11 BACKGROUND
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)
Nelson Mandela Bay Municipality Eastern Cape Province
The demand for galvanised steel products is high in South Africa and Africa and is
expected to increase in the foreseeable future From an economic point of view the
proposed project has therefore been found to be viable
Casa Steel will source the steel coils from various markets internationally and in
South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is
destined to be exported mainly to African countries
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
An Environmental Impact Assessment (EIA) is required as the proposed project
involves several activities listed in terms of Section 24 of the National Environmental
Management Act (NEMA) No 107 of 1998 as amended and requires an
environmental authorisation
The following listed activities requiring environmental authorisation have been
identified
Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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
Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped
land to industrial use greater than 1 ha but less than 20 ha in size outside an
urban area
Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any
process or activity requiring a license in terms of national or provincial legislation
governing the generation or release of emissions
Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5
hectares or more of vegetation where 75 or more of the vegetative cover
constitutes indigenous vegetation except where such removal of vegetation is
required for
(i) purposes of agriculture or afforestation inside areas identified in
spatial instruments adopted by the competent authority for
agriculture or afforestation purposes
(ii) the undertaking of a process or activity included in the list of waste
management activities published in terms of section 19 of the
National Environmental Management Waste Act 2008 (Act No 59
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-2
of 2008) in which case the activity is regarded to be excluded from
this list
(iii) the undertaking of a linear activity falling below the thresholds in
Notice 544 of 2010
Hot dip galvanizing is a listed activity in terms of section 21 of the National
Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires
an Atmospheric Emissions Licence (AEL)
In addition the treatment of wastewater with an annual throughput capacity of more
than 2000 m3 is a listed activity in terms of the National Environmental Management
Waste Act 59 of 2008 and requires a waste management licence
ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental
Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact
Assessment process in terms of section 24 of NEMA for the construction and
operation of the proposed galvanizing plant The EIA process covers all aspects of
the project and informs all three applications (for environmental authorisation waste
management licence and AEL)
13 PURPOSE OF THIS REPORT
This report builds on the scoping report submitted to the Eastern Cape Department of
Economic Development and Environmental Affairs (DEDEA) and the Nelson
Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It
describes the proposed project and presents the findings of the second phase of
investigations (EIA phase)
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP)
The EIA was managed by Ms Terry Baker a certified Environmental Assessment
Practitioner with 20 years of working experience She has a MA in Environmental
Management and specialises in Environmental Impact Assessments and Project
Management She has been involved in a variety of different types of EIAs including
for water supply projects dams transmission lines roads and airports in South
Africa Botswana Uganda Lesotho and Mozambique She has been involved in
water resource management and public participation programmes on a number of
projects Terry has also been involved in the use of Geographic Information Systems
environmental status quo reports water quality assessments socio-economic and
institutional development projects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-3
15 PROJECT TEAM
In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen
(water quality specialist) and Lea September (EAP) with specialist input from Renee
von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous
substances) and Seniel Pillay (Traffic Impact Assessor)
The Business Unit Head of the ILISO Environmental Management Discipline Group
Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is
a Fellow of the South African Institution of Civil Engineers a member of the South
African Society of Aquatic Scientists of the Environmental Scientific Association of
the International Water Association of the Water Institute of South Africa and of the
Vaal River Catchment Association He is a certified Environmental Assessment
Practitioner with 30 years experience who specialises in project management
environmental impact assessments and water resource planning He specifically has
extensive experience in water quality especially water quality management water
quality monitoring and water quality assessment Martin has experience in managing
projects that involve multi-disciplinary teams and public consultation and
participation in South Africa and abroad
Lea September is an Environmental Assessment Practitioner with a Masters degree
in Environmental Management She has experience in impact assessment and
environmental management and has been responsible for drafting impact
assessment reports and Environmental Management Programmes and conducting
public participation processes as well as high level environmental screenings for a
variety of projects in the energy water transport and industrial sectors
Renee von Gruenewaldt has nine-years experience in the field of air pollution
impact assessment and air quality management Prior to becoming involved in air
quality consultation she was part of the Highveld Boundary Layer Wind Research
Group based at the University of Pretoria Since joining Environmental Management
Services (the company now Airshed Planning Professionals) she has undertaken
numerous air pollution impact studies and has provided extensive guidance to both
industry and government on air quality management practices
Pieter Smuts graduated as a Civil Engineer and became involved in the field of
municipal engineering and infrastructure construction He has specialized during the
last twelve years in solid waste management He has completed waste management
plans feasibility studies and final designs of waste management facilities in South
Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and
the review of the Mavoco hazardous waste landfill design in Maputo Mozambique
and completed a study on hazardous waste (textile factory sludge) management in
Maseru Lesotho
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-4
Seniel Pillay is a transportation engineer with over 16 years experience in
transportation planning and traffic engineering He has been involved in a wide
range of projects ranging from developing the Transport Operations Plan for the
FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System
for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller
traffic impact assessments for inter alia road improvement schemes Of particular
relevance to this project his experience includes Heavy Goods Vehicle Study for
eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact
Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash
Preliminary Transportation Assessment
16 STRUCTURE OF THIS REPORT
The proposed project and the alternatives considered are described in Chapter 2
Chapter 3 details the approach adopted for the EIA phase
The biophysical and socio-economic environment affected by the activity is described
in Chapter 4
The environmental impacts identified are discussed in Chapter 5
The EIA methodology is described in Chapter 6 and Chapter 7 presents the results
of the impact assessment
The environmental impact statement is presented in Chapter 8
Finally Chapter 9 spell out the conclusions and recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-1
2 DESCRIPTION OF THE PROPOSED PROJECT
21 TECHNICAL ASPECTS
211 The galvanizing process
Galvanizing consists of coating steel with zinc in order to protect it from corrosion
Before steel strips can be galvanized they undergo a pre-treatment in order to
ensure that the steel sheets are free from any surface oxides as they enter the
molten zinc coating Bath This is done by removing the oil from the steel sheets (in
the degreasing unit) and then removing the rust from the surface of the sheet (in the
pickling unit)
The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The
melting zinc on the strip surface will be cooled and solidified through air cooling in the
cooling tower
Finally the galvanised steel sheets are dipped into a water quenching tank in order to
further cool the sheets from about 150degC to 40degC
It is possible to make galvanised steel more durable by chromating it Approximately
50 of the galvanised steel production output will receive chromate passivation
treatment after quenching the galvanised steel sheets will be sprayed with a chrome
solution (3 kgcm2)
After galvanizing and chromating the steel sheets are cut to achieve the desired coil
size and weight and transported to the storage yard
The process flow diagram below (Figure 1) illustrates the main stages of the
galvanizing process and indicates the major inputs and outputs as well as the
resulting effluent and atmospheric emissions
Draft Environmenal Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-2
Figure 1 Process flow diagram for proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-3
212 Main inputs and outputs in operational phase
In view of the above the main inputs will be as follows
Steel coils 85 000 tonsyear
Zinc 870 tonsyear
Electricity 2500 kVA
Water 2000 m3month (of which 400 m3 will be potable water)
Liquid Natural Gas (LNG) 270 NM3hour
Sodium hydroxide (NaOH) 1000 m3year
Hydrochloric acid (HCl) 800 m3year
Chrome (Cr+3) 10 m3year
The main outputs will be
Galvanized steel 80 000 tonsyear
Scrap metal 20 tonsyear
General waste 65 tonsyear
Hazardous waste 2 m3month
Wastewater 012 Mlweek
Atmospheric emissions lt 5 ppm
213 Installations on site
The bulk of the operations involved in the galvanizing process occur along a
continuous galvanizing line (See Figure 2 below) which is the main piece of
machinery required for the proposed galvanising plant
Figure 2 Continuous Galvanizing Line
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-4
Water is one of the major inputs and is used throughout the galvanizing process notably
for rinsing and cooling purposes and as a mixing agent for the various chemical
solutions The plant will have a water treatment plant on site to treat the water used in
the various processes (approx 250 m3
of wastewater per week) The wastewater
treatment facility will be operated by a professional water treatment company as Casa
Steel does not have the required expertise in house to treat its process water Sulphuric
acid (H2SO4) is used as part of the treatment process to reduce caustic soda The
neutralised water is discharged to the sewer while any sludge is disposed of as
hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)
will be disposed of
Some critical areas of the galvanizing process such as the zinc pot require uninterrupted
power It is therefore proposed to install an LNG burner to maintain the zinc bath at a
temperature of between 450 and 460degC
22 LOCATION OF THE PROPOSED GALVANIZING PLANT
The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast
of Port Elizabeth in the Eastern Cape (Figure 3)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-5
Figure 3 Location of the proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-6
23 NEED AND DESIRABILITY
The profitability of the proposed project has been established by Casa Steel and a
pre-feasibility study has confirmed that the proposed project was feasible from a
technical and financial point of view The Coega IDZ is specifically designed to host
facilities such as a galvanizing plant and can provide the necessary infrastructure
and services to its investors It therefore constitutes a very suitable location for the
project
24 ALTERNATIVES IDENTIFIED
Zone 6 has been specifically earmarked for heavy ferrous metal industries and is
therefore a suitable location for the proposed galvanizing plant as such no site
alternatives have been provided for and assessed in this EIA However prior to the
commencement of the EIA process Casa Steel was presented with a number of
different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the
selection of the site were
(a) The dimensions of the land the site should be at least 200 m long and
50 m wide in order to accommodate the galvanizing line and adjacent lay
down area and additional land should be available next to the site for future
expansion
(b) The fiscal arrangements applying to the site the site should be located
within the future Custom Controlled Area (CCA) as the bulk of the
production output of the plant will be exported
The no-go alternative is assessed in this report
25 CONSTRUCTION ASPECTS
The construction phase of the project will take about 12 months and will essentially
consist of erecting a building to house the galvanizing line and other equipment and
preparing a concrete laydown area adjacent to the building
The CDC will provide an access point from the existing tarred road that will lead to
the site
Approximately 100 workers from the surrounding areas will be contracted for the
construction work
The requirements in terms of services during construction are listed below
Water 1000 m3month
Electricity 2500 kVA
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-7
The CDC will provide temporary services for the construction phase including a
conservancy tank for flush toilets Sewage infrastructure will only be provided for the
operational phase
26 OPERATION ASPECTS
Before the plant can become fully operational the equipment and machinery will be
tested for approximately 3 months The supplier will supervise these tests as part of
the transfer of know-how and training of staff on the plant
Casa Steel will start operating the plant at a reduced capacity (about 50 000
tonsyear) for a period of time (mostly determined by market aspects) before bringing
production to full capacity (80 000 tonsyear) This is done by operating the line for
longer hours
Approximately 50 to 60 people will be working on the plant Approximately 6-10 of
these will be unskilled 40-45 skilled and about 5 people in managerial positions
The requirements in terms of services during operation are as follows
Water 2000 m3month
Electricity 2500 kVA
Effluent discharge 24 m3day
The CDC has entered into agreements with the municipality to secure the provision
of services such as water and electricity to its tenants Tenants in the IDZ have their
own agreements with the NMBM for electricity while the agreements for water and
sewage are with the Facilities Unit of the CDC
Regarding discharge of wastewater to the sewer the municipality indicated that the
only requirement is that the water discharged complies with applicable municipal
discharge standards
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 3-1
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT
31 OBJECTIVES
The main objectives of the EIA phase are to
Assess the significance of the environmental issues and impacts identified in the
scoping phase focusing on key impacts
Recommend appropriate measures to mitigate negative impacts and enhance the
benefits and include them in the draft EMP
Undertake a public participation process that provides opportunities for all
interested and affected parties (IampAPs) to be involved
32 AUTHORITY CONSULTATION
The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental
Liaison Committeersquo (ELC) which comprises representatives of various authorities
including DEDEAT the Department of Environmental Affairs (DEA) and Department
of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the
Coega Development Corporation (CDC) and Transnet National Ports Authority
(TNPA) The ELC has been specifically formed to facilitate EIA applications in the
IDZ
Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to
the clearance of vegetation should be included in the application A formal request
was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the
application and all registered stakeholders were informed of the request in writing on
19 October 2011
33 PUBLIC PARTICIPATION PROCESS CONDUCTED
On-site notices were replaced by a notification displayed on the CDCrsquos digital notice
board at the business centre in Zone 1 of the IDZ The eNotice was placed on
13 April 2011 and will remain for the full duration of the EIA process
Registered stakeholders will be notified in writing of the availability of the draft EIA
report and EMP which will also be advertised in a local newspaper Stakeholders
including state departments and the public will have forty (40) days to comment on
the draft EIA report and EMP The draft EIA report and EMP will be sent by email
where possible and made available for download on the ILISO website
(wwwilisocom)
A summary of all issues and comments received during the stakeholder consultation
process as well as of correspondence in that regard will be captured in an Issues
and Responses Report that will form an Appendix to the EIA Report
The list of registered IampAPs is included in Appendix A
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 3-2
34 LEGISLATION AND GUIDELINES CONSIDERED
The following legislation and guidelines were considered in the preparation of this
report
National Environmental Management Act Act No 107 of 1998
NEMA EIA Regulations 2010
National Environmental Management Air Quality Act Act No 39 of 2004
National Environmental Management Waste Act Act No 59 of 2008
Hazardous Substances Act Act 15 of 1993
Occupational Health and Safety Act Act 85 of 1993
Hazardous Chemical Substances Regulations 1995 (GNR 1179)
Major Hazard Installation Regulations 2001 (GNR 692)
National Water Act Act 36 of 1998
National Heritage Resources Act Act 25 of 1999
DEAT Integrated Environmental Management Information Series 1-5 and 12-15
NEMA draft Implementation Guideline
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Public Participation (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Alternatives (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Draft Guideline for Determining the Scope of Specialist
Involvement in EIA Processes (2005)
IAIA guidelines
National air quality standard for thoracic particulates Government Gazette
No 32816
Listed activities and associated minimum standards identified in terms of section
21 of the National Environmental Management Air Quality Act Act No 39 of
2004 Government Notice 248 of 2009
Minimum Requirements for the Handling Classification and Disposal of
Hazardous Waste DWAF Waste Management Series (1998)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-1
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION
The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega
IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay
to the north of the N2 highway between Port Elizabeth and Grahamstown east of the
Coega River
The co-ordinates of the corners of the site are shown in Table 1
Table 1 Coordinates of site corners for the proposed galvanizing plant
Point Longitude Latitude
A 25deg411126E 33deg45587S
B 25deg411156E 33deg45499S
C 25deg411938E 33deg45131S
D 25deg412174E 33deg45481S
E 25deg412508E 33deg45979S
F 25deg412634E 33deg451160S
G 25deg411782E 33deg451560S
H 25deg411692E 33deg451428S
J 25deg411314E 33deg45868S
Figure 4 Zone layout in the Coega IDZ
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-2
Figure 5 Site location
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-3
42 SOCIO-ECONOMIC CHARACTERISTICS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the
NMBM There are no residents within the IDZ
As far as the broader NMBM and Eastern Cape Province are concerned the
following can be noted The NMBM is located within the Eastern Cape Province the
2nd largest Province in South Africa (3rd in terms of population) characterised by a
predominantly black population with low incomes and high levels of unemployment
(CES 2010)
The NMBM has a population of just above 11 million and covers an area of
1 950 km2 It is the main urban and industrial centre of the province and Port
Elizabeth in particular which forms part of the NMBM is the commercial capital of
the Eastern Cape 52 of the NMBM population is female and 37 is below the
age of 20 these two groups are particularly affected by unemployment
43 BIOPHYSICAL CHARACTERISTICS
431 Surface and ground water
No rivers occur in Zone 6 There is however a natural attenuation pond on the
southern most part of the site which will have to be avoided
The IDZ is underlain by calcrete sand and gravel deposits that overlie low
permeability clays These clays limit the vertical infiltration of rainwater and induce a
horizontal groundwater flow towards the Coega River channel which is the most
significant surface water feature in the Coega IDZ Consequently rapid run-off takes
place following precipitation (Jacobs 2008)
Groundwater levels at Coega are generally about 3 to 5 m below surface ie just
above the contact between the permeable sands and the underlying impermeable
clays The groundwater flow direction is to the southeast following the surface water
drainage direction (Jacobs 2008)
432 Climate and atmospheric conditions
Port Elizabeth has a warm temperate climate and the temperature ranges are not
extreme Exceptionally high temperatures may be experienced during berg wind
conditions which occur frequently during autumn and winter Extreme temperatures
also occur during summer with little accompanying wind
The wind regime for the area largely reflects the synoptic scale circulation with
dominant westerly and northwesterly flow fields representing the pre-frontal
conditions and south-westerly flow fields representing the frontal conditions The
south-easterly and south-westerly wind flow (land breeze) increases during daytime
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-4
conditions with westerly and north-westerly wind flow increasing during the night (sea
breeze)
The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of
Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15
km southwest) and Port Elizabeth (~23 km southwest)
An ambient air monitoring network has been established in the Coega IDZ which
consists of three monitors Saltworks Motherwell and Amsterdamplein Although
NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative
impacts due to the proposed Galvanising Plant is PM10 A maximum daily average
PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed
SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3
was exceeded on 17 days in 2007 and 26 days in 2008
Existing sources of emissions in the vicinity of the proposed galvanizing plant include
industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other
fugitive dust sources (von Gruenewaldt 2011b)
433 Geology and soils
Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel
and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly
limestone and conglomerate
434 Terrestrial ecology
This section draws from the EIA report compiled for the Agni Steel (formerly Afro-
Asia) steel processing facility which is adjacent to the proposed site for the
galvanizing plant (Jacobs 2008)
The area consists largely of grasses succulents and scrubby bush with alien
species making up the greater part of the more dense vegetation
Zone 6 falls within the inland vegetation and is characterised by a vegetation type
referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the
Coega IDZ and has been found to have three times the level of endemism of other
vegetation communities in the Coega IDZ Bontveld therefore has a high
conservation status Two Bontveld conservation areas have been identified within the
IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)
Bontveld that will be destroyed as a result of development in the IDZ will be given
conservation status in these two areas
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-5
Figure 6 Coega IDZ Open Space Management Plan (OSMP)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-6
Certain areas in the IDZ are invaded by alien plant species The most common
invader species is rooikrans (Acacia cyclops) which presently forms large
monospecific stands in areas throughout the Coega IDZ There are several other
aliens present that pose a threat to the flora of this area including the prickly pear
(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)
Loss of vegetation and alien plant invasion due to human activity has resulted in a
reduction in the diversity of terrestrial fauna
The majority of mammals present in the Coega IDZ are small or medium-sized Of
the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed
gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of
Algoa Bay however it is not considered threatened The gerbil is common in
foredune and dune thicket habitat in the Coega region and is therefore unlikely to
occur on the proposed site
A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird
species are resident or common to the area Most diversity occurs in the thicket
although the coastal area also supports specialised avifauna Two species of tern
the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well
as the Cape gannet (Morus capensis) and the African penguin (Spheniscus
demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne
caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant
(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser
flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns
are two of the most endangered coastal species in South Africa Other bird species
of conservation concern include the Whitefronted plover (Charadrius marginatus)
African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus
bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus
ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides
paradisea) Breeding pairs of Damara terns and African black oyster catchers have
been observed in the coastal dunes of the IDZ but should not be affected by
developments that fall outside the dune areas
The Eastern Cape supports nearly a third (approximately 133 species) of the reptile
species recorded in South Africa More than half of the Eastern Capersquos endemic
reptile species occur in the Algoa Bay area giving the region a high conservation
value A total of 63 reptile species are believed to occur within the Coega IDZ The
majority of these are found in Succulent Thicket and riverine habitats Only a few
reptile species occur in the coastal dunes and estuarine habitats More than a third of
the species are described as relatively tolerant of disturbed environments provided
that migration corridors of suitable habitat are maintained to link pristine habitats
Twenty two reptiles are of special concern including five endemic species (two of
which may also be endangered) four endangered sea turtles eight species listed
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-7
with CITES one rare species and four species at the periphery of their range
Fourteen of these species of special concern are confirmed as occurring on or within
2 km of the Coega IDZ
A total of 32 amphibian species and sub-species occur in the Eastern Cape
representing almost a third of the species recorded in South Africa However none of
the species are endemic or Red Data Book species Based on previous studies in the
area it is estimated that approximately 17 amphibian species occur within the Coega
IDZ Four species are listed as peripheral but none are threatened internationally
These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog
(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and
the bubbling kassina (Kassina senegalensis)
The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated
vegetation has not been extensively studied One grasshopper species Acrotylos
hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue
(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis
pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in
four localities in the Eastern Cape one of which is within the Coega IDZ The Coega
copper Aloeides clarki is endemic to this particular region of the Eastern Cape and
is currently known to occur in three localities two of which are in the Coega IDZ The
localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the
Coega IDZ and their distributions were taken into account when defining Coegarsquos
open space system and Development Framework Plan
435 Land use and topography
The land is currently undeveloped and earmarked for industrial development The
site is relatively flat ranging from an elevation of 66 masl on the northern-most
corner to 59 masl at the southern-most corner
436 Heritage and archaeological survey
Extensive studies have been undertaken in Zone 6 with respect to heritage aspects
Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a
2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond
2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is
currently being finalised
Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing
Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha
in extent and was located next to the R102 road to Motherwell Kaplan conducted
HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi
Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will
now be located in Zone 5)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-8
The various archaeological investigations reached similar observations and
conclusions Stone tools of various densities and types were found throughout the
zone The majority of the stone tools were mainly of Earlier and Middle Stone Age
and occasional Later Stone Age origins (Figure 4)
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble
gravels exposed by tracks in Zone 6 (Source Binneman 2010)
The stone tools which comprised of quartzite flakes chunks flaked pebblecobble
and cores were randomly distributed across the landscape and are in secondary
context There were no lsquoconcentrationsrsquo of tools observed which suggested any
spatial patterning or activity areas although these may be present or covered by soil
and vegetation
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 5-1
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED
The following environmental issues and potential impacts were identified in the
Scoping phase
51 AIR QUALITY
The galvanizing process generates atmospheric emissions with particulates and
hydrogen chloride representing the main pollutants of concern The plant is fitted with
air extraction as well as scrubber systems which are designed to retain the bulk of
pollutants and particles for each of the processes in such a way that less than 5 ppm
of gases and particles will be released into the atmosphere after the fume scrubber
Other sources of impact on air quality include emissions from the LNG burner as well
as emissions and dust from the transport of steel and other materials in trucks
Construction activities will also create dust and gas emissions due to the clearing of
groundcover tipping of material to storage pile levelling of area wind erosion from
storage piles vehicle and construction equipment activity and tailpipe emissions
from vehicles and construction equipment such as graders scrapers and dozers
Overall the air quality impact assessment (Gruenewaldt 2011b) found that
The predicted particulate oxides of nitrogen carbon monoxide and sulphur
dioxide concentrations are all below the National Ambient Air Quality Standards
for all averaging periods
The predicted off-site concentrations of hydrogen chloride are well below the
most stringent effect screening levels
No odour threshold exceedances for hydrogen chloride were predicted to occur
due to routine operations at the Steel Galvanising Plant The South Wales
Environmental Protection Authority stipulates that an odour unit of 20 is
acceptable for urban areas The odour unit would be lt10 directly off-site for
hydrogen chloride
Abnormal emissions can occur in exceptional circumstances Start-up will not
cause abnormal emissions as the scrubbers will be commissioned first and will be
functioning once the plant starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions would be emitted as a
building fugitive
The hourly hydrogen chloride ground level concentrations (directly offsite) were
predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based
on the emission limits as stipulated for listed activities for galvanising processes)
using a screen model which assumes worst case meteorological conditions The
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-2
health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming
abnormal emissions emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset conditions will still
be well within the health effect screening levels
Similarly the hourly particulate emissions from the building fugitives during upset
conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for
listed activities for galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly
off-site
Therefore if emissions are 5 times higher normal they will still be within health effect
screening levels and the daily PM10 NAAQS levels
In the case of a fire a cocktail of gases and particulates could be emitted and could
be over the recommended levels This situation will however be dealt with as an
emergency and normalised as quickly as is possible
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS
The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of
its heritage potential and there are no proposed protected geosites in Zone 6
Should any artefacts be discovered during construction procedures stipulated in the
draft EMP will apply
53 BIODIVERSITY AND CONSERVATION
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
In terms of terrestrial fauna the CDCrsquos open space management plan provides for
the preservation of certain corridors The destruction of certain habitats as a result of
the development will therefore not automatically result in the loss of certain species
54 WATER QUALITY
There is a natural attenuation pond on the southern most part of the site which will be
avoided
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through
spills or leaks
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-3
This risk can however be minimized if not avoided altogether The floor of the factory
will be designed as a bunded area to contain any spills and the entire process will be
contained Potential spills or leaks will therefore be contained and will not impact on
water resources Storm water is therefore considered clean water under normal
operational conditions An oil trap will be placed at the exit of the site to ensure that
no grease from the laydown area enters the stormwater system
Spills and leaks can occur during the handling or the transport of hazardous
substances Best practice guidelines will be followed to ensure that this risk is
adequately managed
Wastewater discharged to sewer will be treated to comply with municipal discharge
standards and is not expected to have an impact on the chemical characteristics of
the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be
discharged from the plant is small in relation to the total volume received at the
Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works
(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently
operated at 61 of its capacity which is approximately 80 Mℓday Thus the
0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore
not have any significant impact on the WWTW
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES
The plant will generate a relatively small amount of solid waste in the form of scrap
metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)
The scrap metal may be sold to other steel processing facilities such as Agni Steel
which will be located next to the plant or collected and disposed of with the rest of
the solid waste by a licensed service provider
As mentioned previously there will be a wastewater treatment plant on site which will
neutralise process water (012 Mlweek) in order to ensure it is of a standard
acceptable for discharge to sewer Waste in the form of sludge from the
neutralization or spent acid must be disposed of as a hazardous waste Solid waste
from the filters used for air quality control is also in this category These wastes can
usually be tested and then delisted which means that it can be placed in a general
purpose landfill
Hazardous effluent from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-
site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored
and removed on a monthly basis is limited to 10 m3
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-4
A number of substances classified as hazardous are used in the galvanizing process
(Table 2) and the transport and handling of these is subject to certain rules and
guidelines In particular the material safety data sheets (cf Appendix H) should be
referred to for inter alia hazards identification accidental release measures
handling and storage precautions exposure controlpersonal protection ecological
information and transport information The Hazardous Chemical Substances
Regulations 1995 should also be adhered to in respect of the transport and storage
of hazardous chemical substances
Table 2 Hazardous materials to be used on site
Major Input Materials
Substance
listed in the
SABS 0228
Group II
hazardous
substances
Volumes to be
stored on site at
any one time
Diesel radic 2000 litres
Liquid petroleum radic 20 000 liters
Sodium hydroxide (NaOH)
(used for degreasing) 8 radic 1000m
3
Hydrochloric acid (HCI)
(used for pickling) 8 radic 800m
3
Zinc (used for galvanising) - TBD
Trivalent chromium (CR+3
)
(used for chromating) 8 radic 10m
3
Sulphuric acid (H2SO4) (used for
treatment of waste water on site) 8 radic TBD
Ammonium Hydroxide (NH4OH) 8 radic TBD
TBD ndash To be determined
Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one
time) and is classified as a flammable substance Specification for flammable storage
facilities in accordance with the requirements of the Nelson Mandela Bay
Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for
quantities between 5000 and 20 000 liters the substance must be kept in a
flammable liquid store which complies with the requirements of a specification
obtainable from the Department Some of the requirements are
Flammable liquid and solid storage facilities are only permitted on the ground
floor
Decanting of flammable liquids and solids are not permitted within any building
Due to the fact that there are flammable materials on site a certificate may be
required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and
Emergency Services Department to confirm that facilities for flammable storage
are in accordance with their requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-5
Because of the permanent installation and high quantity of liquid petroleum on site
the Major Hazard Installation Regulations 2001 promulgated under the Occupational
Health and Safety Act No 85 of 1993 applies A written application for approval of
the installation is required to be submitted to the chief inspector Department of
Labour provincial director Department of Labour and NMBM prior to construction
In addition a risk assessment should be formulated covering all hazardous materials
together with an emergency preparedness and response plan
56 HEALTH AND SAFETY
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling instructions as well as occupational exposure limits
are indicated in the material safety data sheets of the various substances used
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as
provide site supervision including executing tests (individual test cold run and hot
run) during 3 months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the
EMP
In addition the emergency preparedness and response plan will cover the health and
safety aspects related to emergency situations
57 TRAFFIC
The volumes of traffic at the IDZ are currently relatively low and variable depending
on the different zones in the IDZ however these volumes will increase as more
developments are implemented
The construction phase of the Casa Steel development will take about 12 months
and will essentially consist of erecting a building to house the galvanizing line and
other equipment and preparing a concrete laydown area adjacent to the building
The traffic that would be generated during the construction phase can be expected to
be less than the traffic that would be generated by the Casa Steel development when
it is fully operational
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-6
In the operation phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and
from the Port of Ngqura
The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the
Casa Steel development would be off Ring Road 1 The other roads of significance
for the Casa Steel development are the N2 Neptune Road MR435 and MR450
Access to the port is given by Neptune Road Road Link NEP-03 has not yet been
built
Figure 8 Coega IDZ road network identification
(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-7
Figure 9 Coega IDZ road network
Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No
01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-8
The distribution of freight trips is fixed as the majority of trips will be made between
the Port of Ngqura and the Casa Steel site With regard to personnel trips there are
various points of origins (the surrounding residential areas) that could be used by
staff going to the Casa Steel site The distribution of personnel trips is based on
existing traffic count information and is shown in Figure 10
Figure 10 Trip distribution for freight and personnel trips
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The resultant expected Casa Steel traffic assignment is shown in Figure 11
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-9
Figure 11 Morning peak hour Casa Steel development traffic
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The traffic that is expected to be generated by the Casa Steel development is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low
and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)
Consultation has taken place with Transnet Port Authority (TPA) to establish the
impact of the galvanizing plant operations on traffic inside the port The additional
ships entering and exiting the port of Ngqura as a result of the proposed development
will have a negligible impact on port traffic and TPA indicated that it would be well
within the portrsquos capacity
58 NOISE
Noise is not foreseen to be a significant issue insofar as the noise levels inside the
plant and at the boundary of the site will not exceed the limits prescribed by the CDC
Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels
during the day and 60 decibels at night
Mitigation of noise impacts will be addressed in the design of the noise-emitting
components of the plant and their enclosures
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-10
59 SOCIO-ECONOMIC ASPECTS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of
NMBM There are no residents within the IDZ
The direct socio-economic impacts of the proposed project are thus limited to the
employment generated by the project during construction and operation Job creation
remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)
and the IDZ and Port of Ngqura are expected to become a significant catalyst to the
economic growth of the Municipality and the region with current investments at
Coega creating more jobs and stimulating the economy
In this context the proposed galvanizing plant will make a positive contribution
towards the achievement of these goals
There will be 50 to 60 employees during operation phase distributed as follows
Figure 12 Casa Steel organisation chart
Even though a large part of the inputs will be imported and the bulk of the production
output will be exported there will be some positive impacts for the economy of the
region and of South Africa in general Notably the requirements of the plant for
water electricity waste collection and disposal waste water treatment and transport
for example will create business for the various service providers and have an
indirect impact on employment and fiscal revenues as a result
From a visual impact point of view it can be anticipated that the landscape in the IDZ
will be significantly affected over time by developments related to the establishment
of the port and various industries
HEAD ( WORKS )
MGR ( COMM) MGR ( ADMNHR ) Manager marketing
MANAGER OPERATION MANAGER MANAGER MANAGER Q C
AC FIN PUR ampSTORE
PPC SH-GALV SH-tech
SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF
1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO
JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF
2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO
WORKERS WORKERS 7NOS
15 7
RAW MAT amp
DESP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 6-1
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
A description of the nature of the impact any specific legal requirements and the
stage (constructiondecommissioning or operation) will be given Impacts are
considered to be the same during construction and decommissioning The
significance of the potential impacts will be considered before and after identified
mitigation is implemented
The following criteria will be used to evaluate significance
Nature The nature of the impact will be classified as positive or negative and
direct or indirect
Extent and location Magnitude of the impact and is classified as
Local the impacted area is only at the site ndash the actual extent of the activity
Regional the impacted area extends to the surrounding immediate and
neighbouring properties
National the impact can be considered to be of national importance
Duration This measures the lifetime of the impact and is classified as
o Short term the impact will be for 0 ndash 3 years or only last for the period of
construction
o Medium term three to ten years
o Long term longer than 10 years or the impact will continue for the entire
operational lifetime of the project
o Permanent this applies to the impact that will remain after the operational
lifetime of the project
Intensity This is the degree to which the project affects or changes the
environment and is classified as
o Low the change is slight and often not noticeable and the natural functioning
of the environment is not affected
o Medium The environment is remarkably altered but still functions in a
modified way
o High Functioning of the affected environment is disturbed and can cease
Probability This is the likelihood or the chances that the impact will occur and
is classified as
o Low during the normal operation of the project no impacts are expected
o Medium the impact is likely to occur if extra care is not taken to mitigate
them
o High the environment will be affected irrespectively in some cases such
impact can be reduced
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 6-2
Confidence This is the level knowledgeinformation the environmental impact
practitioner or a specialist had in hisher judgement and is rated as
o Low the judgement is based on intuition and not on knowledge or
information
o Medium common sense and general knowledge informs the decision
o High Scientific and or proven information has been used to give such a
judgment
Significance Based on the above criteria the significance of issues will be
determined This is the importance of the impact in terms of physical extent and
time scale and is rated as
o Low the impacts are less important
o Medium the impacts are important and require attention mitigation is
required to reduce the negative impacts
o High the impacts are of great importance Mitigation is therefore crucial
Cumulative Impacts The possible cumulative impacts will also be considered
Mitigation Mitigation for significant issues is incorporated into the EMP for
construction
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 7-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS
71 IMPACTS DURING CONSTRUCTION
711 Air quality
Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris
handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine
particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural
operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks
and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)
Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Fugitive particulate emissions (dust)
related to construction activities Regional
Short
term Medium High High Medium Regional
Short
term Low High High Low
Construction vehicle gas emissions Regional Short
term Medium High High Medium Regional
Short
term Low High High Low
712 Heritage and archaeological resources
Naturedescription of impact excavation activities may impact on unidentified heritage resources
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-2
Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based
on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments
Heritage and archaeological
resources Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on unidentified heritage
resources Local
Short
term
Medium -
high Low High Low
713 Biodiversity and conservation
Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation
importance and cause soil contamination
Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species
Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan
and has compiled a list of protected species to be rescued (see draft EMP)
Biodiversity and conservation Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Loss of fauna and flora Local Perma
nent
Medium -
high High High High Local
Permanen
t Medium High High Medium
Soil contamination Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-3
714 Water related impacts
Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater
runoff spills and leaks Soil erosion
Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of
spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste
disposal Stormwater quality monitoring (see draft EMP)
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Soil erosion Local Short
term Medium Medium High Medium Local
Short
term Medium Low High Low
715 Waste management
Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed
Commentmitigation see draft EMP and waste management plan
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-4
Waste management Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Local
Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
716 Health and safety
Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Short
term
Medium -
high
Medium -
high High High Local
Short
term
Medium -
high Low High Low
717 Traffic
Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and
construction workers from surrounding areas and transport of equipment from the port
Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low
Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and
accurate estimates of quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-5
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Increased traffic on N2 and within the
IDZ Regional
Short
term Low High High Low
718 Noise
Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Short
term
Medium-
high High High Medium Local
Short
term Medium High High Medium
719 Socio-economic
Naturedescription of impact temporary employment will be created during the construction phase
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-6
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Temporary employment Regional Short
term Medium High High Medium
72 IMPACTS DURING OPERATION
721 Air quality
NatureDescription of impact gas and particulate emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning
Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local
sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and
veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute
to background fine particulate concentrations (von Gruenewaldt 2011b)
Assumptions and limitations Potential release of CR6+
As no emission factors are available for trivalent chromium processing the
potential impacts due to these activities could not be quantified
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Dust emitted from traffic on paved roads Regional Long Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-7
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
term
Hydrogen chloride emissions from
pickling process Local
Long
term Low High High Low
Particulate emissions (smoke) from
galvanizing process (due to the
volatilization of flux)
Local Long
term Low High High Low
Particulate oxides of nitrogen carbon
monoxide and sulphur dioxide emissions
from LNG burner
Local Long
term Low High High Low
Nuisance related to odour Local Long
term Low Low High Low
Abnormally high hydrogen chloride and
particulate emissions due to scrubber
malfunction
Local Short
term Medium Low High Medium
Gases (eg SOx NOx CO etc) and
smoke emitted in case of a fire Local
Short
term High Low High Medium
722 Water quality
NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks
Commentmitigation see draft EMP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-8
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Stormwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
723 Waste management and hazardous substances
NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous
waste both can affect environmental quality and human health
Commentmitigation see draft EMP and waste management plan
Waste management and hazardous
substances Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Regional
Long
term High
Medium -
high High High Regional Long term High Low High Low
Soilwaterair pollution due to improper
transport storage and handling of
hazardous substances
Regional Long
term High
Medium -
high High High Regional Long term High Low High Low
Health hazard Local Long
term High
Medium -
high High High Local Long term High Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-9
724 Health and safety
Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Long
term
Medium-
high
Medium-
high High High Local Long term
Medium-
high Low High Low
725 Traffic
Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on
the road network
Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak
hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road
network within Zone 6 of the IDZ (Iliso 2011)
Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)
Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of
quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-10
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on traffic and capacity of the N2 Regional Long
term Low High High Low
Impact on traffic and capacity of ring
road 1 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR435 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR450 Local
Long
term Low High High Low
Impact on traffic and capacity of
Neptune road Local
Long
term Low High High Low
726 Noise
Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Long
term Medium High High Medium Local Long term Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-11
727 Socio-economic
Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate
revenue for the municipality and the region as a whole
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Employment and economic growth Regional Short
term Medium High High Medium
73 COMPARATIVE ASSESSMENT OF IMPACTS
During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as
low during operation after mitigation
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 8-1
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
As a tenant operating in the IDZ Casa Steel will be required to comply with all
current and future CDC requirements as well as with the relevant conditions of
permits licences issued to CDC (eg Integrated Stormwater Masterplan for the
eastern side of the Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)
In particular the CDC has its own requirements regarding the monitoring of certain
aspects of the project such as the quality of the effluent and the noise levels These
have been incorporated into the EMP
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 9-1
9 ENVIRONMENTAL IMPACT STATEMENT
All predicted negative impacts can be mitigated to a low significance The only
exceptions are biodiversity as the construction of the plant will result in the
destruction of habitat and loss of fauna and flora and noise impacts inherent to
construction activities Mitigation measures have been included in the EMP for these
impacts and they have a medium significance post-mitigation
Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium to
long term similar impacts are likely to occur due to ongoing developments in the IDZ
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 10-1
10 CONCLUSION AND RECOMMENDATIONS
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as
other infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified
and assessed No fatal flaws have been identified
It is recommended that the project be approved subject to the conditions listed in
chapter 9 and adherence to the EMP requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 11-1
11 REFERENCES
Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ
Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants
Bennie JS (2010) The historical component (built environment) of the Heritage
Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port
Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report
compiled for Eastern Cape Heritage Consultants
Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater
Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay
Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage
Consultants
BKS (2006) Coega Industrial Development Zone Transport Study Volume 3
Demand Modelling Report Final Draft
Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I
Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6
Report compiled for SRK Consulting
Coastal amp Environmental Services (2010) Environmental Impact Assessment for the
Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone
Volume 3 Environmental Impact Assessment Report CES Grahamstown
Coega Development Corporation (2008) Industry Waste Management Plan -
Strategic Master Plan Report
Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants
Report No CDCSHE 03 8122
Department of Water Affairs and Forestry (1998) Waste Management Series
ldquoMinimum Requirements For The Handling Classification And Disposal Of
Hazardous Wasterdquo Second Edition
Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising
Plant in the Coega Industrial Development Zone
Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the
Coega Industrial Development Zone (IDZ) Specialist Water Study
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 11-2
Jacobs E (2008) Final Environmental Impact Report and Draft Environmental
Management Plan Proposed Steel Recycling and Processing Facility within the
Coega IDZ Report compiled for SRK Consulting
Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY
Galvanising Plant in the Coega Industrial Development Zone Waste Management
and Hazardous Substances Report compiled for ILISO Consulting
RSA National air quality standard for thoracic particulates (PM10) SA standards
(Government Gazette No 32816)
von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed
Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape
Report compiled for ILISO Consulting
von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel
Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report
compiled for ILISO Consulting
Additional sources
Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed
Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared
for Coastal Environmental Services
Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed
Kalagadi Manganese smelter in the Coega Industrial Development Zone Port
Elizabeth Eastern Cape Province Report prepared for Coastal Environmental
Services
Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia
steel recycling facility at the Coega Industrial Development Area Port Elizabeth
Prepared for SRK Consulting Port Elizabeth
APPENDIX A
LIST OF INTERESTED AND
AFFECTED PARTIES
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
DEDEARegional Manager
and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza
DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza
DEA Ocean and
CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza
DEA Ocean and
Coast
Oceanographer land-
based sources of
marine pollution
Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza
DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza
CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza
CDCEnvironmental
Project
Manager
Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza
TNPAPort of Ngqura
Environmental
Manager
Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet
NMBMEnvironmental
ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza
NMBMEnvironmental
ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza
DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza
DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza
WESSASenior Conservation
Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza
Zwartkops
ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700
hughlauegmailcom
zwartkopstrustiafricacom
SANParksNational Marine
CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza
Department Of
LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza
NMBM Air Quality
Division
Assistant
DirectorAir
Pollution and Noise
Templeton Titima 079 490 0574 Ttitimamandelametrogovza
NMBM Air Quality
DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza
NUMSARegional
RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
Department of
HealthNadiema
van der
Bergh083 378 2103
nadiemavanderberghimpiloecprovgov
za
DWA Chief Services
Officer
Joseph Jacobs 041 586 4884 jjacobsdwafgovza
EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza
NUMSecretary of union
officesZandile Xhentsa 043 743 6597 zxhentsanumorgza
DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza
Dynamic
CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom
EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza
Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza
UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom
lprincezago2uticom
Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza
Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza
Absa Mr Johann Steyn 082 3775820 johannstabsacoza
Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza
PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza
Universal
EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza
Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza
GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom
Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza
NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom
DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza
DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza
TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet
DWA Mr Landile Jack JackLdwagovza
DWA Ms Lizna Fourie FourieL4dwagovza
APPENDIX B
NOTICE OF ATMOSPHERIC
EMISSIONS LICENCE APPLICATION
AND ADVERTISEMENT
APPENDIX C
NOTICE OF COMMENT PERIOD FOR
DRAFT SCOPING REPORT
APPENDIX D
SUMMARY OF ISSUES RAISED AND
RESPONSES THERETO
April 2012
1
PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL
DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))
IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt
AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt
This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses
provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process
conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the
Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
2
IssueCommentQuestion Date
received Origin Response
1 Please provide more information with respect to the potential
dangers including the toxicity of the proposed project
07032011
By email
Wayne Poulton
(Bosun Brick
tenant at the
IDZ)
An Environmental Impact Assessment (EIA) was undertaken
which assessed the potential toxicity of the emissions and
effluent Mitigation measures were also recommended in the draft
Environmental Management Programme (EMP) to avoid
minimise or compensate any significant impacts The Draft
Environmental Impact Report and draft EMP were made available
to stakeholders for comment in March 2012
2 Do you have a Background Information Document (BID) or
similar that provides more information on the project
27032011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The BID was sent to all registered IampAPs on 4 May 2011
3 The RoD issued to the CDC on 632007 for the change in
land use for the remaining area of the Coega IDZ includes a
number of requirements with respect to
atmospheric emissions that should be considered in the
Atmospheric Emissions Licence (AEL) application such as
prohibiting and monitoring where possible visible emission
plumes to the atmosphere In particular the
recommendations on pp87-91 of the final revised Scoping
Report dated Nov 2006 must be implemented (clause 421)
04042011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
We have obtained copies of the documents referred to and ensure
that these requirements were taken into account in the
environmental assessment and AEL application
4 If the Port of Ngqura is used for import and export the scope
of the traffic impact assessment (TIA) should also include the
port
10052011
By email
Elliot
Motsoahole
(TNPA Port of
Ngqura)
The scope of the TIA was extended to include port related traffic
The TNPA at the Port of Ngqura was consulted and does not
have any objection to the project TNPA has indicated that the
development would require a minimum number of vessels per
year which would have minimal impact on the Port operations
However due notice would have to be given to the Port of Ngqura
before a vessel is scheduled to arrive so that the vessel can be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
3
IssueCommentQuestion Date
received Origin Response
accommodated at an available berth
5 Concerns with respect to potential stormwater pollution
draining into the Coega catchment and the port of Ngqura
The port needs to be dredged and heavy metals present a
risk in that regard
16052011
By
telephone
Andrew Lucas
(Department of
Water Affairs)
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination by effluent waste or
hazardousdangerous substances is very low
Thus no metals oils or other contaminants are expected to be
present in the stormwater
However stormwater pollution can occur in exceptional
circumstances such as accidents and emergencies The
emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
6 All steel sheets bathing unit must be under roof
7 The sludge out of the decreasing bath will be high in Na and
pH Therefore handling and disposal must be clarified up front
in this project
8 Per se the wastewater from decreasing bath will have high
ph and the component from the pickling unit will have low ph
Then it may be assumed that both streams will neutralize
each other Please then clarify proposed sewer discharge
with Nelson Mandela Bay Municipality up-front for acceptance
of influent as per the documented proposal
9 Pickling may result in dissolved metals How does your team
expect to deal with this As it is planned for discharge into
24052011
By email
Landile Jack
(Department of
Water Affairs)
All bathing units will be under roof
Effluent from the degreasing and pickling baths will be discharged
to the wastewater treatment plant The respectively alkaline and
acidic effluents will mix and neutralise each other in the
wastewater treatment plant Calcium or gypsum will be added if
required to complete the neutralisation process Effluent from the
treatment plant will be discharged to sewer Contact has been
made with the relevant officials and the Municipalityrsquos
requirements have been obtained The effluent discharged to
sewer will notably comply with the applicable discharge standards
Traces of metals (eg iron) may be present but will not exceed
prescribed thresholds The necessary authorisation will be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
4
IssueCommentQuestion Date
received Origin Response
sewer Clarity and acceptance needs to be agreed with
Nelson Mandela Bay Municipality Who owns the sewer
10 Quenching unit will results to Zinc particles How will this
affect sewer discharge This again must be dealt with within
the negotiations with the Municipality
11 Once all has been agreed with the Municipality and at the
same time due negotiations must be done with hazardous
waste courier and disposal facility to accept the hazardous
waste identified in all production lines
12 Of note is the low volume of the proposed WWTW facility ie
250 cubmweek And the no discharge of the quenching
water ie over-flow and cooling only Hence Zinc particles
generation
obtained from the municipality
The sludge from the treatment plant will be collected by a licensed
service provider and disposed of at a permitted site
The quenching bath will be periodically emptied (every 6 months)
and the water discharged will go to the water treatment plant Zinc
particles will settle in the sludge which will be disposed of at a
permitted site
Contact has been made with EnviroServ who manages the
Aloes II HH waste site regarding collection and disposal of
hazardous waste (See waste management report)
13 Investigate the potential effects of toxicity andor influence of
emissions waste and hazardous substances both in
terrestrial and marine fauna
14 With regards to water usage where is the plant going to
extract its waters used in galvanization andor waste
management process ie rainfall rivers or even from the
sea) and which avenues would be more environmental
friendly and effective
31052011
By email
A Bewana
(SANPARKS)
Emissions waste and hazardous substances are not expected to
affect terrestrial or marine ecosystems The air quality study
concluded that atmospheric emissions would not be harmful to
human health and by extension terrestrial fauna There are no
standards for air quality for defining faunal impacts therefore by
ensuring that standards for humans are complied with the impact
on fauna is deemed to be acceptable In this case the impact of
emissions on terrestrial and marine fauna are thus not significant
Solid and liquid wastes both general and hazardous as well as
hazardous substances will be stored handled and disposed of
appropriately to as not to cause harm to terrestrial or marine
fauna
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
5
IssueCommentQuestion Date
received Origin Response
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination and hence land-based
marine pollution by effluent waste or hazardousdangerous
substances is very low
The risk of emissions waste and hazardous substances to
terrestrial and marine fauna is thus very low
However pollution of terrestrial and marine ecosystems can occur
in exceptional circumstances such as accidents and emergencies
The emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
The CDC has an agreement with the NMBM to supply potable
water to the Coega IDZ Currently the infrastructure to supply
return effluent (RE) to the IDZ is not in place therefore Casa Steel
will be supplied with potable water up until such time as the
following 2 options of RE are available
1) Upgrading of the existing Fishwater Flats waste water
treatment works (between IDZ amp PE) including RE plant
and infrastructure to pipe RE to the IDZ (EIA for the
upgrade is underway)
2) Construction of a new waste water treatment works
including RE plant in Zone 9 of the Coega IDZ
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option should be investigated further between Agni and Casa The
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
6
IssueCommentQuestion Date
received Origin Response
CDC can facilitate discussions between the 2 investors
Compliance with CDC Permits amp Requirements
15 It should be made clear that tenants will be required to
comply with CDC requirements and the relevant conditions of
permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water
Licence for its Storm Water Systems on the
East Side of the Coega River that tenants will
need to take cognizance of The contents of the
ldquoIntegrated Stormwater Masterplan for the
eastern side of the Coega IDZ Oct 2010rdquo
especially the Table of best practice p53
onwards may need to be taken cognizance of
o CDC is developing an Operations
Environmental Management Plan that will place
certain obligations on tenants
16 Environmental audits and data collected during monitoring
(eg stack emissions stormwater) will need to be shared with
CDC
Air Emissions
17 Presumably permanent in stack monitoring will be required in
terms of AEL permit requirements
18 Abnormal operating conditions resulting in air emissions ndash I
could find nothing in the EIR to indicate under what
circumstances these could occur (eg start-up) potential
frequency and duration and the impact on ambient air quality
ndash these events usually result in the most problems wrt air
emissions
09042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
15 Compliance with the CDCrsquos Permits amp Requirements has
been included explicitly as a requirement in the EIR (p8-1) and
EMP (pp18 and 25) in the following terms
ldquoAs a tenant operating in the IDZ Casa Steel will be required to
comply with all current and future CDC requirements as well as
with the relevant conditions of permits licences issued to CDC
(eg Integrated Stormwater Masterplan for the eastern side of the
Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)rdquo
16 The need to communicate with the CDC on monitoring and
auditing activities was emphasised in Chapter 8 of the EMP The
following paragraphs were added
ldquoDuring construction the environmental officer will be responsible
for monitoring compliance with the EMP and authorisation
conditions and keeping records as required in the EMP andor
authorisation conditions
The ECO will conduct site inspections every two weeks audit the
records kept by the environmental officer and submit an
environmental compliance report every two months to the
authorities and the CDC (via the Environmental Monitoring
Committeersquos ECO)
During operation the health and safety officer will monitor
compliance with the EMP and the conditions of the Environmental
Authorisation Data collected during monitoring activities and any
environmental audits conducted will be shared with authorities
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
7
IssueCommentQuestion Date
received Origin Response
Water
19 Large volumes of (2000 m3mth) of water are required of
which only 400m3 needs to be potable The NMBM return
effluent system will provide non-potable water once it is
constructed What other water recycling initiatives can be
utilized to reduce potable water requirements (the ISWMP for
the eastern side of the Coega IDZ has some best practice
guidelines collecting rainwater from the roof etc)
General
20 There is no mention of how the CDC Architectural Guidelines
will be incorporated into the development (eg to prevent a
stark uniform warehouse type development)
21 Does NMBM have adequate fire services to cover this
development Apart from the large petroleum store are there
any other large fire hazards
22 Reports from the tenantrsquos ECO during construction and from
the SHE Officer during operations should be channeled to the
Coega Environmental Monitoring Committee This can be
directly or preferably via the EMCrsquos ECO (this will be while
the EMC and ECO are in place) A precedent has been set
for this in the Environmental Authorisations for Agni-Steel and
Kalagadi Manganese Smelter
23 All mitigation actions emanating from the EIR should be
summarized (preferably in a table) If compliance with them is
to be part of the Environmental Authorization from DEDEAT
then they (or the ones that DEDEAT deems to be applicable)
and the CDC (via the Environmental Monitoring Committeersquos
ECO)
The ECO (during construction) and the health and safety officer
(during operation) will report to the Coega Environmental
Monitoring Committee (EMC) via the EMCrsquos ECO (this will be
while the EMC and ECO are in place)rdquo
17 The draft EMP recommends regular monitoring of emissions
from the scrubbers and from the chromating process Additional
emissions monitoring requirements will be confirmed once the
AEL is issued Mention has been made in the EMP (pp11 and 19)
that all AEL conditions including monitoring and reporting
requirements should be adhered to
18 Abnormal emissions can occur in exceptional circumstances
Start-up will not cause abnormal emissions as the scrubbers
will be commissioned first and will be functioning once the plant
starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions
would be emitted as a building fugitive
The hourly hydrogen chloride ground level concentrations
(directly offsite) were predicted to be 239 microgmsup3 (based on the
emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits
as stipulated for listed activities for galvanising processes) using a
screen model which assumes worst case meteorological
conditions The health effect screening level for hourly HCl
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
8
IssueCommentQuestion Date
received Origin Response
should be attached to the EA as an Appendix (otherwise no
one knows about them or takes cognizance of them)
concentrations is 2100 microgmsup3 Assuming abnormal emissions
emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset
conditions will still be well within the health effect screening
levels
Similarly the hourly particulate emissions from the building
fugitives during upset conditions would amount to 293 microgmsup3
(based on the emission limits as stipulated for listed activities for
galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1
January 2015) directly off-site
Therefore if emissions are 5 times higher normal they will still be
within health effect screening levels and the daily PM10 NAAQS
levels
In the case of a fire a cocktail of gases and particulates could be
emitted and could be over the recommended levels This
situation will however be dealt with as an emergency and
normalised as quickly as is possible
The above has been added to the impact identificationdescription
and assessment sections of the EIR
19 The CDC has an agreement with the NMBM to supply
potable water to the Coega IDZ Currently the infrastructure to
supply return effluent to the IDZ is not in place therefore Casa
Steel will be supplied with potable water up until such time as the
infrastructure is in place
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
9
IssueCommentQuestion Date
received Origin Response
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option will be investigated further between Agni and Casa The
CDC has come forward to facilitate discussions between the two
investors
Other water recycling initiatives such as rainwater harvesting
have been considered but are not practical
20 The CDCrsquos Architectural and Landscape Design guidelines
contain requirements pertaining to such aspects as the height
orientation and mass and form of buildings as well as guidelines
for landscaping and signage in order to ensure an attractive
development and achieve an architectural integrity within the
Coega IDZ The plans for the proposed galvanizing plant will be
submitted to the Design Review Committee for approval as
required by the CDC
21 Casa Steel will be required to install fire hydrants according
to the NMBMrsquos standardsrequirements The CDC will provide
potable water (up until such time as return effluent is available)
and a connection to the boundary of the site which will be
connected to the fire hydrants The installation of the fire hydrants
will require approval by the Metrorsquos Fire Chief as was done for
Agni-Steel one of the investors in Zone 6
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
10
IssueCommentQuestion Date
received Origin Response
The Coega IDZ falls within the NMBM and therefore the rates and
taxes paid by the CDC covers the fire services for which the Metro
is responsible Currently the Metro has sufficient capacity to
provide fire services to the tenants within the IDZ This was
confirmed in discussion with the CDCrsquos Infrastructure
Development Unit It is however unknown at which point the
Metrorsquos Disaster Management Plan would not be able to
accommodate servicing tenants in the IDZ
The LNG burner is the only major fire hazard on the plant
22 See response to item 16 above
23 Key mitigation and management measures emanating from
the EIR were recapitulated in Chapter 9 of the EIR to form part of
the conditions attached to the Environmental Authorization from
DEDEAT All mitigation measures recommended as a result of the
impact assessment are presented in a table in the draft EMP
which is appended to the EIR (Appendix J)
24 Hydrogen chloride is one of the main emissions There are no
ambient air quality guidelines for HCl and the EIR says
concentrations will be well within health parameters
However the main problem with HCl is its corrosive effect -
there is absolutely no mention of this in the draft EIR nor air
specialist report
There needs to be some sort of comment assessment as to
whether HCl emissions are likely to impact on for example
the adjacent Agni-Steel Plant wrt corrosion - their factory
structure will be made of steel
11042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The atmospheric corrosion of metals is a complex process with
both the extent of deterioration and the mechanisms varying
considerably depending on the metal Depending on the way
pollutants are transported from the atmosphere to the corroding
surface two types of deposition processes are recognized in
atmospheric corrosion ndash dry deposition and wet deposition Wet
deposition refers to precipitation whereas dry deposition refers to
the remaining processes including gas phase deposition and
particle deposition The most important pollutants acting as
corrosive agents are sulphur and nitrogen compounds including
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
11
IssueCommentQuestion Date
received Origin Response
The EIR specialist rpt suggests monitoring HCl at ground
level on the property boundary and this is supported in case
there are complaints from neighbours
secondary pollutants and particulates Pollutants can contribute to
corrosivity individually however there may be a synergistic effect
when more than one of these pollutants is present in the
environment being affected In the field of atmospheric corrosion
sulphur dioxide is the single most investigated gaseous pollutant
and the quantification of the direct contribution of sulphur dioxide
to the corrosion process of metallic materials is comparatively well
understood (Tidblad amp Kucera 1998)
Very little work has reported on the effect of HCl on the
degradation of materials in the environment with no local dose-
response thresholds developed for corrosion occurring due to HCl
exposures This is probably because HCl which is present
outdoors in markedly reduced concentrations when compared
with SO2 has not been considered to contribute to significant
degradation of materials (Syed 2006) For this reason the
incremental corrosion due to HCl from the Coega Galvanising
Plant cannot be quantified
25 It is unacceptable for ILISO to be using CDC maps (see
figure 9 ndash pg5-6) without these maps being referenced
accordingly particularly when it appears that a CDC map has
been used and then overlaid with features by an unknown
author (ie CASA steel site Port (where the boundaries
depicted are incorrect) and a North legend which is out of
keeping with the overall cartographic intent of the original
work
26 Figure 10 is not referenced appropriately and I believe that I
commented previously in respect to references to roads not
12042012
By email
Graham Taylor
(Spatial
Development
Manager -
Infrastructure
Development
CDC)
This has been rectified in the final version of the report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
12
IssueCommentQuestion Date
received Origin Response
yet built As a result Figure 10 is confusing and clarity needs
to be provided in terms of referencing In addition the Port
shape is irregular and similar to the comment above
27 I acknowledge the emergency preparedness and response
plan but please confirm that this includes pro-active routine
monitoring of storm water leaving your premises to verify that
your assumptions of clean storm water are correct
13042012
By post
Andrew Lucas
(Director
WRampU
Department of
Water Affairs)
Pro-active routine monitoring of stormwater leaving the premises
will be undertaken This has been explicitly emphasised in
chapter 8 of the draft EMP
28 Will portablechemical toilets be used during construction
29 What provisions have been made for storm water drainage
during construction
18042012
By
telephone
Department of
Water Affairs
Port Elizabeth
Chemical toilets will be used during construction
The Casa Steel site will be located at the corner of two roads
drainage of stormwater from the site will take place through the
roadsrsquo drainage system
From Lea September [mailtoleailisocom]
Sent 11 March 2011 0935 AM
To Wayne Poulton
Cc Terry Baker
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Wayne
An Environmental Impact Assessment (EIA) will be undertaken for this project during the
next 10 to 12 months
We foresee that some of the key environmental impacts of the project will be in terms of air
quality water quality waste and hazardous substances
At this stage I am not able to give you any details regarding the potential toxicity of the
emissions andor effluent However specialist studies will be conducted as part of the EIA
that will determine the key impacts of the project Mitigation measures will also be identified
to avoid minimise or compensate any significant impacts
You are registered on the stakeholder database and you will be kept informed of progress in
the EIA process you will notably get the opportunity to access the reports produced and
provide any feedback on them
Please feel free to contact me should you need any further information
Best regards
Lea September
From Wayne Poulton [mailtowaynepbosuncoza]
Sent 07 March 2011 1257 PM
To Lea September
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
Please can you provide me with some more information as to the potential dangers including
the toxicity of this
Kind regards
Wayne
From Lea September [mailtoleailisocom]
Sent 04 March 2011 1123
To Lea September
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 March 2011 0745 AM
To Paul Martin
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 05 April 2011 0847 AM
To Paul Martin
Cc Terry Baker Renee von Gruenewaldt
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Thank you Paul for this information
I have downloaded a copy of the RoD and Scoping report you referred to and will make sure
these requirements are taken into account in the environmental assessment
Best regards
Lea September
From Paul Martin [mailtopmartinaxxesscoza]
Sent 04 April 2011 0955 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Further to my comments on 27311
Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in
the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega
IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised
scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions
including prohibiting and monitoring where possible visible emission plumes to the atmosphere
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Paul Martin
Sent Monday March 28 2011 745 AM
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 10 May 2011 0327 PM
To ElliotMotsoaholetransnetnet
Cc Terry Baker
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Mr Motsoahole
Thank you for your input on this issue
The Port of Ngqura will indeed be used for import and export At the moment the scope of
the traffic impact assessment only covers road traffic I have however relayed the matter to
our traffic specialist and we will consider this issue in the finalization of the Scoping Report I
will keep you informed of any developments in that regard
I trust this is acceptable to you
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]
Sent 10 May 2011 0855 AM
To Lea September
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
It has been noted that Casa Steel will source steel coils from various markets internationally and
in South Africa and the bulk of the plantrsquos production output will be exported to African countries
However there is no mention of logistic requirements
Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will
be used the scope of traffic impact assessment should also include the port
Regards
From Lea September [mailtoleailisocom]
Sent 04 May 2011 0747 AM
To Lea September
Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
Please find attached a letter announcing the EIA process underway for the proposed 80 000
tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as
a Background Information Document (BID) outlining the details of the project
Please contact me should you require any further information on this project
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
Elliot Motsoahole
Manager - Environment
Transnet National Ports Authority
Port of Nqqura
Port Control Building Klub Road Port Elizabeth 6212
PO Box 612054 Bluewater Bay 6212
+27 41 507 8450
+27 86 674 7729
Cell +27 83 542 5619
E-mail Elliotmotsoaholetransnetnet
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
DISCLAIMER The information contained in this communication is subject to copyright and
intended only for the use of leailisocom Unauthorised use disclosure or copying is
strictly prohibited Should a virus infection occur as a result of this communication the sender
will not be liable If you have received this communication in error please notify
elliotmotsoaholetransnetnet
From Lea September [mailtoleailisocom]
Sent 25 May 2011 1147 AM
To Jack Landile (ELS)
Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi
Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Landile
Thank you for your input
Contact has been made with the relevant Municipal Directorate and we will follow up with
them to obtain clarifications on all these issues
I have added both Lizna and yourself on the database and will keep you updated on
progress on this project
Best regards
Lea September
From Jack Landile (ELS) [mailtoJackLdwagovza]
Sent 24 May 2011 0524 PM
To Fourie Lizna (ELS)
Cc Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Hi Lizna
I missed you on this sorry
I linked Pieter twice Instead
Regards
Landile
From Jack Landile (ELS)
Sent 24 May 2011 0445 PM
To leailisocom
Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Lea
The e-mail you sent to Mr Kooverji dated 19 May 2011 refer
Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are
All steel sheets bathing unit must be under roof
The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project
Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal
Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer
Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality
Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines
Of note is the low volume of the proposed WWTW facility ie 250 cubmweek
And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles
generation
Regards
Landile
From Lea September [mailtoleailisocom]
Sent 19 May 2011 0947 AM
To Lea September
Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Stakeholder
Please find attached the remaining appendices to the draft Scoping report for the proposed
80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 June 2011 0411 PM
To Aphiwe Bewana
Subject RE Proposed 80 000 TPY Galvanizing plant in Coega
Dear Mr Bewana
Thank you for your input and apologies for the late reply
We have taken note of your comments and are will be taking them forward in the EIA phase
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Aphiwe Bewana [mailtoaphiwebewanagmailcom]
Sent 31 May 2011 1205 PM
To Lea September
Subject Re Proposed 80 000 TPY Galvanizing plant in Coega
Comment
Re Proposed 80 000 TPY Galvanizing plant in Coega
As SANParks we would like the EIA phase to investigate the potential effects of toxicity
andor influence of emissions waste and hazardous substances both in terrestrial and
marine fauna In the draft scoping report reference has been made with regards to the
terrestrial fauna but there is no attention to potential effects to marine fauna
Equally with regards to water usage where is the plant going to extract its waters used in
galvanization andor waste management process ie rainfall rivers or even from the sea)
and which avenues would be more environmental friendly and effective
Regards
Aphiwe Bewana
Marine Planner
South African National Parks
POBox 76693
NMMU
Port Elizabeth
6031
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 06 July 2011 1031 AM
To Lea September
Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Hi Lea
Irsquove reviewed the Final Scoping Report Herewith a few comments
1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the
Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a
revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the
NMBLP Please include only those in the IDZ as part of your IAP list
Regards
Andrea
From Lea September [mailtoleailisocom]
Sent Wednesday July 06 2011 859 AM
To Lea Septemberrsquo
Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Dear Stakeholder
The final scoping report for the above-mentioned project (attached) is available for comment
until 27 July 2011
The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic
commentaryrdquo tab
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 09 April 2012 1159 AM
To Lea September
Subject Comments on Galvanising Plant EIR Coega IDZ
Lea
Attached are my comments on the Draft EIR for the Coega IDZ galvanising
plant
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
Email attachment
COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ
Dr Paul Martin PO Box 61029
Bluewater Bay 6212 Tel 041 4665698
Email pmartinaxxesscoza
Compliance with CDC Permits amp Requirements
It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of
o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants
Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC
Air Emissions
Presumably permanent in stack monitoring will be required in terms of AEL permit requirements
Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions
Water
Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)
General
There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)
Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards
Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter
All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 11 April 2012 1245 PM
To Lea September
Subject Fw Comments on Galvanising Plant EIR Coega IDZ
Lea
One other comment on that I have on the Galvanising Plant Draft EIR
Hydrogen chloride is one of the main emissions There are no ambient air
quality guidelines for HCl and the EIR says concentrations will be well
within health parameters
However the main problem with HCl is its corrosive effect - there is
absolutely no mention of this in the draft EIR nor air specialist report
There needs to be some sort of comment assessment as to whether HCl
emissions are likely to impact on for example the adjacent Agni-Steel
Plant wrt corrosion - their factory structure will be made of steel
The EIR specialist rpt suggests monitoring HCl at ground level on the
property boundary and this is supported in case there are complaints from
neighbours
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Paul Martin ltpmartinaxxesscozagt
To Lea September ltleailisocomgt
Sent Monday April 09 2012 1158 AM
Subject Comments on Galvanising Plant EIR Coega IDZ
gt Lea
gt
gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising
gt plant
gt
gt
gt Dr Paul Martin
gt PO Box 61029
gt Bluewater Bay 6212
gt Tel 041 4665698
gt Cell 0732524111
gt email pmartinaxxesscoza
gt
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 12 April 2012 1139 AM
To Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Hi Lea
Hope yoursquore keeping well
I have requested comments from my colleagues and the CDC Casa team on the Draft EIR
Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report
Regards
Andrea
From Graham Taylor
Sent Thursday April 12 2012 838 AM
To Andrea Von Holdt Firhana Sam
Cc Johan Fourie Maria van Zyl Melikhaya Sihawu
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Andrea Firhana
Firhana if you could please ensure that the co-ordinates provided in the EIR correspond
with our records (pages 4-1 amp 4-2)
My comments are as follows
It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work
Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above
Regards
Graham Taylor
Spatial Development Manager - Infrastructure Development
Mobile 0832283055
Office 0414030454
Facsimile 0865185033
Email GrahamTaylorcoegacoza
Website wwwcoegacom
right PLACE | right TIME | right CHOICE
This email and all contents are subject to the following disclaimer
httpwwwcoegacomemaildisclaimerhtml
From Lea September [mailtoleailisocom]
Sent 04 May 2012 0411 PM
To Andrea Von Holdt
Cc Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Dear Andrea
We have taken note of the comments from the GIS Unit These issues have been rectified in
the final version of the EIR
Please can you forward to the relevant persons at the GIS Unit
Thank you
Best regards
Lea September
APPENDIX E
BACKGROUND INFORMATION
DOCUMENT
APPENDIX F
AIR QUALITY IMPACT ASSESSMENT
APPENDIX G
TRAFFIC IMPACT ASSESSMENT
APPENDIX H
WASTE MANAGEMENT AND HAZARDOUS
SUBSTANCES SPECIALIST STUDY
APPENDIX I
WATER QUALITY SPECIALIST STUDY
APPENDIX J
ENVIRONMENTAL MANAGEMENT
PROGRAMME
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-1
1 INTRODUCTION
11 BACKGROUND
Casa Steel Trading (Pty) Ltd (Casa Steel) proposes to construct and operate a
80 000 tonsyear galvanising plant in the Coega Industrial Development Zone (IDZ)
Nelson Mandela Bay Municipality Eastern Cape Province
The demand for galvanised steel products is high in South Africa and Africa and is
expected to increase in the foreseeable future From an economic point of view the
proposed project has therefore been found to be viable
Casa Steel will source the steel coils from various markets internationally and in
South Africa and the bulk of the plantrsquos production output (approximately 80-90 ) is
destined to be exported mainly to African countries
12 REQUIREMENT FOR AN ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
An Environmental Impact Assessment (EIA) is required as the proposed project
involves several activities listed in terms of Section 24 of the National Environmental
Management Act (NEMA) No 107 of 1998 as amended and requires an
environmental authorisation
The following listed activities requiring environmental authorisation have been
identified
Activity 13 of Listing Notice 1 (GN 544 of 2010) The construction of facilities 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
Activity 23 of Listing Notice 1 (GN 544 of 2010) Transformation of undeveloped
land to industrial use greater than 1 ha but less than 20 ha in size outside an
urban area
Activity 5 of Listing Notice 2 (GN 545 of 2010) Construction of facilities for any
process or activity requiring a license in terms of national or provincial legislation
governing the generation or release of emissions
Activity 14 of Listing Notice 3 (GN 546 of 2010) The clearance of an area of 5
hectares or more of vegetation where 75 or more of the vegetative cover
constitutes indigenous vegetation except where such removal of vegetation is
required for
(i) purposes of agriculture or afforestation inside areas identified in
spatial instruments adopted by the competent authority for
agriculture or afforestation purposes
(ii) the undertaking of a process or activity included in the list of waste
management activities published in terms of section 19 of the
National Environmental Management Waste Act 2008 (Act No 59
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-2
of 2008) in which case the activity is regarded to be excluded from
this list
(iii) the undertaking of a linear activity falling below the thresholds in
Notice 544 of 2010
Hot dip galvanizing is a listed activity in terms of section 21 of the National
Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires
an Atmospheric Emissions Licence (AEL)
In addition the treatment of wastewater with an annual throughput capacity of more
than 2000 m3 is a listed activity in terms of the National Environmental Management
Waste Act 59 of 2008 and requires a waste management licence
ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental
Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact
Assessment process in terms of section 24 of NEMA for the construction and
operation of the proposed galvanizing plant The EIA process covers all aspects of
the project and informs all three applications (for environmental authorisation waste
management licence and AEL)
13 PURPOSE OF THIS REPORT
This report builds on the scoping report submitted to the Eastern Cape Department of
Economic Development and Environmental Affairs (DEDEA) and the Nelson
Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It
describes the proposed project and presents the findings of the second phase of
investigations (EIA phase)
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP)
The EIA was managed by Ms Terry Baker a certified Environmental Assessment
Practitioner with 20 years of working experience She has a MA in Environmental
Management and specialises in Environmental Impact Assessments and Project
Management She has been involved in a variety of different types of EIAs including
for water supply projects dams transmission lines roads and airports in South
Africa Botswana Uganda Lesotho and Mozambique She has been involved in
water resource management and public participation programmes on a number of
projects Terry has also been involved in the use of Geographic Information Systems
environmental status quo reports water quality assessments socio-economic and
institutional development projects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-3
15 PROJECT TEAM
In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen
(water quality specialist) and Lea September (EAP) with specialist input from Renee
von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous
substances) and Seniel Pillay (Traffic Impact Assessor)
The Business Unit Head of the ILISO Environmental Management Discipline Group
Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is
a Fellow of the South African Institution of Civil Engineers a member of the South
African Society of Aquatic Scientists of the Environmental Scientific Association of
the International Water Association of the Water Institute of South Africa and of the
Vaal River Catchment Association He is a certified Environmental Assessment
Practitioner with 30 years experience who specialises in project management
environmental impact assessments and water resource planning He specifically has
extensive experience in water quality especially water quality management water
quality monitoring and water quality assessment Martin has experience in managing
projects that involve multi-disciplinary teams and public consultation and
participation in South Africa and abroad
Lea September is an Environmental Assessment Practitioner with a Masters degree
in Environmental Management She has experience in impact assessment and
environmental management and has been responsible for drafting impact
assessment reports and Environmental Management Programmes and conducting
public participation processes as well as high level environmental screenings for a
variety of projects in the energy water transport and industrial sectors
Renee von Gruenewaldt has nine-years experience in the field of air pollution
impact assessment and air quality management Prior to becoming involved in air
quality consultation she was part of the Highveld Boundary Layer Wind Research
Group based at the University of Pretoria Since joining Environmental Management
Services (the company now Airshed Planning Professionals) she has undertaken
numerous air pollution impact studies and has provided extensive guidance to both
industry and government on air quality management practices
Pieter Smuts graduated as a Civil Engineer and became involved in the field of
municipal engineering and infrastructure construction He has specialized during the
last twelve years in solid waste management He has completed waste management
plans feasibility studies and final designs of waste management facilities in South
Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and
the review of the Mavoco hazardous waste landfill design in Maputo Mozambique
and completed a study on hazardous waste (textile factory sludge) management in
Maseru Lesotho
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-4
Seniel Pillay is a transportation engineer with over 16 years experience in
transportation planning and traffic engineering He has been involved in a wide
range of projects ranging from developing the Transport Operations Plan for the
FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System
for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller
traffic impact assessments for inter alia road improvement schemes Of particular
relevance to this project his experience includes Heavy Goods Vehicle Study for
eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact
Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash
Preliminary Transportation Assessment
16 STRUCTURE OF THIS REPORT
The proposed project and the alternatives considered are described in Chapter 2
Chapter 3 details the approach adopted for the EIA phase
The biophysical and socio-economic environment affected by the activity is described
in Chapter 4
The environmental impacts identified are discussed in Chapter 5
The EIA methodology is described in Chapter 6 and Chapter 7 presents the results
of the impact assessment
The environmental impact statement is presented in Chapter 8
Finally Chapter 9 spell out the conclusions and recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-1
2 DESCRIPTION OF THE PROPOSED PROJECT
21 TECHNICAL ASPECTS
211 The galvanizing process
Galvanizing consists of coating steel with zinc in order to protect it from corrosion
Before steel strips can be galvanized they undergo a pre-treatment in order to
ensure that the steel sheets are free from any surface oxides as they enter the
molten zinc coating Bath This is done by removing the oil from the steel sheets (in
the degreasing unit) and then removing the rust from the surface of the sheet (in the
pickling unit)
The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The
melting zinc on the strip surface will be cooled and solidified through air cooling in the
cooling tower
Finally the galvanised steel sheets are dipped into a water quenching tank in order to
further cool the sheets from about 150degC to 40degC
It is possible to make galvanised steel more durable by chromating it Approximately
50 of the galvanised steel production output will receive chromate passivation
treatment after quenching the galvanised steel sheets will be sprayed with a chrome
solution (3 kgcm2)
After galvanizing and chromating the steel sheets are cut to achieve the desired coil
size and weight and transported to the storage yard
The process flow diagram below (Figure 1) illustrates the main stages of the
galvanizing process and indicates the major inputs and outputs as well as the
resulting effluent and atmospheric emissions
Draft Environmenal Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-2
Figure 1 Process flow diagram for proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-3
212 Main inputs and outputs in operational phase
In view of the above the main inputs will be as follows
Steel coils 85 000 tonsyear
Zinc 870 tonsyear
Electricity 2500 kVA
Water 2000 m3month (of which 400 m3 will be potable water)
Liquid Natural Gas (LNG) 270 NM3hour
Sodium hydroxide (NaOH) 1000 m3year
Hydrochloric acid (HCl) 800 m3year
Chrome (Cr+3) 10 m3year
The main outputs will be
Galvanized steel 80 000 tonsyear
Scrap metal 20 tonsyear
General waste 65 tonsyear
Hazardous waste 2 m3month
Wastewater 012 Mlweek
Atmospheric emissions lt 5 ppm
213 Installations on site
The bulk of the operations involved in the galvanizing process occur along a
continuous galvanizing line (See Figure 2 below) which is the main piece of
machinery required for the proposed galvanising plant
Figure 2 Continuous Galvanizing Line
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-4
Water is one of the major inputs and is used throughout the galvanizing process notably
for rinsing and cooling purposes and as a mixing agent for the various chemical
solutions The plant will have a water treatment plant on site to treat the water used in
the various processes (approx 250 m3
of wastewater per week) The wastewater
treatment facility will be operated by a professional water treatment company as Casa
Steel does not have the required expertise in house to treat its process water Sulphuric
acid (H2SO4) is used as part of the treatment process to reduce caustic soda The
neutralised water is discharged to the sewer while any sludge is disposed of as
hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)
will be disposed of
Some critical areas of the galvanizing process such as the zinc pot require uninterrupted
power It is therefore proposed to install an LNG burner to maintain the zinc bath at a
temperature of between 450 and 460degC
22 LOCATION OF THE PROPOSED GALVANIZING PLANT
The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast
of Port Elizabeth in the Eastern Cape (Figure 3)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-5
Figure 3 Location of the proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-6
23 NEED AND DESIRABILITY
The profitability of the proposed project has been established by Casa Steel and a
pre-feasibility study has confirmed that the proposed project was feasible from a
technical and financial point of view The Coega IDZ is specifically designed to host
facilities such as a galvanizing plant and can provide the necessary infrastructure
and services to its investors It therefore constitutes a very suitable location for the
project
24 ALTERNATIVES IDENTIFIED
Zone 6 has been specifically earmarked for heavy ferrous metal industries and is
therefore a suitable location for the proposed galvanizing plant as such no site
alternatives have been provided for and assessed in this EIA However prior to the
commencement of the EIA process Casa Steel was presented with a number of
different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the
selection of the site were
(a) The dimensions of the land the site should be at least 200 m long and
50 m wide in order to accommodate the galvanizing line and adjacent lay
down area and additional land should be available next to the site for future
expansion
(b) The fiscal arrangements applying to the site the site should be located
within the future Custom Controlled Area (CCA) as the bulk of the
production output of the plant will be exported
The no-go alternative is assessed in this report
25 CONSTRUCTION ASPECTS
The construction phase of the project will take about 12 months and will essentially
consist of erecting a building to house the galvanizing line and other equipment and
preparing a concrete laydown area adjacent to the building
The CDC will provide an access point from the existing tarred road that will lead to
the site
Approximately 100 workers from the surrounding areas will be contracted for the
construction work
The requirements in terms of services during construction are listed below
Water 1000 m3month
Electricity 2500 kVA
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-7
The CDC will provide temporary services for the construction phase including a
conservancy tank for flush toilets Sewage infrastructure will only be provided for the
operational phase
26 OPERATION ASPECTS
Before the plant can become fully operational the equipment and machinery will be
tested for approximately 3 months The supplier will supervise these tests as part of
the transfer of know-how and training of staff on the plant
Casa Steel will start operating the plant at a reduced capacity (about 50 000
tonsyear) for a period of time (mostly determined by market aspects) before bringing
production to full capacity (80 000 tonsyear) This is done by operating the line for
longer hours
Approximately 50 to 60 people will be working on the plant Approximately 6-10 of
these will be unskilled 40-45 skilled and about 5 people in managerial positions
The requirements in terms of services during operation are as follows
Water 2000 m3month
Electricity 2500 kVA
Effluent discharge 24 m3day
The CDC has entered into agreements with the municipality to secure the provision
of services such as water and electricity to its tenants Tenants in the IDZ have their
own agreements with the NMBM for electricity while the agreements for water and
sewage are with the Facilities Unit of the CDC
Regarding discharge of wastewater to the sewer the municipality indicated that the
only requirement is that the water discharged complies with applicable municipal
discharge standards
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 3-1
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT
31 OBJECTIVES
The main objectives of the EIA phase are to
Assess the significance of the environmental issues and impacts identified in the
scoping phase focusing on key impacts
Recommend appropriate measures to mitigate negative impacts and enhance the
benefits and include them in the draft EMP
Undertake a public participation process that provides opportunities for all
interested and affected parties (IampAPs) to be involved
32 AUTHORITY CONSULTATION
The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental
Liaison Committeersquo (ELC) which comprises representatives of various authorities
including DEDEAT the Department of Environmental Affairs (DEA) and Department
of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the
Coega Development Corporation (CDC) and Transnet National Ports Authority
(TNPA) The ELC has been specifically formed to facilitate EIA applications in the
IDZ
Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to
the clearance of vegetation should be included in the application A formal request
was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the
application and all registered stakeholders were informed of the request in writing on
19 October 2011
33 PUBLIC PARTICIPATION PROCESS CONDUCTED
On-site notices were replaced by a notification displayed on the CDCrsquos digital notice
board at the business centre in Zone 1 of the IDZ The eNotice was placed on
13 April 2011 and will remain for the full duration of the EIA process
Registered stakeholders will be notified in writing of the availability of the draft EIA
report and EMP which will also be advertised in a local newspaper Stakeholders
including state departments and the public will have forty (40) days to comment on
the draft EIA report and EMP The draft EIA report and EMP will be sent by email
where possible and made available for download on the ILISO website
(wwwilisocom)
A summary of all issues and comments received during the stakeholder consultation
process as well as of correspondence in that regard will be captured in an Issues
and Responses Report that will form an Appendix to the EIA Report
The list of registered IampAPs is included in Appendix A
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 3-2
34 LEGISLATION AND GUIDELINES CONSIDERED
The following legislation and guidelines were considered in the preparation of this
report
National Environmental Management Act Act No 107 of 1998
NEMA EIA Regulations 2010
National Environmental Management Air Quality Act Act No 39 of 2004
National Environmental Management Waste Act Act No 59 of 2008
Hazardous Substances Act Act 15 of 1993
Occupational Health and Safety Act Act 85 of 1993
Hazardous Chemical Substances Regulations 1995 (GNR 1179)
Major Hazard Installation Regulations 2001 (GNR 692)
National Water Act Act 36 of 1998
National Heritage Resources Act Act 25 of 1999
DEAT Integrated Environmental Management Information Series 1-5 and 12-15
NEMA draft Implementation Guideline
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Public Participation (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Alternatives (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Draft Guideline for Determining the Scope of Specialist
Involvement in EIA Processes (2005)
IAIA guidelines
National air quality standard for thoracic particulates Government Gazette
No 32816
Listed activities and associated minimum standards identified in terms of section
21 of the National Environmental Management Air Quality Act Act No 39 of
2004 Government Notice 248 of 2009
Minimum Requirements for the Handling Classification and Disposal of
Hazardous Waste DWAF Waste Management Series (1998)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-1
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION
The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega
IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay
to the north of the N2 highway between Port Elizabeth and Grahamstown east of the
Coega River
The co-ordinates of the corners of the site are shown in Table 1
Table 1 Coordinates of site corners for the proposed galvanizing plant
Point Longitude Latitude
A 25deg411126E 33deg45587S
B 25deg411156E 33deg45499S
C 25deg411938E 33deg45131S
D 25deg412174E 33deg45481S
E 25deg412508E 33deg45979S
F 25deg412634E 33deg451160S
G 25deg411782E 33deg451560S
H 25deg411692E 33deg451428S
J 25deg411314E 33deg45868S
Figure 4 Zone layout in the Coega IDZ
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-2
Figure 5 Site location
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-3
42 SOCIO-ECONOMIC CHARACTERISTICS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the
NMBM There are no residents within the IDZ
As far as the broader NMBM and Eastern Cape Province are concerned the
following can be noted The NMBM is located within the Eastern Cape Province the
2nd largest Province in South Africa (3rd in terms of population) characterised by a
predominantly black population with low incomes and high levels of unemployment
(CES 2010)
The NMBM has a population of just above 11 million and covers an area of
1 950 km2 It is the main urban and industrial centre of the province and Port
Elizabeth in particular which forms part of the NMBM is the commercial capital of
the Eastern Cape 52 of the NMBM population is female and 37 is below the
age of 20 these two groups are particularly affected by unemployment
43 BIOPHYSICAL CHARACTERISTICS
431 Surface and ground water
No rivers occur in Zone 6 There is however a natural attenuation pond on the
southern most part of the site which will have to be avoided
The IDZ is underlain by calcrete sand and gravel deposits that overlie low
permeability clays These clays limit the vertical infiltration of rainwater and induce a
horizontal groundwater flow towards the Coega River channel which is the most
significant surface water feature in the Coega IDZ Consequently rapid run-off takes
place following precipitation (Jacobs 2008)
Groundwater levels at Coega are generally about 3 to 5 m below surface ie just
above the contact between the permeable sands and the underlying impermeable
clays The groundwater flow direction is to the southeast following the surface water
drainage direction (Jacobs 2008)
432 Climate and atmospheric conditions
Port Elizabeth has a warm temperate climate and the temperature ranges are not
extreme Exceptionally high temperatures may be experienced during berg wind
conditions which occur frequently during autumn and winter Extreme temperatures
also occur during summer with little accompanying wind
The wind regime for the area largely reflects the synoptic scale circulation with
dominant westerly and northwesterly flow fields representing the pre-frontal
conditions and south-westerly flow fields representing the frontal conditions The
south-easterly and south-westerly wind flow (land breeze) increases during daytime
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-4
conditions with westerly and north-westerly wind flow increasing during the night (sea
breeze)
The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of
Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15
km southwest) and Port Elizabeth (~23 km southwest)
An ambient air monitoring network has been established in the Coega IDZ which
consists of three monitors Saltworks Motherwell and Amsterdamplein Although
NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative
impacts due to the proposed Galvanising Plant is PM10 A maximum daily average
PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed
SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3
was exceeded on 17 days in 2007 and 26 days in 2008
Existing sources of emissions in the vicinity of the proposed galvanizing plant include
industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other
fugitive dust sources (von Gruenewaldt 2011b)
433 Geology and soils
Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel
and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly
limestone and conglomerate
434 Terrestrial ecology
This section draws from the EIA report compiled for the Agni Steel (formerly Afro-
Asia) steel processing facility which is adjacent to the proposed site for the
galvanizing plant (Jacobs 2008)
The area consists largely of grasses succulents and scrubby bush with alien
species making up the greater part of the more dense vegetation
Zone 6 falls within the inland vegetation and is characterised by a vegetation type
referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the
Coega IDZ and has been found to have three times the level of endemism of other
vegetation communities in the Coega IDZ Bontveld therefore has a high
conservation status Two Bontveld conservation areas have been identified within the
IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)
Bontveld that will be destroyed as a result of development in the IDZ will be given
conservation status in these two areas
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-5
Figure 6 Coega IDZ Open Space Management Plan (OSMP)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-6
Certain areas in the IDZ are invaded by alien plant species The most common
invader species is rooikrans (Acacia cyclops) which presently forms large
monospecific stands in areas throughout the Coega IDZ There are several other
aliens present that pose a threat to the flora of this area including the prickly pear
(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)
Loss of vegetation and alien plant invasion due to human activity has resulted in a
reduction in the diversity of terrestrial fauna
The majority of mammals present in the Coega IDZ are small or medium-sized Of
the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed
gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of
Algoa Bay however it is not considered threatened The gerbil is common in
foredune and dune thicket habitat in the Coega region and is therefore unlikely to
occur on the proposed site
A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird
species are resident or common to the area Most diversity occurs in the thicket
although the coastal area also supports specialised avifauna Two species of tern
the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well
as the Cape gannet (Morus capensis) and the African penguin (Spheniscus
demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne
caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant
(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser
flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns
are two of the most endangered coastal species in South Africa Other bird species
of conservation concern include the Whitefronted plover (Charadrius marginatus)
African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus
bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus
ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides
paradisea) Breeding pairs of Damara terns and African black oyster catchers have
been observed in the coastal dunes of the IDZ but should not be affected by
developments that fall outside the dune areas
The Eastern Cape supports nearly a third (approximately 133 species) of the reptile
species recorded in South Africa More than half of the Eastern Capersquos endemic
reptile species occur in the Algoa Bay area giving the region a high conservation
value A total of 63 reptile species are believed to occur within the Coega IDZ The
majority of these are found in Succulent Thicket and riverine habitats Only a few
reptile species occur in the coastal dunes and estuarine habitats More than a third of
the species are described as relatively tolerant of disturbed environments provided
that migration corridors of suitable habitat are maintained to link pristine habitats
Twenty two reptiles are of special concern including five endemic species (two of
which may also be endangered) four endangered sea turtles eight species listed
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-7
with CITES one rare species and four species at the periphery of their range
Fourteen of these species of special concern are confirmed as occurring on or within
2 km of the Coega IDZ
A total of 32 amphibian species and sub-species occur in the Eastern Cape
representing almost a third of the species recorded in South Africa However none of
the species are endemic or Red Data Book species Based on previous studies in the
area it is estimated that approximately 17 amphibian species occur within the Coega
IDZ Four species are listed as peripheral but none are threatened internationally
These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog
(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and
the bubbling kassina (Kassina senegalensis)
The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated
vegetation has not been extensively studied One grasshopper species Acrotylos
hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue
(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis
pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in
four localities in the Eastern Cape one of which is within the Coega IDZ The Coega
copper Aloeides clarki is endemic to this particular region of the Eastern Cape and
is currently known to occur in three localities two of which are in the Coega IDZ The
localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the
Coega IDZ and their distributions were taken into account when defining Coegarsquos
open space system and Development Framework Plan
435 Land use and topography
The land is currently undeveloped and earmarked for industrial development The
site is relatively flat ranging from an elevation of 66 masl on the northern-most
corner to 59 masl at the southern-most corner
436 Heritage and archaeological survey
Extensive studies have been undertaken in Zone 6 with respect to heritage aspects
Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a
2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond
2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is
currently being finalised
Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing
Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha
in extent and was located next to the R102 road to Motherwell Kaplan conducted
HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi
Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will
now be located in Zone 5)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-8
The various archaeological investigations reached similar observations and
conclusions Stone tools of various densities and types were found throughout the
zone The majority of the stone tools were mainly of Earlier and Middle Stone Age
and occasional Later Stone Age origins (Figure 4)
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble
gravels exposed by tracks in Zone 6 (Source Binneman 2010)
The stone tools which comprised of quartzite flakes chunks flaked pebblecobble
and cores were randomly distributed across the landscape and are in secondary
context There were no lsquoconcentrationsrsquo of tools observed which suggested any
spatial patterning or activity areas although these may be present or covered by soil
and vegetation
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 5-1
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED
The following environmental issues and potential impacts were identified in the
Scoping phase
51 AIR QUALITY
The galvanizing process generates atmospheric emissions with particulates and
hydrogen chloride representing the main pollutants of concern The plant is fitted with
air extraction as well as scrubber systems which are designed to retain the bulk of
pollutants and particles for each of the processes in such a way that less than 5 ppm
of gases and particles will be released into the atmosphere after the fume scrubber
Other sources of impact on air quality include emissions from the LNG burner as well
as emissions and dust from the transport of steel and other materials in trucks
Construction activities will also create dust and gas emissions due to the clearing of
groundcover tipping of material to storage pile levelling of area wind erosion from
storage piles vehicle and construction equipment activity and tailpipe emissions
from vehicles and construction equipment such as graders scrapers and dozers
Overall the air quality impact assessment (Gruenewaldt 2011b) found that
The predicted particulate oxides of nitrogen carbon monoxide and sulphur
dioxide concentrations are all below the National Ambient Air Quality Standards
for all averaging periods
The predicted off-site concentrations of hydrogen chloride are well below the
most stringent effect screening levels
No odour threshold exceedances for hydrogen chloride were predicted to occur
due to routine operations at the Steel Galvanising Plant The South Wales
Environmental Protection Authority stipulates that an odour unit of 20 is
acceptable for urban areas The odour unit would be lt10 directly off-site for
hydrogen chloride
Abnormal emissions can occur in exceptional circumstances Start-up will not
cause abnormal emissions as the scrubbers will be commissioned first and will be
functioning once the plant starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions would be emitted as a
building fugitive
The hourly hydrogen chloride ground level concentrations (directly offsite) were
predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based
on the emission limits as stipulated for listed activities for galvanising processes)
using a screen model which assumes worst case meteorological conditions The
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-2
health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming
abnormal emissions emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset conditions will still
be well within the health effect screening levels
Similarly the hourly particulate emissions from the building fugitives during upset
conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for
listed activities for galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly
off-site
Therefore if emissions are 5 times higher normal they will still be within health effect
screening levels and the daily PM10 NAAQS levels
In the case of a fire a cocktail of gases and particulates could be emitted and could
be over the recommended levels This situation will however be dealt with as an
emergency and normalised as quickly as is possible
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS
The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of
its heritage potential and there are no proposed protected geosites in Zone 6
Should any artefacts be discovered during construction procedures stipulated in the
draft EMP will apply
53 BIODIVERSITY AND CONSERVATION
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
In terms of terrestrial fauna the CDCrsquos open space management plan provides for
the preservation of certain corridors The destruction of certain habitats as a result of
the development will therefore not automatically result in the loss of certain species
54 WATER QUALITY
There is a natural attenuation pond on the southern most part of the site which will be
avoided
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through
spills or leaks
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-3
This risk can however be minimized if not avoided altogether The floor of the factory
will be designed as a bunded area to contain any spills and the entire process will be
contained Potential spills or leaks will therefore be contained and will not impact on
water resources Storm water is therefore considered clean water under normal
operational conditions An oil trap will be placed at the exit of the site to ensure that
no grease from the laydown area enters the stormwater system
Spills and leaks can occur during the handling or the transport of hazardous
substances Best practice guidelines will be followed to ensure that this risk is
adequately managed
Wastewater discharged to sewer will be treated to comply with municipal discharge
standards and is not expected to have an impact on the chemical characteristics of
the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be
discharged from the plant is small in relation to the total volume received at the
Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works
(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently
operated at 61 of its capacity which is approximately 80 Mℓday Thus the
0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore
not have any significant impact on the WWTW
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES
The plant will generate a relatively small amount of solid waste in the form of scrap
metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)
The scrap metal may be sold to other steel processing facilities such as Agni Steel
which will be located next to the plant or collected and disposed of with the rest of
the solid waste by a licensed service provider
As mentioned previously there will be a wastewater treatment plant on site which will
neutralise process water (012 Mlweek) in order to ensure it is of a standard
acceptable for discharge to sewer Waste in the form of sludge from the
neutralization or spent acid must be disposed of as a hazardous waste Solid waste
from the filters used for air quality control is also in this category These wastes can
usually be tested and then delisted which means that it can be placed in a general
purpose landfill
Hazardous effluent from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-
site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored
and removed on a monthly basis is limited to 10 m3
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-4
A number of substances classified as hazardous are used in the galvanizing process
(Table 2) and the transport and handling of these is subject to certain rules and
guidelines In particular the material safety data sheets (cf Appendix H) should be
referred to for inter alia hazards identification accidental release measures
handling and storage precautions exposure controlpersonal protection ecological
information and transport information The Hazardous Chemical Substances
Regulations 1995 should also be adhered to in respect of the transport and storage
of hazardous chemical substances
Table 2 Hazardous materials to be used on site
Major Input Materials
Substance
listed in the
SABS 0228
Group II
hazardous
substances
Volumes to be
stored on site at
any one time
Diesel radic 2000 litres
Liquid petroleum radic 20 000 liters
Sodium hydroxide (NaOH)
(used for degreasing) 8 radic 1000m
3
Hydrochloric acid (HCI)
(used for pickling) 8 radic 800m
3
Zinc (used for galvanising) - TBD
Trivalent chromium (CR+3
)
(used for chromating) 8 radic 10m
3
Sulphuric acid (H2SO4) (used for
treatment of waste water on site) 8 radic TBD
Ammonium Hydroxide (NH4OH) 8 radic TBD
TBD ndash To be determined
Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one
time) and is classified as a flammable substance Specification for flammable storage
facilities in accordance with the requirements of the Nelson Mandela Bay
Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for
quantities between 5000 and 20 000 liters the substance must be kept in a
flammable liquid store which complies with the requirements of a specification
obtainable from the Department Some of the requirements are
Flammable liquid and solid storage facilities are only permitted on the ground
floor
Decanting of flammable liquids and solids are not permitted within any building
Due to the fact that there are flammable materials on site a certificate may be
required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and
Emergency Services Department to confirm that facilities for flammable storage
are in accordance with their requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-5
Because of the permanent installation and high quantity of liquid petroleum on site
the Major Hazard Installation Regulations 2001 promulgated under the Occupational
Health and Safety Act No 85 of 1993 applies A written application for approval of
the installation is required to be submitted to the chief inspector Department of
Labour provincial director Department of Labour and NMBM prior to construction
In addition a risk assessment should be formulated covering all hazardous materials
together with an emergency preparedness and response plan
56 HEALTH AND SAFETY
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling instructions as well as occupational exposure limits
are indicated in the material safety data sheets of the various substances used
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as
provide site supervision including executing tests (individual test cold run and hot
run) during 3 months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the
EMP
In addition the emergency preparedness and response plan will cover the health and
safety aspects related to emergency situations
57 TRAFFIC
The volumes of traffic at the IDZ are currently relatively low and variable depending
on the different zones in the IDZ however these volumes will increase as more
developments are implemented
The construction phase of the Casa Steel development will take about 12 months
and will essentially consist of erecting a building to house the galvanizing line and
other equipment and preparing a concrete laydown area adjacent to the building
The traffic that would be generated during the construction phase can be expected to
be less than the traffic that would be generated by the Casa Steel development when
it is fully operational
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-6
In the operation phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and
from the Port of Ngqura
The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the
Casa Steel development would be off Ring Road 1 The other roads of significance
for the Casa Steel development are the N2 Neptune Road MR435 and MR450
Access to the port is given by Neptune Road Road Link NEP-03 has not yet been
built
Figure 8 Coega IDZ road network identification
(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-7
Figure 9 Coega IDZ road network
Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No
01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-8
The distribution of freight trips is fixed as the majority of trips will be made between
the Port of Ngqura and the Casa Steel site With regard to personnel trips there are
various points of origins (the surrounding residential areas) that could be used by
staff going to the Casa Steel site The distribution of personnel trips is based on
existing traffic count information and is shown in Figure 10
Figure 10 Trip distribution for freight and personnel trips
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The resultant expected Casa Steel traffic assignment is shown in Figure 11
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-9
Figure 11 Morning peak hour Casa Steel development traffic
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The traffic that is expected to be generated by the Casa Steel development is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low
and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)
Consultation has taken place with Transnet Port Authority (TPA) to establish the
impact of the galvanizing plant operations on traffic inside the port The additional
ships entering and exiting the port of Ngqura as a result of the proposed development
will have a negligible impact on port traffic and TPA indicated that it would be well
within the portrsquos capacity
58 NOISE
Noise is not foreseen to be a significant issue insofar as the noise levels inside the
plant and at the boundary of the site will not exceed the limits prescribed by the CDC
Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels
during the day and 60 decibels at night
Mitigation of noise impacts will be addressed in the design of the noise-emitting
components of the plant and their enclosures
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-10
59 SOCIO-ECONOMIC ASPECTS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of
NMBM There are no residents within the IDZ
The direct socio-economic impacts of the proposed project are thus limited to the
employment generated by the project during construction and operation Job creation
remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)
and the IDZ and Port of Ngqura are expected to become a significant catalyst to the
economic growth of the Municipality and the region with current investments at
Coega creating more jobs and stimulating the economy
In this context the proposed galvanizing plant will make a positive contribution
towards the achievement of these goals
There will be 50 to 60 employees during operation phase distributed as follows
Figure 12 Casa Steel organisation chart
Even though a large part of the inputs will be imported and the bulk of the production
output will be exported there will be some positive impacts for the economy of the
region and of South Africa in general Notably the requirements of the plant for
water electricity waste collection and disposal waste water treatment and transport
for example will create business for the various service providers and have an
indirect impact on employment and fiscal revenues as a result
From a visual impact point of view it can be anticipated that the landscape in the IDZ
will be significantly affected over time by developments related to the establishment
of the port and various industries
HEAD ( WORKS )
MGR ( COMM) MGR ( ADMNHR ) Manager marketing
MANAGER OPERATION MANAGER MANAGER MANAGER Q C
AC FIN PUR ampSTORE
PPC SH-GALV SH-tech
SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF
1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO
JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF
2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO
WORKERS WORKERS 7NOS
15 7
RAW MAT amp
DESP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 6-1
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
A description of the nature of the impact any specific legal requirements and the
stage (constructiondecommissioning or operation) will be given Impacts are
considered to be the same during construction and decommissioning The
significance of the potential impacts will be considered before and after identified
mitigation is implemented
The following criteria will be used to evaluate significance
Nature The nature of the impact will be classified as positive or negative and
direct or indirect
Extent and location Magnitude of the impact and is classified as
Local the impacted area is only at the site ndash the actual extent of the activity
Regional the impacted area extends to the surrounding immediate and
neighbouring properties
National the impact can be considered to be of national importance
Duration This measures the lifetime of the impact and is classified as
o Short term the impact will be for 0 ndash 3 years or only last for the period of
construction
o Medium term three to ten years
o Long term longer than 10 years or the impact will continue for the entire
operational lifetime of the project
o Permanent this applies to the impact that will remain after the operational
lifetime of the project
Intensity This is the degree to which the project affects or changes the
environment and is classified as
o Low the change is slight and often not noticeable and the natural functioning
of the environment is not affected
o Medium The environment is remarkably altered but still functions in a
modified way
o High Functioning of the affected environment is disturbed and can cease
Probability This is the likelihood or the chances that the impact will occur and
is classified as
o Low during the normal operation of the project no impacts are expected
o Medium the impact is likely to occur if extra care is not taken to mitigate
them
o High the environment will be affected irrespectively in some cases such
impact can be reduced
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 6-2
Confidence This is the level knowledgeinformation the environmental impact
practitioner or a specialist had in hisher judgement and is rated as
o Low the judgement is based on intuition and not on knowledge or
information
o Medium common sense and general knowledge informs the decision
o High Scientific and or proven information has been used to give such a
judgment
Significance Based on the above criteria the significance of issues will be
determined This is the importance of the impact in terms of physical extent and
time scale and is rated as
o Low the impacts are less important
o Medium the impacts are important and require attention mitigation is
required to reduce the negative impacts
o High the impacts are of great importance Mitigation is therefore crucial
Cumulative Impacts The possible cumulative impacts will also be considered
Mitigation Mitigation for significant issues is incorporated into the EMP for
construction
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 7-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS
71 IMPACTS DURING CONSTRUCTION
711 Air quality
Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris
handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine
particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural
operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks
and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)
Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Fugitive particulate emissions (dust)
related to construction activities Regional
Short
term Medium High High Medium Regional
Short
term Low High High Low
Construction vehicle gas emissions Regional Short
term Medium High High Medium Regional
Short
term Low High High Low
712 Heritage and archaeological resources
Naturedescription of impact excavation activities may impact on unidentified heritage resources
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-2
Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based
on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments
Heritage and archaeological
resources Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on unidentified heritage
resources Local
Short
term
Medium -
high Low High Low
713 Biodiversity and conservation
Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation
importance and cause soil contamination
Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species
Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan
and has compiled a list of protected species to be rescued (see draft EMP)
Biodiversity and conservation Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Loss of fauna and flora Local Perma
nent
Medium -
high High High High Local
Permanen
t Medium High High Medium
Soil contamination Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-3
714 Water related impacts
Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater
runoff spills and leaks Soil erosion
Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of
spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste
disposal Stormwater quality monitoring (see draft EMP)
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Soil erosion Local Short
term Medium Medium High Medium Local
Short
term Medium Low High Low
715 Waste management
Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed
Commentmitigation see draft EMP and waste management plan
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-4
Waste management Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Local
Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
716 Health and safety
Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Short
term
Medium -
high
Medium -
high High High Local
Short
term
Medium -
high Low High Low
717 Traffic
Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and
construction workers from surrounding areas and transport of equipment from the port
Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low
Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and
accurate estimates of quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-5
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Increased traffic on N2 and within the
IDZ Regional
Short
term Low High High Low
718 Noise
Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Short
term
Medium-
high High High Medium Local
Short
term Medium High High Medium
719 Socio-economic
Naturedescription of impact temporary employment will be created during the construction phase
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-6
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Temporary employment Regional Short
term Medium High High Medium
72 IMPACTS DURING OPERATION
721 Air quality
NatureDescription of impact gas and particulate emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning
Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local
sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and
veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute
to background fine particulate concentrations (von Gruenewaldt 2011b)
Assumptions and limitations Potential release of CR6+
As no emission factors are available for trivalent chromium processing the
potential impacts due to these activities could not be quantified
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Dust emitted from traffic on paved roads Regional Long Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-7
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
term
Hydrogen chloride emissions from
pickling process Local
Long
term Low High High Low
Particulate emissions (smoke) from
galvanizing process (due to the
volatilization of flux)
Local Long
term Low High High Low
Particulate oxides of nitrogen carbon
monoxide and sulphur dioxide emissions
from LNG burner
Local Long
term Low High High Low
Nuisance related to odour Local Long
term Low Low High Low
Abnormally high hydrogen chloride and
particulate emissions due to scrubber
malfunction
Local Short
term Medium Low High Medium
Gases (eg SOx NOx CO etc) and
smoke emitted in case of a fire Local
Short
term High Low High Medium
722 Water quality
NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks
Commentmitigation see draft EMP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-8
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Stormwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
723 Waste management and hazardous substances
NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous
waste both can affect environmental quality and human health
Commentmitigation see draft EMP and waste management plan
Waste management and hazardous
substances Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Regional
Long
term High
Medium -
high High High Regional Long term High Low High Low
Soilwaterair pollution due to improper
transport storage and handling of
hazardous substances
Regional Long
term High
Medium -
high High High Regional Long term High Low High Low
Health hazard Local Long
term High
Medium -
high High High Local Long term High Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-9
724 Health and safety
Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Long
term
Medium-
high
Medium-
high High High Local Long term
Medium-
high Low High Low
725 Traffic
Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on
the road network
Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak
hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road
network within Zone 6 of the IDZ (Iliso 2011)
Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)
Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of
quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-10
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on traffic and capacity of the N2 Regional Long
term Low High High Low
Impact on traffic and capacity of ring
road 1 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR435 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR450 Local
Long
term Low High High Low
Impact on traffic and capacity of
Neptune road Local
Long
term Low High High Low
726 Noise
Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Long
term Medium High High Medium Local Long term Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-11
727 Socio-economic
Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate
revenue for the municipality and the region as a whole
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Employment and economic growth Regional Short
term Medium High High Medium
73 COMPARATIVE ASSESSMENT OF IMPACTS
During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as
low during operation after mitigation
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 8-1
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
As a tenant operating in the IDZ Casa Steel will be required to comply with all
current and future CDC requirements as well as with the relevant conditions of
permits licences issued to CDC (eg Integrated Stormwater Masterplan for the
eastern side of the Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)
In particular the CDC has its own requirements regarding the monitoring of certain
aspects of the project such as the quality of the effluent and the noise levels These
have been incorporated into the EMP
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 9-1
9 ENVIRONMENTAL IMPACT STATEMENT
All predicted negative impacts can be mitigated to a low significance The only
exceptions are biodiversity as the construction of the plant will result in the
destruction of habitat and loss of fauna and flora and noise impacts inherent to
construction activities Mitigation measures have been included in the EMP for these
impacts and they have a medium significance post-mitigation
Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium to
long term similar impacts are likely to occur due to ongoing developments in the IDZ
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 10-1
10 CONCLUSION AND RECOMMENDATIONS
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as
other infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified
and assessed No fatal flaws have been identified
It is recommended that the project be approved subject to the conditions listed in
chapter 9 and adherence to the EMP requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 11-1
11 REFERENCES
Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ
Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants
Bennie JS (2010) The historical component (built environment) of the Heritage
Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port
Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report
compiled for Eastern Cape Heritage Consultants
Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater
Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay
Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage
Consultants
BKS (2006) Coega Industrial Development Zone Transport Study Volume 3
Demand Modelling Report Final Draft
Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I
Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6
Report compiled for SRK Consulting
Coastal amp Environmental Services (2010) Environmental Impact Assessment for the
Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone
Volume 3 Environmental Impact Assessment Report CES Grahamstown
Coega Development Corporation (2008) Industry Waste Management Plan -
Strategic Master Plan Report
Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants
Report No CDCSHE 03 8122
Department of Water Affairs and Forestry (1998) Waste Management Series
ldquoMinimum Requirements For The Handling Classification And Disposal Of
Hazardous Wasterdquo Second Edition
Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising
Plant in the Coega Industrial Development Zone
Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the
Coega Industrial Development Zone (IDZ) Specialist Water Study
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 11-2
Jacobs E (2008) Final Environmental Impact Report and Draft Environmental
Management Plan Proposed Steel Recycling and Processing Facility within the
Coega IDZ Report compiled for SRK Consulting
Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY
Galvanising Plant in the Coega Industrial Development Zone Waste Management
and Hazardous Substances Report compiled for ILISO Consulting
RSA National air quality standard for thoracic particulates (PM10) SA standards
(Government Gazette No 32816)
von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed
Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape
Report compiled for ILISO Consulting
von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel
Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report
compiled for ILISO Consulting
Additional sources
Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed
Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared
for Coastal Environmental Services
Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed
Kalagadi Manganese smelter in the Coega Industrial Development Zone Port
Elizabeth Eastern Cape Province Report prepared for Coastal Environmental
Services
Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia
steel recycling facility at the Coega Industrial Development Area Port Elizabeth
Prepared for SRK Consulting Port Elizabeth
APPENDIX A
LIST OF INTERESTED AND
AFFECTED PARTIES
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
DEDEARegional Manager
and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza
DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza
DEA Ocean and
CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza
DEA Ocean and
Coast
Oceanographer land-
based sources of
marine pollution
Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza
DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza
CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza
CDCEnvironmental
Project
Manager
Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza
TNPAPort of Ngqura
Environmental
Manager
Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet
NMBMEnvironmental
ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza
NMBMEnvironmental
ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza
DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza
DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza
WESSASenior Conservation
Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza
Zwartkops
ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700
hughlauegmailcom
zwartkopstrustiafricacom
SANParksNational Marine
CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza
Department Of
LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza
NMBM Air Quality
Division
Assistant
DirectorAir
Pollution and Noise
Templeton Titima 079 490 0574 Ttitimamandelametrogovza
NMBM Air Quality
DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza
NUMSARegional
RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
Department of
HealthNadiema
van der
Bergh083 378 2103
nadiemavanderberghimpiloecprovgov
za
DWA Chief Services
Officer
Joseph Jacobs 041 586 4884 jjacobsdwafgovza
EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza
NUMSecretary of union
officesZandile Xhentsa 043 743 6597 zxhentsanumorgza
DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza
Dynamic
CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom
EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza
Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza
UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom
lprincezago2uticom
Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza
Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza
Absa Mr Johann Steyn 082 3775820 johannstabsacoza
Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza
PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza
Universal
EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza
Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza
GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom
Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza
NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom
DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza
DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza
TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet
DWA Mr Landile Jack JackLdwagovza
DWA Ms Lizna Fourie FourieL4dwagovza
APPENDIX B
NOTICE OF ATMOSPHERIC
EMISSIONS LICENCE APPLICATION
AND ADVERTISEMENT
APPENDIX C
NOTICE OF COMMENT PERIOD FOR
DRAFT SCOPING REPORT
APPENDIX D
SUMMARY OF ISSUES RAISED AND
RESPONSES THERETO
April 2012
1
PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL
DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))
IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt
AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt
This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses
provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process
conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the
Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
2
IssueCommentQuestion Date
received Origin Response
1 Please provide more information with respect to the potential
dangers including the toxicity of the proposed project
07032011
By email
Wayne Poulton
(Bosun Brick
tenant at the
IDZ)
An Environmental Impact Assessment (EIA) was undertaken
which assessed the potential toxicity of the emissions and
effluent Mitigation measures were also recommended in the draft
Environmental Management Programme (EMP) to avoid
minimise or compensate any significant impacts The Draft
Environmental Impact Report and draft EMP were made available
to stakeholders for comment in March 2012
2 Do you have a Background Information Document (BID) or
similar that provides more information on the project
27032011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The BID was sent to all registered IampAPs on 4 May 2011
3 The RoD issued to the CDC on 632007 for the change in
land use for the remaining area of the Coega IDZ includes a
number of requirements with respect to
atmospheric emissions that should be considered in the
Atmospheric Emissions Licence (AEL) application such as
prohibiting and monitoring where possible visible emission
plumes to the atmosphere In particular the
recommendations on pp87-91 of the final revised Scoping
Report dated Nov 2006 must be implemented (clause 421)
04042011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
We have obtained copies of the documents referred to and ensure
that these requirements were taken into account in the
environmental assessment and AEL application
4 If the Port of Ngqura is used for import and export the scope
of the traffic impact assessment (TIA) should also include the
port
10052011
By email
Elliot
Motsoahole
(TNPA Port of
Ngqura)
The scope of the TIA was extended to include port related traffic
The TNPA at the Port of Ngqura was consulted and does not
have any objection to the project TNPA has indicated that the
development would require a minimum number of vessels per
year which would have minimal impact on the Port operations
However due notice would have to be given to the Port of Ngqura
before a vessel is scheduled to arrive so that the vessel can be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
3
IssueCommentQuestion Date
received Origin Response
accommodated at an available berth
5 Concerns with respect to potential stormwater pollution
draining into the Coega catchment and the port of Ngqura
The port needs to be dredged and heavy metals present a
risk in that regard
16052011
By
telephone
Andrew Lucas
(Department of
Water Affairs)
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination by effluent waste or
hazardousdangerous substances is very low
Thus no metals oils or other contaminants are expected to be
present in the stormwater
However stormwater pollution can occur in exceptional
circumstances such as accidents and emergencies The
emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
6 All steel sheets bathing unit must be under roof
7 The sludge out of the decreasing bath will be high in Na and
pH Therefore handling and disposal must be clarified up front
in this project
8 Per se the wastewater from decreasing bath will have high
ph and the component from the pickling unit will have low ph
Then it may be assumed that both streams will neutralize
each other Please then clarify proposed sewer discharge
with Nelson Mandela Bay Municipality up-front for acceptance
of influent as per the documented proposal
9 Pickling may result in dissolved metals How does your team
expect to deal with this As it is planned for discharge into
24052011
By email
Landile Jack
(Department of
Water Affairs)
All bathing units will be under roof
Effluent from the degreasing and pickling baths will be discharged
to the wastewater treatment plant The respectively alkaline and
acidic effluents will mix and neutralise each other in the
wastewater treatment plant Calcium or gypsum will be added if
required to complete the neutralisation process Effluent from the
treatment plant will be discharged to sewer Contact has been
made with the relevant officials and the Municipalityrsquos
requirements have been obtained The effluent discharged to
sewer will notably comply with the applicable discharge standards
Traces of metals (eg iron) may be present but will not exceed
prescribed thresholds The necessary authorisation will be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
4
IssueCommentQuestion Date
received Origin Response
sewer Clarity and acceptance needs to be agreed with
Nelson Mandela Bay Municipality Who owns the sewer
10 Quenching unit will results to Zinc particles How will this
affect sewer discharge This again must be dealt with within
the negotiations with the Municipality
11 Once all has been agreed with the Municipality and at the
same time due negotiations must be done with hazardous
waste courier and disposal facility to accept the hazardous
waste identified in all production lines
12 Of note is the low volume of the proposed WWTW facility ie
250 cubmweek And the no discharge of the quenching
water ie over-flow and cooling only Hence Zinc particles
generation
obtained from the municipality
The sludge from the treatment plant will be collected by a licensed
service provider and disposed of at a permitted site
The quenching bath will be periodically emptied (every 6 months)
and the water discharged will go to the water treatment plant Zinc
particles will settle in the sludge which will be disposed of at a
permitted site
Contact has been made with EnviroServ who manages the
Aloes II HH waste site regarding collection and disposal of
hazardous waste (See waste management report)
13 Investigate the potential effects of toxicity andor influence of
emissions waste and hazardous substances both in
terrestrial and marine fauna
14 With regards to water usage where is the plant going to
extract its waters used in galvanization andor waste
management process ie rainfall rivers or even from the
sea) and which avenues would be more environmental
friendly and effective
31052011
By email
A Bewana
(SANPARKS)
Emissions waste and hazardous substances are not expected to
affect terrestrial or marine ecosystems The air quality study
concluded that atmospheric emissions would not be harmful to
human health and by extension terrestrial fauna There are no
standards for air quality for defining faunal impacts therefore by
ensuring that standards for humans are complied with the impact
on fauna is deemed to be acceptable In this case the impact of
emissions on terrestrial and marine fauna are thus not significant
Solid and liquid wastes both general and hazardous as well as
hazardous substances will be stored handled and disposed of
appropriately to as not to cause harm to terrestrial or marine
fauna
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
5
IssueCommentQuestion Date
received Origin Response
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination and hence land-based
marine pollution by effluent waste or hazardousdangerous
substances is very low
The risk of emissions waste and hazardous substances to
terrestrial and marine fauna is thus very low
However pollution of terrestrial and marine ecosystems can occur
in exceptional circumstances such as accidents and emergencies
The emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
The CDC has an agreement with the NMBM to supply potable
water to the Coega IDZ Currently the infrastructure to supply
return effluent (RE) to the IDZ is not in place therefore Casa Steel
will be supplied with potable water up until such time as the
following 2 options of RE are available
1) Upgrading of the existing Fishwater Flats waste water
treatment works (between IDZ amp PE) including RE plant
and infrastructure to pipe RE to the IDZ (EIA for the
upgrade is underway)
2) Construction of a new waste water treatment works
including RE plant in Zone 9 of the Coega IDZ
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option should be investigated further between Agni and Casa The
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
6
IssueCommentQuestion Date
received Origin Response
CDC can facilitate discussions between the 2 investors
Compliance with CDC Permits amp Requirements
15 It should be made clear that tenants will be required to
comply with CDC requirements and the relevant conditions of
permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water
Licence for its Storm Water Systems on the
East Side of the Coega River that tenants will
need to take cognizance of The contents of the
ldquoIntegrated Stormwater Masterplan for the
eastern side of the Coega IDZ Oct 2010rdquo
especially the Table of best practice p53
onwards may need to be taken cognizance of
o CDC is developing an Operations
Environmental Management Plan that will place
certain obligations on tenants
16 Environmental audits and data collected during monitoring
(eg stack emissions stormwater) will need to be shared with
CDC
Air Emissions
17 Presumably permanent in stack monitoring will be required in
terms of AEL permit requirements
18 Abnormal operating conditions resulting in air emissions ndash I
could find nothing in the EIR to indicate under what
circumstances these could occur (eg start-up) potential
frequency and duration and the impact on ambient air quality
ndash these events usually result in the most problems wrt air
emissions
09042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
15 Compliance with the CDCrsquos Permits amp Requirements has
been included explicitly as a requirement in the EIR (p8-1) and
EMP (pp18 and 25) in the following terms
ldquoAs a tenant operating in the IDZ Casa Steel will be required to
comply with all current and future CDC requirements as well as
with the relevant conditions of permits licences issued to CDC
(eg Integrated Stormwater Masterplan for the eastern side of the
Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)rdquo
16 The need to communicate with the CDC on monitoring and
auditing activities was emphasised in Chapter 8 of the EMP The
following paragraphs were added
ldquoDuring construction the environmental officer will be responsible
for monitoring compliance with the EMP and authorisation
conditions and keeping records as required in the EMP andor
authorisation conditions
The ECO will conduct site inspections every two weeks audit the
records kept by the environmental officer and submit an
environmental compliance report every two months to the
authorities and the CDC (via the Environmental Monitoring
Committeersquos ECO)
During operation the health and safety officer will monitor
compliance with the EMP and the conditions of the Environmental
Authorisation Data collected during monitoring activities and any
environmental audits conducted will be shared with authorities
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
7
IssueCommentQuestion Date
received Origin Response
Water
19 Large volumes of (2000 m3mth) of water are required of
which only 400m3 needs to be potable The NMBM return
effluent system will provide non-potable water once it is
constructed What other water recycling initiatives can be
utilized to reduce potable water requirements (the ISWMP for
the eastern side of the Coega IDZ has some best practice
guidelines collecting rainwater from the roof etc)
General
20 There is no mention of how the CDC Architectural Guidelines
will be incorporated into the development (eg to prevent a
stark uniform warehouse type development)
21 Does NMBM have adequate fire services to cover this
development Apart from the large petroleum store are there
any other large fire hazards
22 Reports from the tenantrsquos ECO during construction and from
the SHE Officer during operations should be channeled to the
Coega Environmental Monitoring Committee This can be
directly or preferably via the EMCrsquos ECO (this will be while
the EMC and ECO are in place) A precedent has been set
for this in the Environmental Authorisations for Agni-Steel and
Kalagadi Manganese Smelter
23 All mitigation actions emanating from the EIR should be
summarized (preferably in a table) If compliance with them is
to be part of the Environmental Authorization from DEDEAT
then they (or the ones that DEDEAT deems to be applicable)
and the CDC (via the Environmental Monitoring Committeersquos
ECO)
The ECO (during construction) and the health and safety officer
(during operation) will report to the Coega Environmental
Monitoring Committee (EMC) via the EMCrsquos ECO (this will be
while the EMC and ECO are in place)rdquo
17 The draft EMP recommends regular monitoring of emissions
from the scrubbers and from the chromating process Additional
emissions monitoring requirements will be confirmed once the
AEL is issued Mention has been made in the EMP (pp11 and 19)
that all AEL conditions including monitoring and reporting
requirements should be adhered to
18 Abnormal emissions can occur in exceptional circumstances
Start-up will not cause abnormal emissions as the scrubbers
will be commissioned first and will be functioning once the plant
starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions
would be emitted as a building fugitive
The hourly hydrogen chloride ground level concentrations
(directly offsite) were predicted to be 239 microgmsup3 (based on the
emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits
as stipulated for listed activities for galvanising processes) using a
screen model which assumes worst case meteorological
conditions The health effect screening level for hourly HCl
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
8
IssueCommentQuestion Date
received Origin Response
should be attached to the EA as an Appendix (otherwise no
one knows about them or takes cognizance of them)
concentrations is 2100 microgmsup3 Assuming abnormal emissions
emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset
conditions will still be well within the health effect screening
levels
Similarly the hourly particulate emissions from the building
fugitives during upset conditions would amount to 293 microgmsup3
(based on the emission limits as stipulated for listed activities for
galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1
January 2015) directly off-site
Therefore if emissions are 5 times higher normal they will still be
within health effect screening levels and the daily PM10 NAAQS
levels
In the case of a fire a cocktail of gases and particulates could be
emitted and could be over the recommended levels This
situation will however be dealt with as an emergency and
normalised as quickly as is possible
The above has been added to the impact identificationdescription
and assessment sections of the EIR
19 The CDC has an agreement with the NMBM to supply
potable water to the Coega IDZ Currently the infrastructure to
supply return effluent to the IDZ is not in place therefore Casa
Steel will be supplied with potable water up until such time as the
infrastructure is in place
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
9
IssueCommentQuestion Date
received Origin Response
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option will be investigated further between Agni and Casa The
CDC has come forward to facilitate discussions between the two
investors
Other water recycling initiatives such as rainwater harvesting
have been considered but are not practical
20 The CDCrsquos Architectural and Landscape Design guidelines
contain requirements pertaining to such aspects as the height
orientation and mass and form of buildings as well as guidelines
for landscaping and signage in order to ensure an attractive
development and achieve an architectural integrity within the
Coega IDZ The plans for the proposed galvanizing plant will be
submitted to the Design Review Committee for approval as
required by the CDC
21 Casa Steel will be required to install fire hydrants according
to the NMBMrsquos standardsrequirements The CDC will provide
potable water (up until such time as return effluent is available)
and a connection to the boundary of the site which will be
connected to the fire hydrants The installation of the fire hydrants
will require approval by the Metrorsquos Fire Chief as was done for
Agni-Steel one of the investors in Zone 6
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
10
IssueCommentQuestion Date
received Origin Response
The Coega IDZ falls within the NMBM and therefore the rates and
taxes paid by the CDC covers the fire services for which the Metro
is responsible Currently the Metro has sufficient capacity to
provide fire services to the tenants within the IDZ This was
confirmed in discussion with the CDCrsquos Infrastructure
Development Unit It is however unknown at which point the
Metrorsquos Disaster Management Plan would not be able to
accommodate servicing tenants in the IDZ
The LNG burner is the only major fire hazard on the plant
22 See response to item 16 above
23 Key mitigation and management measures emanating from
the EIR were recapitulated in Chapter 9 of the EIR to form part of
the conditions attached to the Environmental Authorization from
DEDEAT All mitigation measures recommended as a result of the
impact assessment are presented in a table in the draft EMP
which is appended to the EIR (Appendix J)
24 Hydrogen chloride is one of the main emissions There are no
ambient air quality guidelines for HCl and the EIR says
concentrations will be well within health parameters
However the main problem with HCl is its corrosive effect -
there is absolutely no mention of this in the draft EIR nor air
specialist report
There needs to be some sort of comment assessment as to
whether HCl emissions are likely to impact on for example
the adjacent Agni-Steel Plant wrt corrosion - their factory
structure will be made of steel
11042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The atmospheric corrosion of metals is a complex process with
both the extent of deterioration and the mechanisms varying
considerably depending on the metal Depending on the way
pollutants are transported from the atmosphere to the corroding
surface two types of deposition processes are recognized in
atmospheric corrosion ndash dry deposition and wet deposition Wet
deposition refers to precipitation whereas dry deposition refers to
the remaining processes including gas phase deposition and
particle deposition The most important pollutants acting as
corrosive agents are sulphur and nitrogen compounds including
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
11
IssueCommentQuestion Date
received Origin Response
The EIR specialist rpt suggests monitoring HCl at ground
level on the property boundary and this is supported in case
there are complaints from neighbours
secondary pollutants and particulates Pollutants can contribute to
corrosivity individually however there may be a synergistic effect
when more than one of these pollutants is present in the
environment being affected In the field of atmospheric corrosion
sulphur dioxide is the single most investigated gaseous pollutant
and the quantification of the direct contribution of sulphur dioxide
to the corrosion process of metallic materials is comparatively well
understood (Tidblad amp Kucera 1998)
Very little work has reported on the effect of HCl on the
degradation of materials in the environment with no local dose-
response thresholds developed for corrosion occurring due to HCl
exposures This is probably because HCl which is present
outdoors in markedly reduced concentrations when compared
with SO2 has not been considered to contribute to significant
degradation of materials (Syed 2006) For this reason the
incremental corrosion due to HCl from the Coega Galvanising
Plant cannot be quantified
25 It is unacceptable for ILISO to be using CDC maps (see
figure 9 ndash pg5-6) without these maps being referenced
accordingly particularly when it appears that a CDC map has
been used and then overlaid with features by an unknown
author (ie CASA steel site Port (where the boundaries
depicted are incorrect) and a North legend which is out of
keeping with the overall cartographic intent of the original
work
26 Figure 10 is not referenced appropriately and I believe that I
commented previously in respect to references to roads not
12042012
By email
Graham Taylor
(Spatial
Development
Manager -
Infrastructure
Development
CDC)
This has been rectified in the final version of the report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
12
IssueCommentQuestion Date
received Origin Response
yet built As a result Figure 10 is confusing and clarity needs
to be provided in terms of referencing In addition the Port
shape is irregular and similar to the comment above
27 I acknowledge the emergency preparedness and response
plan but please confirm that this includes pro-active routine
monitoring of storm water leaving your premises to verify that
your assumptions of clean storm water are correct
13042012
By post
Andrew Lucas
(Director
WRampU
Department of
Water Affairs)
Pro-active routine monitoring of stormwater leaving the premises
will be undertaken This has been explicitly emphasised in
chapter 8 of the draft EMP
28 Will portablechemical toilets be used during construction
29 What provisions have been made for storm water drainage
during construction
18042012
By
telephone
Department of
Water Affairs
Port Elizabeth
Chemical toilets will be used during construction
The Casa Steel site will be located at the corner of two roads
drainage of stormwater from the site will take place through the
roadsrsquo drainage system
From Lea September [mailtoleailisocom]
Sent 11 March 2011 0935 AM
To Wayne Poulton
Cc Terry Baker
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Wayne
An Environmental Impact Assessment (EIA) will be undertaken for this project during the
next 10 to 12 months
We foresee that some of the key environmental impacts of the project will be in terms of air
quality water quality waste and hazardous substances
At this stage I am not able to give you any details regarding the potential toxicity of the
emissions andor effluent However specialist studies will be conducted as part of the EIA
that will determine the key impacts of the project Mitigation measures will also be identified
to avoid minimise or compensate any significant impacts
You are registered on the stakeholder database and you will be kept informed of progress in
the EIA process you will notably get the opportunity to access the reports produced and
provide any feedback on them
Please feel free to contact me should you need any further information
Best regards
Lea September
From Wayne Poulton [mailtowaynepbosuncoza]
Sent 07 March 2011 1257 PM
To Lea September
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
Please can you provide me with some more information as to the potential dangers including
the toxicity of this
Kind regards
Wayne
From Lea September [mailtoleailisocom]
Sent 04 March 2011 1123
To Lea September
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 March 2011 0745 AM
To Paul Martin
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 05 April 2011 0847 AM
To Paul Martin
Cc Terry Baker Renee von Gruenewaldt
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Thank you Paul for this information
I have downloaded a copy of the RoD and Scoping report you referred to and will make sure
these requirements are taken into account in the environmental assessment
Best regards
Lea September
From Paul Martin [mailtopmartinaxxesscoza]
Sent 04 April 2011 0955 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Further to my comments on 27311
Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in
the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega
IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised
scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions
including prohibiting and monitoring where possible visible emission plumes to the atmosphere
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Paul Martin
Sent Monday March 28 2011 745 AM
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 10 May 2011 0327 PM
To ElliotMotsoaholetransnetnet
Cc Terry Baker
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Mr Motsoahole
Thank you for your input on this issue
The Port of Ngqura will indeed be used for import and export At the moment the scope of
the traffic impact assessment only covers road traffic I have however relayed the matter to
our traffic specialist and we will consider this issue in the finalization of the Scoping Report I
will keep you informed of any developments in that regard
I trust this is acceptable to you
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]
Sent 10 May 2011 0855 AM
To Lea September
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
It has been noted that Casa Steel will source steel coils from various markets internationally and
in South Africa and the bulk of the plantrsquos production output will be exported to African countries
However there is no mention of logistic requirements
Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will
be used the scope of traffic impact assessment should also include the port
Regards
From Lea September [mailtoleailisocom]
Sent 04 May 2011 0747 AM
To Lea September
Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
Please find attached a letter announcing the EIA process underway for the proposed 80 000
tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as
a Background Information Document (BID) outlining the details of the project
Please contact me should you require any further information on this project
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
Elliot Motsoahole
Manager - Environment
Transnet National Ports Authority
Port of Nqqura
Port Control Building Klub Road Port Elizabeth 6212
PO Box 612054 Bluewater Bay 6212
+27 41 507 8450
+27 86 674 7729
Cell +27 83 542 5619
E-mail Elliotmotsoaholetransnetnet
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
DISCLAIMER The information contained in this communication is subject to copyright and
intended only for the use of leailisocom Unauthorised use disclosure or copying is
strictly prohibited Should a virus infection occur as a result of this communication the sender
will not be liable If you have received this communication in error please notify
elliotmotsoaholetransnetnet
From Lea September [mailtoleailisocom]
Sent 25 May 2011 1147 AM
To Jack Landile (ELS)
Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi
Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Landile
Thank you for your input
Contact has been made with the relevant Municipal Directorate and we will follow up with
them to obtain clarifications on all these issues
I have added both Lizna and yourself on the database and will keep you updated on
progress on this project
Best regards
Lea September
From Jack Landile (ELS) [mailtoJackLdwagovza]
Sent 24 May 2011 0524 PM
To Fourie Lizna (ELS)
Cc Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Hi Lizna
I missed you on this sorry
I linked Pieter twice Instead
Regards
Landile
From Jack Landile (ELS)
Sent 24 May 2011 0445 PM
To leailisocom
Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Lea
The e-mail you sent to Mr Kooverji dated 19 May 2011 refer
Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are
All steel sheets bathing unit must be under roof
The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project
Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal
Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer
Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality
Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines
Of note is the low volume of the proposed WWTW facility ie 250 cubmweek
And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles
generation
Regards
Landile
From Lea September [mailtoleailisocom]
Sent 19 May 2011 0947 AM
To Lea September
Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Stakeholder
Please find attached the remaining appendices to the draft Scoping report for the proposed
80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 June 2011 0411 PM
To Aphiwe Bewana
Subject RE Proposed 80 000 TPY Galvanizing plant in Coega
Dear Mr Bewana
Thank you for your input and apologies for the late reply
We have taken note of your comments and are will be taking them forward in the EIA phase
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Aphiwe Bewana [mailtoaphiwebewanagmailcom]
Sent 31 May 2011 1205 PM
To Lea September
Subject Re Proposed 80 000 TPY Galvanizing plant in Coega
Comment
Re Proposed 80 000 TPY Galvanizing plant in Coega
As SANParks we would like the EIA phase to investigate the potential effects of toxicity
andor influence of emissions waste and hazardous substances both in terrestrial and
marine fauna In the draft scoping report reference has been made with regards to the
terrestrial fauna but there is no attention to potential effects to marine fauna
Equally with regards to water usage where is the plant going to extract its waters used in
galvanization andor waste management process ie rainfall rivers or even from the sea)
and which avenues would be more environmental friendly and effective
Regards
Aphiwe Bewana
Marine Planner
South African National Parks
POBox 76693
NMMU
Port Elizabeth
6031
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 06 July 2011 1031 AM
To Lea September
Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Hi Lea
Irsquove reviewed the Final Scoping Report Herewith a few comments
1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the
Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a
revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the
NMBLP Please include only those in the IDZ as part of your IAP list
Regards
Andrea
From Lea September [mailtoleailisocom]
Sent Wednesday July 06 2011 859 AM
To Lea Septemberrsquo
Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Dear Stakeholder
The final scoping report for the above-mentioned project (attached) is available for comment
until 27 July 2011
The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic
commentaryrdquo tab
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 09 April 2012 1159 AM
To Lea September
Subject Comments on Galvanising Plant EIR Coega IDZ
Lea
Attached are my comments on the Draft EIR for the Coega IDZ galvanising
plant
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
Email attachment
COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ
Dr Paul Martin PO Box 61029
Bluewater Bay 6212 Tel 041 4665698
Email pmartinaxxesscoza
Compliance with CDC Permits amp Requirements
It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of
o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants
Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC
Air Emissions
Presumably permanent in stack monitoring will be required in terms of AEL permit requirements
Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions
Water
Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)
General
There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)
Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards
Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter
All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 11 April 2012 1245 PM
To Lea September
Subject Fw Comments on Galvanising Plant EIR Coega IDZ
Lea
One other comment on that I have on the Galvanising Plant Draft EIR
Hydrogen chloride is one of the main emissions There are no ambient air
quality guidelines for HCl and the EIR says concentrations will be well
within health parameters
However the main problem with HCl is its corrosive effect - there is
absolutely no mention of this in the draft EIR nor air specialist report
There needs to be some sort of comment assessment as to whether HCl
emissions are likely to impact on for example the adjacent Agni-Steel
Plant wrt corrosion - their factory structure will be made of steel
The EIR specialist rpt suggests monitoring HCl at ground level on the
property boundary and this is supported in case there are complaints from
neighbours
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Paul Martin ltpmartinaxxesscozagt
To Lea September ltleailisocomgt
Sent Monday April 09 2012 1158 AM
Subject Comments on Galvanising Plant EIR Coega IDZ
gt Lea
gt
gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising
gt plant
gt
gt
gt Dr Paul Martin
gt PO Box 61029
gt Bluewater Bay 6212
gt Tel 041 4665698
gt Cell 0732524111
gt email pmartinaxxesscoza
gt
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 12 April 2012 1139 AM
To Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Hi Lea
Hope yoursquore keeping well
I have requested comments from my colleagues and the CDC Casa team on the Draft EIR
Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report
Regards
Andrea
From Graham Taylor
Sent Thursday April 12 2012 838 AM
To Andrea Von Holdt Firhana Sam
Cc Johan Fourie Maria van Zyl Melikhaya Sihawu
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Andrea Firhana
Firhana if you could please ensure that the co-ordinates provided in the EIR correspond
with our records (pages 4-1 amp 4-2)
My comments are as follows
It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work
Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above
Regards
Graham Taylor
Spatial Development Manager - Infrastructure Development
Mobile 0832283055
Office 0414030454
Facsimile 0865185033
Email GrahamTaylorcoegacoza
Website wwwcoegacom
right PLACE | right TIME | right CHOICE
This email and all contents are subject to the following disclaimer
httpwwwcoegacomemaildisclaimerhtml
From Lea September [mailtoleailisocom]
Sent 04 May 2012 0411 PM
To Andrea Von Holdt
Cc Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Dear Andrea
We have taken note of the comments from the GIS Unit These issues have been rectified in
the final version of the EIR
Please can you forward to the relevant persons at the GIS Unit
Thank you
Best regards
Lea September
APPENDIX E
BACKGROUND INFORMATION
DOCUMENT
APPENDIX F
AIR QUALITY IMPACT ASSESSMENT
APPENDIX G
TRAFFIC IMPACT ASSESSMENT
APPENDIX H
WASTE MANAGEMENT AND HAZARDOUS
SUBSTANCES SPECIALIST STUDY
APPENDIX I
WATER QUALITY SPECIALIST STUDY
APPENDIX J
ENVIRONMENTAL MANAGEMENT
PROGRAMME
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-2
of 2008) in which case the activity is regarded to be excluded from
this list
(iii) the undertaking of a linear activity falling below the thresholds in
Notice 544 of 2010
Hot dip galvanizing is a listed activity in terms of section 21 of the National
Environmental Management Air Quality Act 2004 (Act No 39 of 2004) and requires
an Atmospheric Emissions Licence (AEL)
In addition the treatment of wastewater with an annual throughput capacity of more
than 2000 m3 is a listed activity in terms of the National Environmental Management
Waste Act 59 of 2008 and requires a waste management licence
ILISO Consulting (Pty) Ltd has been appointed as the Independent Environmental
Assessment Practitioner (EAP) to conduct a Scoping and Environmental Impact
Assessment process in terms of section 24 of NEMA for the construction and
operation of the proposed galvanizing plant The EIA process covers all aspects of
the project and informs all three applications (for environmental authorisation waste
management licence and AEL)
13 PURPOSE OF THIS REPORT
This report builds on the scoping report submitted to the Eastern Cape Department of
Economic Development and Environmental Affairs (DEDEA) and the Nelson
Mandela Bay Municipality (the Competent Authorities) on 1st August 2011 It
describes the proposed project and presents the findings of the second phase of
investigations (EIA phase)
14 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP)
The EIA was managed by Ms Terry Baker a certified Environmental Assessment
Practitioner with 20 years of working experience She has a MA in Environmental
Management and specialises in Environmental Impact Assessments and Project
Management She has been involved in a variety of different types of EIAs including
for water supply projects dams transmission lines roads and airports in South
Africa Botswana Uganda Lesotho and Mozambique She has been involved in
water resource management and public participation programmes on a number of
projects Terry has also been involved in the use of Geographic Information Systems
environmental status quo reports water quality assessments socio-economic and
institutional development projects
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-3
15 PROJECT TEAM
In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen
(water quality specialist) and Lea September (EAP) with specialist input from Renee
von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous
substances) and Seniel Pillay (Traffic Impact Assessor)
The Business Unit Head of the ILISO Environmental Management Discipline Group
Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is
a Fellow of the South African Institution of Civil Engineers a member of the South
African Society of Aquatic Scientists of the Environmental Scientific Association of
the International Water Association of the Water Institute of South Africa and of the
Vaal River Catchment Association He is a certified Environmental Assessment
Practitioner with 30 years experience who specialises in project management
environmental impact assessments and water resource planning He specifically has
extensive experience in water quality especially water quality management water
quality monitoring and water quality assessment Martin has experience in managing
projects that involve multi-disciplinary teams and public consultation and
participation in South Africa and abroad
Lea September is an Environmental Assessment Practitioner with a Masters degree
in Environmental Management She has experience in impact assessment and
environmental management and has been responsible for drafting impact
assessment reports and Environmental Management Programmes and conducting
public participation processes as well as high level environmental screenings for a
variety of projects in the energy water transport and industrial sectors
Renee von Gruenewaldt has nine-years experience in the field of air pollution
impact assessment and air quality management Prior to becoming involved in air
quality consultation she was part of the Highveld Boundary Layer Wind Research
Group based at the University of Pretoria Since joining Environmental Management
Services (the company now Airshed Planning Professionals) she has undertaken
numerous air pollution impact studies and has provided extensive guidance to both
industry and government on air quality management practices
Pieter Smuts graduated as a Civil Engineer and became involved in the field of
municipal engineering and infrastructure construction He has specialized during the
last twelve years in solid waste management He has completed waste management
plans feasibility studies and final designs of waste management facilities in South
Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and
the review of the Mavoco hazardous waste landfill design in Maputo Mozambique
and completed a study on hazardous waste (textile factory sludge) management in
Maseru Lesotho
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-4
Seniel Pillay is a transportation engineer with over 16 years experience in
transportation planning and traffic engineering He has been involved in a wide
range of projects ranging from developing the Transport Operations Plan for the
FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System
for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller
traffic impact assessments for inter alia road improvement schemes Of particular
relevance to this project his experience includes Heavy Goods Vehicle Study for
eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact
Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash
Preliminary Transportation Assessment
16 STRUCTURE OF THIS REPORT
The proposed project and the alternatives considered are described in Chapter 2
Chapter 3 details the approach adopted for the EIA phase
The biophysical and socio-economic environment affected by the activity is described
in Chapter 4
The environmental impacts identified are discussed in Chapter 5
The EIA methodology is described in Chapter 6 and Chapter 7 presents the results
of the impact assessment
The environmental impact statement is presented in Chapter 8
Finally Chapter 9 spell out the conclusions and recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-1
2 DESCRIPTION OF THE PROPOSED PROJECT
21 TECHNICAL ASPECTS
211 The galvanizing process
Galvanizing consists of coating steel with zinc in order to protect it from corrosion
Before steel strips can be galvanized they undergo a pre-treatment in order to
ensure that the steel sheets are free from any surface oxides as they enter the
molten zinc coating Bath This is done by removing the oil from the steel sheets (in
the degreasing unit) and then removing the rust from the surface of the sheet (in the
pickling unit)
The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The
melting zinc on the strip surface will be cooled and solidified through air cooling in the
cooling tower
Finally the galvanised steel sheets are dipped into a water quenching tank in order to
further cool the sheets from about 150degC to 40degC
It is possible to make galvanised steel more durable by chromating it Approximately
50 of the galvanised steel production output will receive chromate passivation
treatment after quenching the galvanised steel sheets will be sprayed with a chrome
solution (3 kgcm2)
After galvanizing and chromating the steel sheets are cut to achieve the desired coil
size and weight and transported to the storage yard
The process flow diagram below (Figure 1) illustrates the main stages of the
galvanizing process and indicates the major inputs and outputs as well as the
resulting effluent and atmospheric emissions
Draft Environmenal Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-2
Figure 1 Process flow diagram for proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-3
212 Main inputs and outputs in operational phase
In view of the above the main inputs will be as follows
Steel coils 85 000 tonsyear
Zinc 870 tonsyear
Electricity 2500 kVA
Water 2000 m3month (of which 400 m3 will be potable water)
Liquid Natural Gas (LNG) 270 NM3hour
Sodium hydroxide (NaOH) 1000 m3year
Hydrochloric acid (HCl) 800 m3year
Chrome (Cr+3) 10 m3year
The main outputs will be
Galvanized steel 80 000 tonsyear
Scrap metal 20 tonsyear
General waste 65 tonsyear
Hazardous waste 2 m3month
Wastewater 012 Mlweek
Atmospheric emissions lt 5 ppm
213 Installations on site
The bulk of the operations involved in the galvanizing process occur along a
continuous galvanizing line (See Figure 2 below) which is the main piece of
machinery required for the proposed galvanising plant
Figure 2 Continuous Galvanizing Line
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-4
Water is one of the major inputs and is used throughout the galvanizing process notably
for rinsing and cooling purposes and as a mixing agent for the various chemical
solutions The plant will have a water treatment plant on site to treat the water used in
the various processes (approx 250 m3
of wastewater per week) The wastewater
treatment facility will be operated by a professional water treatment company as Casa
Steel does not have the required expertise in house to treat its process water Sulphuric
acid (H2SO4) is used as part of the treatment process to reduce caustic soda The
neutralised water is discharged to the sewer while any sludge is disposed of as
hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)
will be disposed of
Some critical areas of the galvanizing process such as the zinc pot require uninterrupted
power It is therefore proposed to install an LNG burner to maintain the zinc bath at a
temperature of between 450 and 460degC
22 LOCATION OF THE PROPOSED GALVANIZING PLANT
The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast
of Port Elizabeth in the Eastern Cape (Figure 3)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-5
Figure 3 Location of the proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-6
23 NEED AND DESIRABILITY
The profitability of the proposed project has been established by Casa Steel and a
pre-feasibility study has confirmed that the proposed project was feasible from a
technical and financial point of view The Coega IDZ is specifically designed to host
facilities such as a galvanizing plant and can provide the necessary infrastructure
and services to its investors It therefore constitutes a very suitable location for the
project
24 ALTERNATIVES IDENTIFIED
Zone 6 has been specifically earmarked for heavy ferrous metal industries and is
therefore a suitable location for the proposed galvanizing plant as such no site
alternatives have been provided for and assessed in this EIA However prior to the
commencement of the EIA process Casa Steel was presented with a number of
different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the
selection of the site were
(a) The dimensions of the land the site should be at least 200 m long and
50 m wide in order to accommodate the galvanizing line and adjacent lay
down area and additional land should be available next to the site for future
expansion
(b) The fiscal arrangements applying to the site the site should be located
within the future Custom Controlled Area (CCA) as the bulk of the
production output of the plant will be exported
The no-go alternative is assessed in this report
25 CONSTRUCTION ASPECTS
The construction phase of the project will take about 12 months and will essentially
consist of erecting a building to house the galvanizing line and other equipment and
preparing a concrete laydown area adjacent to the building
The CDC will provide an access point from the existing tarred road that will lead to
the site
Approximately 100 workers from the surrounding areas will be contracted for the
construction work
The requirements in terms of services during construction are listed below
Water 1000 m3month
Electricity 2500 kVA
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-7
The CDC will provide temporary services for the construction phase including a
conservancy tank for flush toilets Sewage infrastructure will only be provided for the
operational phase
26 OPERATION ASPECTS
Before the plant can become fully operational the equipment and machinery will be
tested for approximately 3 months The supplier will supervise these tests as part of
the transfer of know-how and training of staff on the plant
Casa Steel will start operating the plant at a reduced capacity (about 50 000
tonsyear) for a period of time (mostly determined by market aspects) before bringing
production to full capacity (80 000 tonsyear) This is done by operating the line for
longer hours
Approximately 50 to 60 people will be working on the plant Approximately 6-10 of
these will be unskilled 40-45 skilled and about 5 people in managerial positions
The requirements in terms of services during operation are as follows
Water 2000 m3month
Electricity 2500 kVA
Effluent discharge 24 m3day
The CDC has entered into agreements with the municipality to secure the provision
of services such as water and electricity to its tenants Tenants in the IDZ have their
own agreements with the NMBM for electricity while the agreements for water and
sewage are with the Facilities Unit of the CDC
Regarding discharge of wastewater to the sewer the municipality indicated that the
only requirement is that the water discharged complies with applicable municipal
discharge standards
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 3-1
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT
31 OBJECTIVES
The main objectives of the EIA phase are to
Assess the significance of the environmental issues and impacts identified in the
scoping phase focusing on key impacts
Recommend appropriate measures to mitigate negative impacts and enhance the
benefits and include them in the draft EMP
Undertake a public participation process that provides opportunities for all
interested and affected parties (IampAPs) to be involved
32 AUTHORITY CONSULTATION
The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental
Liaison Committeersquo (ELC) which comprises representatives of various authorities
including DEDEAT the Department of Environmental Affairs (DEA) and Department
of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the
Coega Development Corporation (CDC) and Transnet National Ports Authority
(TNPA) The ELC has been specifically formed to facilitate EIA applications in the
IDZ
Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to
the clearance of vegetation should be included in the application A formal request
was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the
application and all registered stakeholders were informed of the request in writing on
19 October 2011
33 PUBLIC PARTICIPATION PROCESS CONDUCTED
On-site notices were replaced by a notification displayed on the CDCrsquos digital notice
board at the business centre in Zone 1 of the IDZ The eNotice was placed on
13 April 2011 and will remain for the full duration of the EIA process
Registered stakeholders will be notified in writing of the availability of the draft EIA
report and EMP which will also be advertised in a local newspaper Stakeholders
including state departments and the public will have forty (40) days to comment on
the draft EIA report and EMP The draft EIA report and EMP will be sent by email
where possible and made available for download on the ILISO website
(wwwilisocom)
A summary of all issues and comments received during the stakeholder consultation
process as well as of correspondence in that regard will be captured in an Issues
and Responses Report that will form an Appendix to the EIA Report
The list of registered IampAPs is included in Appendix A
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 3-2
34 LEGISLATION AND GUIDELINES CONSIDERED
The following legislation and guidelines were considered in the preparation of this
report
National Environmental Management Act Act No 107 of 1998
NEMA EIA Regulations 2010
National Environmental Management Air Quality Act Act No 39 of 2004
National Environmental Management Waste Act Act No 59 of 2008
Hazardous Substances Act Act 15 of 1993
Occupational Health and Safety Act Act 85 of 1993
Hazardous Chemical Substances Regulations 1995 (GNR 1179)
Major Hazard Installation Regulations 2001 (GNR 692)
National Water Act Act 36 of 1998
National Heritage Resources Act Act 25 of 1999
DEAT Integrated Environmental Management Information Series 1-5 and 12-15
NEMA draft Implementation Guideline
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Public Participation (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Alternatives (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Draft Guideline for Determining the Scope of Specialist
Involvement in EIA Processes (2005)
IAIA guidelines
National air quality standard for thoracic particulates Government Gazette
No 32816
Listed activities and associated minimum standards identified in terms of section
21 of the National Environmental Management Air Quality Act Act No 39 of
2004 Government Notice 248 of 2009
Minimum Requirements for the Handling Classification and Disposal of
Hazardous Waste DWAF Waste Management Series (1998)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-1
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION
The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega
IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay
to the north of the N2 highway between Port Elizabeth and Grahamstown east of the
Coega River
The co-ordinates of the corners of the site are shown in Table 1
Table 1 Coordinates of site corners for the proposed galvanizing plant
Point Longitude Latitude
A 25deg411126E 33deg45587S
B 25deg411156E 33deg45499S
C 25deg411938E 33deg45131S
D 25deg412174E 33deg45481S
E 25deg412508E 33deg45979S
F 25deg412634E 33deg451160S
G 25deg411782E 33deg451560S
H 25deg411692E 33deg451428S
J 25deg411314E 33deg45868S
Figure 4 Zone layout in the Coega IDZ
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-2
Figure 5 Site location
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-3
42 SOCIO-ECONOMIC CHARACTERISTICS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the
NMBM There are no residents within the IDZ
As far as the broader NMBM and Eastern Cape Province are concerned the
following can be noted The NMBM is located within the Eastern Cape Province the
2nd largest Province in South Africa (3rd in terms of population) characterised by a
predominantly black population with low incomes and high levels of unemployment
(CES 2010)
The NMBM has a population of just above 11 million and covers an area of
1 950 km2 It is the main urban and industrial centre of the province and Port
Elizabeth in particular which forms part of the NMBM is the commercial capital of
the Eastern Cape 52 of the NMBM population is female and 37 is below the
age of 20 these two groups are particularly affected by unemployment
43 BIOPHYSICAL CHARACTERISTICS
431 Surface and ground water
No rivers occur in Zone 6 There is however a natural attenuation pond on the
southern most part of the site which will have to be avoided
The IDZ is underlain by calcrete sand and gravel deposits that overlie low
permeability clays These clays limit the vertical infiltration of rainwater and induce a
horizontal groundwater flow towards the Coega River channel which is the most
significant surface water feature in the Coega IDZ Consequently rapid run-off takes
place following precipitation (Jacobs 2008)
Groundwater levels at Coega are generally about 3 to 5 m below surface ie just
above the contact between the permeable sands and the underlying impermeable
clays The groundwater flow direction is to the southeast following the surface water
drainage direction (Jacobs 2008)
432 Climate and atmospheric conditions
Port Elizabeth has a warm temperate climate and the temperature ranges are not
extreme Exceptionally high temperatures may be experienced during berg wind
conditions which occur frequently during autumn and winter Extreme temperatures
also occur during summer with little accompanying wind
The wind regime for the area largely reflects the synoptic scale circulation with
dominant westerly and northwesterly flow fields representing the pre-frontal
conditions and south-westerly flow fields representing the frontal conditions The
south-easterly and south-westerly wind flow (land breeze) increases during daytime
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-4
conditions with westerly and north-westerly wind flow increasing during the night (sea
breeze)
The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of
Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15
km southwest) and Port Elizabeth (~23 km southwest)
An ambient air monitoring network has been established in the Coega IDZ which
consists of three monitors Saltworks Motherwell and Amsterdamplein Although
NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative
impacts due to the proposed Galvanising Plant is PM10 A maximum daily average
PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed
SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3
was exceeded on 17 days in 2007 and 26 days in 2008
Existing sources of emissions in the vicinity of the proposed galvanizing plant include
industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other
fugitive dust sources (von Gruenewaldt 2011b)
433 Geology and soils
Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel
and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly
limestone and conglomerate
434 Terrestrial ecology
This section draws from the EIA report compiled for the Agni Steel (formerly Afro-
Asia) steel processing facility which is adjacent to the proposed site for the
galvanizing plant (Jacobs 2008)
The area consists largely of grasses succulents and scrubby bush with alien
species making up the greater part of the more dense vegetation
Zone 6 falls within the inland vegetation and is characterised by a vegetation type
referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the
Coega IDZ and has been found to have three times the level of endemism of other
vegetation communities in the Coega IDZ Bontveld therefore has a high
conservation status Two Bontveld conservation areas have been identified within the
IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)
Bontveld that will be destroyed as a result of development in the IDZ will be given
conservation status in these two areas
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-5
Figure 6 Coega IDZ Open Space Management Plan (OSMP)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-6
Certain areas in the IDZ are invaded by alien plant species The most common
invader species is rooikrans (Acacia cyclops) which presently forms large
monospecific stands in areas throughout the Coega IDZ There are several other
aliens present that pose a threat to the flora of this area including the prickly pear
(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)
Loss of vegetation and alien plant invasion due to human activity has resulted in a
reduction in the diversity of terrestrial fauna
The majority of mammals present in the Coega IDZ are small or medium-sized Of
the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed
gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of
Algoa Bay however it is not considered threatened The gerbil is common in
foredune and dune thicket habitat in the Coega region and is therefore unlikely to
occur on the proposed site
A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird
species are resident or common to the area Most diversity occurs in the thicket
although the coastal area also supports specialised avifauna Two species of tern
the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well
as the Cape gannet (Morus capensis) and the African penguin (Spheniscus
demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne
caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant
(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser
flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns
are two of the most endangered coastal species in South Africa Other bird species
of conservation concern include the Whitefronted plover (Charadrius marginatus)
African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus
bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus
ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides
paradisea) Breeding pairs of Damara terns and African black oyster catchers have
been observed in the coastal dunes of the IDZ but should not be affected by
developments that fall outside the dune areas
The Eastern Cape supports nearly a third (approximately 133 species) of the reptile
species recorded in South Africa More than half of the Eastern Capersquos endemic
reptile species occur in the Algoa Bay area giving the region a high conservation
value A total of 63 reptile species are believed to occur within the Coega IDZ The
majority of these are found in Succulent Thicket and riverine habitats Only a few
reptile species occur in the coastal dunes and estuarine habitats More than a third of
the species are described as relatively tolerant of disturbed environments provided
that migration corridors of suitable habitat are maintained to link pristine habitats
Twenty two reptiles are of special concern including five endemic species (two of
which may also be endangered) four endangered sea turtles eight species listed
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-7
with CITES one rare species and four species at the periphery of their range
Fourteen of these species of special concern are confirmed as occurring on or within
2 km of the Coega IDZ
A total of 32 amphibian species and sub-species occur in the Eastern Cape
representing almost a third of the species recorded in South Africa However none of
the species are endemic or Red Data Book species Based on previous studies in the
area it is estimated that approximately 17 amphibian species occur within the Coega
IDZ Four species are listed as peripheral but none are threatened internationally
These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog
(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and
the bubbling kassina (Kassina senegalensis)
The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated
vegetation has not been extensively studied One grasshopper species Acrotylos
hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue
(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis
pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in
four localities in the Eastern Cape one of which is within the Coega IDZ The Coega
copper Aloeides clarki is endemic to this particular region of the Eastern Cape and
is currently known to occur in three localities two of which are in the Coega IDZ The
localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the
Coega IDZ and their distributions were taken into account when defining Coegarsquos
open space system and Development Framework Plan
435 Land use and topography
The land is currently undeveloped and earmarked for industrial development The
site is relatively flat ranging from an elevation of 66 masl on the northern-most
corner to 59 masl at the southern-most corner
436 Heritage and archaeological survey
Extensive studies have been undertaken in Zone 6 with respect to heritage aspects
Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a
2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond
2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is
currently being finalised
Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing
Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha
in extent and was located next to the R102 road to Motherwell Kaplan conducted
HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi
Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will
now be located in Zone 5)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-8
The various archaeological investigations reached similar observations and
conclusions Stone tools of various densities and types were found throughout the
zone The majority of the stone tools were mainly of Earlier and Middle Stone Age
and occasional Later Stone Age origins (Figure 4)
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble
gravels exposed by tracks in Zone 6 (Source Binneman 2010)
The stone tools which comprised of quartzite flakes chunks flaked pebblecobble
and cores were randomly distributed across the landscape and are in secondary
context There were no lsquoconcentrationsrsquo of tools observed which suggested any
spatial patterning or activity areas although these may be present or covered by soil
and vegetation
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 5-1
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED
The following environmental issues and potential impacts were identified in the
Scoping phase
51 AIR QUALITY
The galvanizing process generates atmospheric emissions with particulates and
hydrogen chloride representing the main pollutants of concern The plant is fitted with
air extraction as well as scrubber systems which are designed to retain the bulk of
pollutants and particles for each of the processes in such a way that less than 5 ppm
of gases and particles will be released into the atmosphere after the fume scrubber
Other sources of impact on air quality include emissions from the LNG burner as well
as emissions and dust from the transport of steel and other materials in trucks
Construction activities will also create dust and gas emissions due to the clearing of
groundcover tipping of material to storage pile levelling of area wind erosion from
storage piles vehicle and construction equipment activity and tailpipe emissions
from vehicles and construction equipment such as graders scrapers and dozers
Overall the air quality impact assessment (Gruenewaldt 2011b) found that
The predicted particulate oxides of nitrogen carbon monoxide and sulphur
dioxide concentrations are all below the National Ambient Air Quality Standards
for all averaging periods
The predicted off-site concentrations of hydrogen chloride are well below the
most stringent effect screening levels
No odour threshold exceedances for hydrogen chloride were predicted to occur
due to routine operations at the Steel Galvanising Plant The South Wales
Environmental Protection Authority stipulates that an odour unit of 20 is
acceptable for urban areas The odour unit would be lt10 directly off-site for
hydrogen chloride
Abnormal emissions can occur in exceptional circumstances Start-up will not
cause abnormal emissions as the scrubbers will be commissioned first and will be
functioning once the plant starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions would be emitted as a
building fugitive
The hourly hydrogen chloride ground level concentrations (directly offsite) were
predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based
on the emission limits as stipulated for listed activities for galvanising processes)
using a screen model which assumes worst case meteorological conditions The
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-2
health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming
abnormal emissions emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset conditions will still
be well within the health effect screening levels
Similarly the hourly particulate emissions from the building fugitives during upset
conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for
listed activities for galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly
off-site
Therefore if emissions are 5 times higher normal they will still be within health effect
screening levels and the daily PM10 NAAQS levels
In the case of a fire a cocktail of gases and particulates could be emitted and could
be over the recommended levels This situation will however be dealt with as an
emergency and normalised as quickly as is possible
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS
The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of
its heritage potential and there are no proposed protected geosites in Zone 6
Should any artefacts be discovered during construction procedures stipulated in the
draft EMP will apply
53 BIODIVERSITY AND CONSERVATION
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
In terms of terrestrial fauna the CDCrsquos open space management plan provides for
the preservation of certain corridors The destruction of certain habitats as a result of
the development will therefore not automatically result in the loss of certain species
54 WATER QUALITY
There is a natural attenuation pond on the southern most part of the site which will be
avoided
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through
spills or leaks
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-3
This risk can however be minimized if not avoided altogether The floor of the factory
will be designed as a bunded area to contain any spills and the entire process will be
contained Potential spills or leaks will therefore be contained and will not impact on
water resources Storm water is therefore considered clean water under normal
operational conditions An oil trap will be placed at the exit of the site to ensure that
no grease from the laydown area enters the stormwater system
Spills and leaks can occur during the handling or the transport of hazardous
substances Best practice guidelines will be followed to ensure that this risk is
adequately managed
Wastewater discharged to sewer will be treated to comply with municipal discharge
standards and is not expected to have an impact on the chemical characteristics of
the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be
discharged from the plant is small in relation to the total volume received at the
Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works
(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently
operated at 61 of its capacity which is approximately 80 Mℓday Thus the
0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore
not have any significant impact on the WWTW
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES
The plant will generate a relatively small amount of solid waste in the form of scrap
metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)
The scrap metal may be sold to other steel processing facilities such as Agni Steel
which will be located next to the plant or collected and disposed of with the rest of
the solid waste by a licensed service provider
As mentioned previously there will be a wastewater treatment plant on site which will
neutralise process water (012 Mlweek) in order to ensure it is of a standard
acceptable for discharge to sewer Waste in the form of sludge from the
neutralization or spent acid must be disposed of as a hazardous waste Solid waste
from the filters used for air quality control is also in this category These wastes can
usually be tested and then delisted which means that it can be placed in a general
purpose landfill
Hazardous effluent from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-
site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored
and removed on a monthly basis is limited to 10 m3
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-4
A number of substances classified as hazardous are used in the galvanizing process
(Table 2) and the transport and handling of these is subject to certain rules and
guidelines In particular the material safety data sheets (cf Appendix H) should be
referred to for inter alia hazards identification accidental release measures
handling and storage precautions exposure controlpersonal protection ecological
information and transport information The Hazardous Chemical Substances
Regulations 1995 should also be adhered to in respect of the transport and storage
of hazardous chemical substances
Table 2 Hazardous materials to be used on site
Major Input Materials
Substance
listed in the
SABS 0228
Group II
hazardous
substances
Volumes to be
stored on site at
any one time
Diesel radic 2000 litres
Liquid petroleum radic 20 000 liters
Sodium hydroxide (NaOH)
(used for degreasing) 8 radic 1000m
3
Hydrochloric acid (HCI)
(used for pickling) 8 radic 800m
3
Zinc (used for galvanising) - TBD
Trivalent chromium (CR+3
)
(used for chromating) 8 radic 10m
3
Sulphuric acid (H2SO4) (used for
treatment of waste water on site) 8 radic TBD
Ammonium Hydroxide (NH4OH) 8 radic TBD
TBD ndash To be determined
Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one
time) and is classified as a flammable substance Specification for flammable storage
facilities in accordance with the requirements of the Nelson Mandela Bay
Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for
quantities between 5000 and 20 000 liters the substance must be kept in a
flammable liquid store which complies with the requirements of a specification
obtainable from the Department Some of the requirements are
Flammable liquid and solid storage facilities are only permitted on the ground
floor
Decanting of flammable liquids and solids are not permitted within any building
Due to the fact that there are flammable materials on site a certificate may be
required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and
Emergency Services Department to confirm that facilities for flammable storage
are in accordance with their requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-5
Because of the permanent installation and high quantity of liquid petroleum on site
the Major Hazard Installation Regulations 2001 promulgated under the Occupational
Health and Safety Act No 85 of 1993 applies A written application for approval of
the installation is required to be submitted to the chief inspector Department of
Labour provincial director Department of Labour and NMBM prior to construction
In addition a risk assessment should be formulated covering all hazardous materials
together with an emergency preparedness and response plan
56 HEALTH AND SAFETY
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling instructions as well as occupational exposure limits
are indicated in the material safety data sheets of the various substances used
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as
provide site supervision including executing tests (individual test cold run and hot
run) during 3 months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the
EMP
In addition the emergency preparedness and response plan will cover the health and
safety aspects related to emergency situations
57 TRAFFIC
The volumes of traffic at the IDZ are currently relatively low and variable depending
on the different zones in the IDZ however these volumes will increase as more
developments are implemented
The construction phase of the Casa Steel development will take about 12 months
and will essentially consist of erecting a building to house the galvanizing line and
other equipment and preparing a concrete laydown area adjacent to the building
The traffic that would be generated during the construction phase can be expected to
be less than the traffic that would be generated by the Casa Steel development when
it is fully operational
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-6
In the operation phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and
from the Port of Ngqura
The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the
Casa Steel development would be off Ring Road 1 The other roads of significance
for the Casa Steel development are the N2 Neptune Road MR435 and MR450
Access to the port is given by Neptune Road Road Link NEP-03 has not yet been
built
Figure 8 Coega IDZ road network identification
(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-7
Figure 9 Coega IDZ road network
Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No
01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-8
The distribution of freight trips is fixed as the majority of trips will be made between
the Port of Ngqura and the Casa Steel site With regard to personnel trips there are
various points of origins (the surrounding residential areas) that could be used by
staff going to the Casa Steel site The distribution of personnel trips is based on
existing traffic count information and is shown in Figure 10
Figure 10 Trip distribution for freight and personnel trips
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The resultant expected Casa Steel traffic assignment is shown in Figure 11
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-9
Figure 11 Morning peak hour Casa Steel development traffic
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The traffic that is expected to be generated by the Casa Steel development is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low
and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)
Consultation has taken place with Transnet Port Authority (TPA) to establish the
impact of the galvanizing plant operations on traffic inside the port The additional
ships entering and exiting the port of Ngqura as a result of the proposed development
will have a negligible impact on port traffic and TPA indicated that it would be well
within the portrsquos capacity
58 NOISE
Noise is not foreseen to be a significant issue insofar as the noise levels inside the
plant and at the boundary of the site will not exceed the limits prescribed by the CDC
Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels
during the day and 60 decibels at night
Mitigation of noise impacts will be addressed in the design of the noise-emitting
components of the plant and their enclosures
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-10
59 SOCIO-ECONOMIC ASPECTS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of
NMBM There are no residents within the IDZ
The direct socio-economic impacts of the proposed project are thus limited to the
employment generated by the project during construction and operation Job creation
remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)
and the IDZ and Port of Ngqura are expected to become a significant catalyst to the
economic growth of the Municipality and the region with current investments at
Coega creating more jobs and stimulating the economy
In this context the proposed galvanizing plant will make a positive contribution
towards the achievement of these goals
There will be 50 to 60 employees during operation phase distributed as follows
Figure 12 Casa Steel organisation chart
Even though a large part of the inputs will be imported and the bulk of the production
output will be exported there will be some positive impacts for the economy of the
region and of South Africa in general Notably the requirements of the plant for
water electricity waste collection and disposal waste water treatment and transport
for example will create business for the various service providers and have an
indirect impact on employment and fiscal revenues as a result
From a visual impact point of view it can be anticipated that the landscape in the IDZ
will be significantly affected over time by developments related to the establishment
of the port and various industries
HEAD ( WORKS )
MGR ( COMM) MGR ( ADMNHR ) Manager marketing
MANAGER OPERATION MANAGER MANAGER MANAGER Q C
AC FIN PUR ampSTORE
PPC SH-GALV SH-tech
SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF
1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO
JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF
2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO
WORKERS WORKERS 7NOS
15 7
RAW MAT amp
DESP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 6-1
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
A description of the nature of the impact any specific legal requirements and the
stage (constructiondecommissioning or operation) will be given Impacts are
considered to be the same during construction and decommissioning The
significance of the potential impacts will be considered before and after identified
mitigation is implemented
The following criteria will be used to evaluate significance
Nature The nature of the impact will be classified as positive or negative and
direct or indirect
Extent and location Magnitude of the impact and is classified as
Local the impacted area is only at the site ndash the actual extent of the activity
Regional the impacted area extends to the surrounding immediate and
neighbouring properties
National the impact can be considered to be of national importance
Duration This measures the lifetime of the impact and is classified as
o Short term the impact will be for 0 ndash 3 years or only last for the period of
construction
o Medium term three to ten years
o Long term longer than 10 years or the impact will continue for the entire
operational lifetime of the project
o Permanent this applies to the impact that will remain after the operational
lifetime of the project
Intensity This is the degree to which the project affects or changes the
environment and is classified as
o Low the change is slight and often not noticeable and the natural functioning
of the environment is not affected
o Medium The environment is remarkably altered but still functions in a
modified way
o High Functioning of the affected environment is disturbed and can cease
Probability This is the likelihood or the chances that the impact will occur and
is classified as
o Low during the normal operation of the project no impacts are expected
o Medium the impact is likely to occur if extra care is not taken to mitigate
them
o High the environment will be affected irrespectively in some cases such
impact can be reduced
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 6-2
Confidence This is the level knowledgeinformation the environmental impact
practitioner or a specialist had in hisher judgement and is rated as
o Low the judgement is based on intuition and not on knowledge or
information
o Medium common sense and general knowledge informs the decision
o High Scientific and or proven information has been used to give such a
judgment
Significance Based on the above criteria the significance of issues will be
determined This is the importance of the impact in terms of physical extent and
time scale and is rated as
o Low the impacts are less important
o Medium the impacts are important and require attention mitigation is
required to reduce the negative impacts
o High the impacts are of great importance Mitigation is therefore crucial
Cumulative Impacts The possible cumulative impacts will also be considered
Mitigation Mitigation for significant issues is incorporated into the EMP for
construction
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 7-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS
71 IMPACTS DURING CONSTRUCTION
711 Air quality
Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris
handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine
particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural
operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks
and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)
Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Fugitive particulate emissions (dust)
related to construction activities Regional
Short
term Medium High High Medium Regional
Short
term Low High High Low
Construction vehicle gas emissions Regional Short
term Medium High High Medium Regional
Short
term Low High High Low
712 Heritage and archaeological resources
Naturedescription of impact excavation activities may impact on unidentified heritage resources
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-2
Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based
on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments
Heritage and archaeological
resources Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on unidentified heritage
resources Local
Short
term
Medium -
high Low High Low
713 Biodiversity and conservation
Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation
importance and cause soil contamination
Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species
Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan
and has compiled a list of protected species to be rescued (see draft EMP)
Biodiversity and conservation Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Loss of fauna and flora Local Perma
nent
Medium -
high High High High Local
Permanen
t Medium High High Medium
Soil contamination Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-3
714 Water related impacts
Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater
runoff spills and leaks Soil erosion
Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of
spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste
disposal Stormwater quality monitoring (see draft EMP)
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Soil erosion Local Short
term Medium Medium High Medium Local
Short
term Medium Low High Low
715 Waste management
Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed
Commentmitigation see draft EMP and waste management plan
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-4
Waste management Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Local
Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
716 Health and safety
Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Short
term
Medium -
high
Medium -
high High High Local
Short
term
Medium -
high Low High Low
717 Traffic
Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and
construction workers from surrounding areas and transport of equipment from the port
Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low
Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and
accurate estimates of quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-5
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Increased traffic on N2 and within the
IDZ Regional
Short
term Low High High Low
718 Noise
Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Short
term
Medium-
high High High Medium Local
Short
term Medium High High Medium
719 Socio-economic
Naturedescription of impact temporary employment will be created during the construction phase
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-6
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Temporary employment Regional Short
term Medium High High Medium
72 IMPACTS DURING OPERATION
721 Air quality
NatureDescription of impact gas and particulate emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning
Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local
sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and
veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute
to background fine particulate concentrations (von Gruenewaldt 2011b)
Assumptions and limitations Potential release of CR6+
As no emission factors are available for trivalent chromium processing the
potential impacts due to these activities could not be quantified
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Dust emitted from traffic on paved roads Regional Long Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-7
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
term
Hydrogen chloride emissions from
pickling process Local
Long
term Low High High Low
Particulate emissions (smoke) from
galvanizing process (due to the
volatilization of flux)
Local Long
term Low High High Low
Particulate oxides of nitrogen carbon
monoxide and sulphur dioxide emissions
from LNG burner
Local Long
term Low High High Low
Nuisance related to odour Local Long
term Low Low High Low
Abnormally high hydrogen chloride and
particulate emissions due to scrubber
malfunction
Local Short
term Medium Low High Medium
Gases (eg SOx NOx CO etc) and
smoke emitted in case of a fire Local
Short
term High Low High Medium
722 Water quality
NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks
Commentmitigation see draft EMP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-8
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Stormwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
723 Waste management and hazardous substances
NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous
waste both can affect environmental quality and human health
Commentmitigation see draft EMP and waste management plan
Waste management and hazardous
substances Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Regional
Long
term High
Medium -
high High High Regional Long term High Low High Low
Soilwaterair pollution due to improper
transport storage and handling of
hazardous substances
Regional Long
term High
Medium -
high High High Regional Long term High Low High Low
Health hazard Local Long
term High
Medium -
high High High Local Long term High Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-9
724 Health and safety
Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Long
term
Medium-
high
Medium-
high High High Local Long term
Medium-
high Low High Low
725 Traffic
Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on
the road network
Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak
hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road
network within Zone 6 of the IDZ (Iliso 2011)
Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)
Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of
quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-10
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on traffic and capacity of the N2 Regional Long
term Low High High Low
Impact on traffic and capacity of ring
road 1 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR435 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR450 Local
Long
term Low High High Low
Impact on traffic and capacity of
Neptune road Local
Long
term Low High High Low
726 Noise
Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Long
term Medium High High Medium Local Long term Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-11
727 Socio-economic
Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate
revenue for the municipality and the region as a whole
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Employment and economic growth Regional Short
term Medium High High Medium
73 COMPARATIVE ASSESSMENT OF IMPACTS
During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as
low during operation after mitigation
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 8-1
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
As a tenant operating in the IDZ Casa Steel will be required to comply with all
current and future CDC requirements as well as with the relevant conditions of
permits licences issued to CDC (eg Integrated Stormwater Masterplan for the
eastern side of the Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)
In particular the CDC has its own requirements regarding the monitoring of certain
aspects of the project such as the quality of the effluent and the noise levels These
have been incorporated into the EMP
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 9-1
9 ENVIRONMENTAL IMPACT STATEMENT
All predicted negative impacts can be mitigated to a low significance The only
exceptions are biodiversity as the construction of the plant will result in the
destruction of habitat and loss of fauna and flora and noise impacts inherent to
construction activities Mitigation measures have been included in the EMP for these
impacts and they have a medium significance post-mitigation
Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium to
long term similar impacts are likely to occur due to ongoing developments in the IDZ
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 10-1
10 CONCLUSION AND RECOMMENDATIONS
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as
other infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified
and assessed No fatal flaws have been identified
It is recommended that the project be approved subject to the conditions listed in
chapter 9 and adherence to the EMP requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 11-1
11 REFERENCES
Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ
Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants
Bennie JS (2010) The historical component (built environment) of the Heritage
Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port
Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report
compiled for Eastern Cape Heritage Consultants
Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater
Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay
Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage
Consultants
BKS (2006) Coega Industrial Development Zone Transport Study Volume 3
Demand Modelling Report Final Draft
Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I
Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6
Report compiled for SRK Consulting
Coastal amp Environmental Services (2010) Environmental Impact Assessment for the
Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone
Volume 3 Environmental Impact Assessment Report CES Grahamstown
Coega Development Corporation (2008) Industry Waste Management Plan -
Strategic Master Plan Report
Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants
Report No CDCSHE 03 8122
Department of Water Affairs and Forestry (1998) Waste Management Series
ldquoMinimum Requirements For The Handling Classification And Disposal Of
Hazardous Wasterdquo Second Edition
Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising
Plant in the Coega Industrial Development Zone
Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the
Coega Industrial Development Zone (IDZ) Specialist Water Study
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 11-2
Jacobs E (2008) Final Environmental Impact Report and Draft Environmental
Management Plan Proposed Steel Recycling and Processing Facility within the
Coega IDZ Report compiled for SRK Consulting
Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY
Galvanising Plant in the Coega Industrial Development Zone Waste Management
and Hazardous Substances Report compiled for ILISO Consulting
RSA National air quality standard for thoracic particulates (PM10) SA standards
(Government Gazette No 32816)
von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed
Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape
Report compiled for ILISO Consulting
von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel
Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report
compiled for ILISO Consulting
Additional sources
Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed
Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared
for Coastal Environmental Services
Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed
Kalagadi Manganese smelter in the Coega Industrial Development Zone Port
Elizabeth Eastern Cape Province Report prepared for Coastal Environmental
Services
Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia
steel recycling facility at the Coega Industrial Development Area Port Elizabeth
Prepared for SRK Consulting Port Elizabeth
APPENDIX A
LIST OF INTERESTED AND
AFFECTED PARTIES
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
DEDEARegional Manager
and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza
DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza
DEA Ocean and
CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza
DEA Ocean and
Coast
Oceanographer land-
based sources of
marine pollution
Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza
DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza
CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza
CDCEnvironmental
Project
Manager
Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza
TNPAPort of Ngqura
Environmental
Manager
Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet
NMBMEnvironmental
ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza
NMBMEnvironmental
ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza
DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza
DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza
WESSASenior Conservation
Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza
Zwartkops
ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700
hughlauegmailcom
zwartkopstrustiafricacom
SANParksNational Marine
CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza
Department Of
LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza
NMBM Air Quality
Division
Assistant
DirectorAir
Pollution and Noise
Templeton Titima 079 490 0574 Ttitimamandelametrogovza
NMBM Air Quality
DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza
NUMSARegional
RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
Department of
HealthNadiema
van der
Bergh083 378 2103
nadiemavanderberghimpiloecprovgov
za
DWA Chief Services
Officer
Joseph Jacobs 041 586 4884 jjacobsdwafgovza
EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza
NUMSecretary of union
officesZandile Xhentsa 043 743 6597 zxhentsanumorgza
DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza
Dynamic
CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom
EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza
Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza
UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom
lprincezago2uticom
Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza
Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza
Absa Mr Johann Steyn 082 3775820 johannstabsacoza
Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza
PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza
Universal
EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza
Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza
GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom
Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza
NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom
DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza
DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza
TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet
DWA Mr Landile Jack JackLdwagovza
DWA Ms Lizna Fourie FourieL4dwagovza
APPENDIX B
NOTICE OF ATMOSPHERIC
EMISSIONS LICENCE APPLICATION
AND ADVERTISEMENT
APPENDIX C
NOTICE OF COMMENT PERIOD FOR
DRAFT SCOPING REPORT
APPENDIX D
SUMMARY OF ISSUES RAISED AND
RESPONSES THERETO
April 2012
1
PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL
DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))
IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt
AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt
This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses
provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process
conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the
Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
2
IssueCommentQuestion Date
received Origin Response
1 Please provide more information with respect to the potential
dangers including the toxicity of the proposed project
07032011
By email
Wayne Poulton
(Bosun Brick
tenant at the
IDZ)
An Environmental Impact Assessment (EIA) was undertaken
which assessed the potential toxicity of the emissions and
effluent Mitigation measures were also recommended in the draft
Environmental Management Programme (EMP) to avoid
minimise or compensate any significant impacts The Draft
Environmental Impact Report and draft EMP were made available
to stakeholders for comment in March 2012
2 Do you have a Background Information Document (BID) or
similar that provides more information on the project
27032011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The BID was sent to all registered IampAPs on 4 May 2011
3 The RoD issued to the CDC on 632007 for the change in
land use for the remaining area of the Coega IDZ includes a
number of requirements with respect to
atmospheric emissions that should be considered in the
Atmospheric Emissions Licence (AEL) application such as
prohibiting and monitoring where possible visible emission
plumes to the atmosphere In particular the
recommendations on pp87-91 of the final revised Scoping
Report dated Nov 2006 must be implemented (clause 421)
04042011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
We have obtained copies of the documents referred to and ensure
that these requirements were taken into account in the
environmental assessment and AEL application
4 If the Port of Ngqura is used for import and export the scope
of the traffic impact assessment (TIA) should also include the
port
10052011
By email
Elliot
Motsoahole
(TNPA Port of
Ngqura)
The scope of the TIA was extended to include port related traffic
The TNPA at the Port of Ngqura was consulted and does not
have any objection to the project TNPA has indicated that the
development would require a minimum number of vessels per
year which would have minimal impact on the Port operations
However due notice would have to be given to the Port of Ngqura
before a vessel is scheduled to arrive so that the vessel can be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
3
IssueCommentQuestion Date
received Origin Response
accommodated at an available berth
5 Concerns with respect to potential stormwater pollution
draining into the Coega catchment and the port of Ngqura
The port needs to be dredged and heavy metals present a
risk in that regard
16052011
By
telephone
Andrew Lucas
(Department of
Water Affairs)
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination by effluent waste or
hazardousdangerous substances is very low
Thus no metals oils or other contaminants are expected to be
present in the stormwater
However stormwater pollution can occur in exceptional
circumstances such as accidents and emergencies The
emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
6 All steel sheets bathing unit must be under roof
7 The sludge out of the decreasing bath will be high in Na and
pH Therefore handling and disposal must be clarified up front
in this project
8 Per se the wastewater from decreasing bath will have high
ph and the component from the pickling unit will have low ph
Then it may be assumed that both streams will neutralize
each other Please then clarify proposed sewer discharge
with Nelson Mandela Bay Municipality up-front for acceptance
of influent as per the documented proposal
9 Pickling may result in dissolved metals How does your team
expect to deal with this As it is planned for discharge into
24052011
By email
Landile Jack
(Department of
Water Affairs)
All bathing units will be under roof
Effluent from the degreasing and pickling baths will be discharged
to the wastewater treatment plant The respectively alkaline and
acidic effluents will mix and neutralise each other in the
wastewater treatment plant Calcium or gypsum will be added if
required to complete the neutralisation process Effluent from the
treatment plant will be discharged to sewer Contact has been
made with the relevant officials and the Municipalityrsquos
requirements have been obtained The effluent discharged to
sewer will notably comply with the applicable discharge standards
Traces of metals (eg iron) may be present but will not exceed
prescribed thresholds The necessary authorisation will be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
4
IssueCommentQuestion Date
received Origin Response
sewer Clarity and acceptance needs to be agreed with
Nelson Mandela Bay Municipality Who owns the sewer
10 Quenching unit will results to Zinc particles How will this
affect sewer discharge This again must be dealt with within
the negotiations with the Municipality
11 Once all has been agreed with the Municipality and at the
same time due negotiations must be done with hazardous
waste courier and disposal facility to accept the hazardous
waste identified in all production lines
12 Of note is the low volume of the proposed WWTW facility ie
250 cubmweek And the no discharge of the quenching
water ie over-flow and cooling only Hence Zinc particles
generation
obtained from the municipality
The sludge from the treatment plant will be collected by a licensed
service provider and disposed of at a permitted site
The quenching bath will be periodically emptied (every 6 months)
and the water discharged will go to the water treatment plant Zinc
particles will settle in the sludge which will be disposed of at a
permitted site
Contact has been made with EnviroServ who manages the
Aloes II HH waste site regarding collection and disposal of
hazardous waste (See waste management report)
13 Investigate the potential effects of toxicity andor influence of
emissions waste and hazardous substances both in
terrestrial and marine fauna
14 With regards to water usage where is the plant going to
extract its waters used in galvanization andor waste
management process ie rainfall rivers or even from the
sea) and which avenues would be more environmental
friendly and effective
31052011
By email
A Bewana
(SANPARKS)
Emissions waste and hazardous substances are not expected to
affect terrestrial or marine ecosystems The air quality study
concluded that atmospheric emissions would not be harmful to
human health and by extension terrestrial fauna There are no
standards for air quality for defining faunal impacts therefore by
ensuring that standards for humans are complied with the impact
on fauna is deemed to be acceptable In this case the impact of
emissions on terrestrial and marine fauna are thus not significant
Solid and liquid wastes both general and hazardous as well as
hazardous substances will be stored handled and disposed of
appropriately to as not to cause harm to terrestrial or marine
fauna
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
5
IssueCommentQuestion Date
received Origin Response
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination and hence land-based
marine pollution by effluent waste or hazardousdangerous
substances is very low
The risk of emissions waste and hazardous substances to
terrestrial and marine fauna is thus very low
However pollution of terrestrial and marine ecosystems can occur
in exceptional circumstances such as accidents and emergencies
The emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
The CDC has an agreement with the NMBM to supply potable
water to the Coega IDZ Currently the infrastructure to supply
return effluent (RE) to the IDZ is not in place therefore Casa Steel
will be supplied with potable water up until such time as the
following 2 options of RE are available
1) Upgrading of the existing Fishwater Flats waste water
treatment works (between IDZ amp PE) including RE plant
and infrastructure to pipe RE to the IDZ (EIA for the
upgrade is underway)
2) Construction of a new waste water treatment works
including RE plant in Zone 9 of the Coega IDZ
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option should be investigated further between Agni and Casa The
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
6
IssueCommentQuestion Date
received Origin Response
CDC can facilitate discussions between the 2 investors
Compliance with CDC Permits amp Requirements
15 It should be made clear that tenants will be required to
comply with CDC requirements and the relevant conditions of
permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water
Licence for its Storm Water Systems on the
East Side of the Coega River that tenants will
need to take cognizance of The contents of the
ldquoIntegrated Stormwater Masterplan for the
eastern side of the Coega IDZ Oct 2010rdquo
especially the Table of best practice p53
onwards may need to be taken cognizance of
o CDC is developing an Operations
Environmental Management Plan that will place
certain obligations on tenants
16 Environmental audits and data collected during monitoring
(eg stack emissions stormwater) will need to be shared with
CDC
Air Emissions
17 Presumably permanent in stack monitoring will be required in
terms of AEL permit requirements
18 Abnormal operating conditions resulting in air emissions ndash I
could find nothing in the EIR to indicate under what
circumstances these could occur (eg start-up) potential
frequency and duration and the impact on ambient air quality
ndash these events usually result in the most problems wrt air
emissions
09042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
15 Compliance with the CDCrsquos Permits amp Requirements has
been included explicitly as a requirement in the EIR (p8-1) and
EMP (pp18 and 25) in the following terms
ldquoAs a tenant operating in the IDZ Casa Steel will be required to
comply with all current and future CDC requirements as well as
with the relevant conditions of permits licences issued to CDC
(eg Integrated Stormwater Masterplan for the eastern side of the
Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)rdquo
16 The need to communicate with the CDC on monitoring and
auditing activities was emphasised in Chapter 8 of the EMP The
following paragraphs were added
ldquoDuring construction the environmental officer will be responsible
for monitoring compliance with the EMP and authorisation
conditions and keeping records as required in the EMP andor
authorisation conditions
The ECO will conduct site inspections every two weeks audit the
records kept by the environmental officer and submit an
environmental compliance report every two months to the
authorities and the CDC (via the Environmental Monitoring
Committeersquos ECO)
During operation the health and safety officer will monitor
compliance with the EMP and the conditions of the Environmental
Authorisation Data collected during monitoring activities and any
environmental audits conducted will be shared with authorities
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
7
IssueCommentQuestion Date
received Origin Response
Water
19 Large volumes of (2000 m3mth) of water are required of
which only 400m3 needs to be potable The NMBM return
effluent system will provide non-potable water once it is
constructed What other water recycling initiatives can be
utilized to reduce potable water requirements (the ISWMP for
the eastern side of the Coega IDZ has some best practice
guidelines collecting rainwater from the roof etc)
General
20 There is no mention of how the CDC Architectural Guidelines
will be incorporated into the development (eg to prevent a
stark uniform warehouse type development)
21 Does NMBM have adequate fire services to cover this
development Apart from the large petroleum store are there
any other large fire hazards
22 Reports from the tenantrsquos ECO during construction and from
the SHE Officer during operations should be channeled to the
Coega Environmental Monitoring Committee This can be
directly or preferably via the EMCrsquos ECO (this will be while
the EMC and ECO are in place) A precedent has been set
for this in the Environmental Authorisations for Agni-Steel and
Kalagadi Manganese Smelter
23 All mitigation actions emanating from the EIR should be
summarized (preferably in a table) If compliance with them is
to be part of the Environmental Authorization from DEDEAT
then they (or the ones that DEDEAT deems to be applicable)
and the CDC (via the Environmental Monitoring Committeersquos
ECO)
The ECO (during construction) and the health and safety officer
(during operation) will report to the Coega Environmental
Monitoring Committee (EMC) via the EMCrsquos ECO (this will be
while the EMC and ECO are in place)rdquo
17 The draft EMP recommends regular monitoring of emissions
from the scrubbers and from the chromating process Additional
emissions monitoring requirements will be confirmed once the
AEL is issued Mention has been made in the EMP (pp11 and 19)
that all AEL conditions including monitoring and reporting
requirements should be adhered to
18 Abnormal emissions can occur in exceptional circumstances
Start-up will not cause abnormal emissions as the scrubbers
will be commissioned first and will be functioning once the plant
starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions
would be emitted as a building fugitive
The hourly hydrogen chloride ground level concentrations
(directly offsite) were predicted to be 239 microgmsup3 (based on the
emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits
as stipulated for listed activities for galvanising processes) using a
screen model which assumes worst case meteorological
conditions The health effect screening level for hourly HCl
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
8
IssueCommentQuestion Date
received Origin Response
should be attached to the EA as an Appendix (otherwise no
one knows about them or takes cognizance of them)
concentrations is 2100 microgmsup3 Assuming abnormal emissions
emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset
conditions will still be well within the health effect screening
levels
Similarly the hourly particulate emissions from the building
fugitives during upset conditions would amount to 293 microgmsup3
(based on the emission limits as stipulated for listed activities for
galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1
January 2015) directly off-site
Therefore if emissions are 5 times higher normal they will still be
within health effect screening levels and the daily PM10 NAAQS
levels
In the case of a fire a cocktail of gases and particulates could be
emitted and could be over the recommended levels This
situation will however be dealt with as an emergency and
normalised as quickly as is possible
The above has been added to the impact identificationdescription
and assessment sections of the EIR
19 The CDC has an agreement with the NMBM to supply
potable water to the Coega IDZ Currently the infrastructure to
supply return effluent to the IDZ is not in place therefore Casa
Steel will be supplied with potable water up until such time as the
infrastructure is in place
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
9
IssueCommentQuestion Date
received Origin Response
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option will be investigated further between Agni and Casa The
CDC has come forward to facilitate discussions between the two
investors
Other water recycling initiatives such as rainwater harvesting
have been considered but are not practical
20 The CDCrsquos Architectural and Landscape Design guidelines
contain requirements pertaining to such aspects as the height
orientation and mass and form of buildings as well as guidelines
for landscaping and signage in order to ensure an attractive
development and achieve an architectural integrity within the
Coega IDZ The plans for the proposed galvanizing plant will be
submitted to the Design Review Committee for approval as
required by the CDC
21 Casa Steel will be required to install fire hydrants according
to the NMBMrsquos standardsrequirements The CDC will provide
potable water (up until such time as return effluent is available)
and a connection to the boundary of the site which will be
connected to the fire hydrants The installation of the fire hydrants
will require approval by the Metrorsquos Fire Chief as was done for
Agni-Steel one of the investors in Zone 6
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
10
IssueCommentQuestion Date
received Origin Response
The Coega IDZ falls within the NMBM and therefore the rates and
taxes paid by the CDC covers the fire services for which the Metro
is responsible Currently the Metro has sufficient capacity to
provide fire services to the tenants within the IDZ This was
confirmed in discussion with the CDCrsquos Infrastructure
Development Unit It is however unknown at which point the
Metrorsquos Disaster Management Plan would not be able to
accommodate servicing tenants in the IDZ
The LNG burner is the only major fire hazard on the plant
22 See response to item 16 above
23 Key mitigation and management measures emanating from
the EIR were recapitulated in Chapter 9 of the EIR to form part of
the conditions attached to the Environmental Authorization from
DEDEAT All mitigation measures recommended as a result of the
impact assessment are presented in a table in the draft EMP
which is appended to the EIR (Appendix J)
24 Hydrogen chloride is one of the main emissions There are no
ambient air quality guidelines for HCl and the EIR says
concentrations will be well within health parameters
However the main problem with HCl is its corrosive effect -
there is absolutely no mention of this in the draft EIR nor air
specialist report
There needs to be some sort of comment assessment as to
whether HCl emissions are likely to impact on for example
the adjacent Agni-Steel Plant wrt corrosion - their factory
structure will be made of steel
11042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The atmospheric corrosion of metals is a complex process with
both the extent of deterioration and the mechanisms varying
considerably depending on the metal Depending on the way
pollutants are transported from the atmosphere to the corroding
surface two types of deposition processes are recognized in
atmospheric corrosion ndash dry deposition and wet deposition Wet
deposition refers to precipitation whereas dry deposition refers to
the remaining processes including gas phase deposition and
particle deposition The most important pollutants acting as
corrosive agents are sulphur and nitrogen compounds including
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
11
IssueCommentQuestion Date
received Origin Response
The EIR specialist rpt suggests monitoring HCl at ground
level on the property boundary and this is supported in case
there are complaints from neighbours
secondary pollutants and particulates Pollutants can contribute to
corrosivity individually however there may be a synergistic effect
when more than one of these pollutants is present in the
environment being affected In the field of atmospheric corrosion
sulphur dioxide is the single most investigated gaseous pollutant
and the quantification of the direct contribution of sulphur dioxide
to the corrosion process of metallic materials is comparatively well
understood (Tidblad amp Kucera 1998)
Very little work has reported on the effect of HCl on the
degradation of materials in the environment with no local dose-
response thresholds developed for corrosion occurring due to HCl
exposures This is probably because HCl which is present
outdoors in markedly reduced concentrations when compared
with SO2 has not been considered to contribute to significant
degradation of materials (Syed 2006) For this reason the
incremental corrosion due to HCl from the Coega Galvanising
Plant cannot be quantified
25 It is unacceptable for ILISO to be using CDC maps (see
figure 9 ndash pg5-6) without these maps being referenced
accordingly particularly when it appears that a CDC map has
been used and then overlaid with features by an unknown
author (ie CASA steel site Port (where the boundaries
depicted are incorrect) and a North legend which is out of
keeping with the overall cartographic intent of the original
work
26 Figure 10 is not referenced appropriately and I believe that I
commented previously in respect to references to roads not
12042012
By email
Graham Taylor
(Spatial
Development
Manager -
Infrastructure
Development
CDC)
This has been rectified in the final version of the report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
12
IssueCommentQuestion Date
received Origin Response
yet built As a result Figure 10 is confusing and clarity needs
to be provided in terms of referencing In addition the Port
shape is irregular and similar to the comment above
27 I acknowledge the emergency preparedness and response
plan but please confirm that this includes pro-active routine
monitoring of storm water leaving your premises to verify that
your assumptions of clean storm water are correct
13042012
By post
Andrew Lucas
(Director
WRampU
Department of
Water Affairs)
Pro-active routine monitoring of stormwater leaving the premises
will be undertaken This has been explicitly emphasised in
chapter 8 of the draft EMP
28 Will portablechemical toilets be used during construction
29 What provisions have been made for storm water drainage
during construction
18042012
By
telephone
Department of
Water Affairs
Port Elizabeth
Chemical toilets will be used during construction
The Casa Steel site will be located at the corner of two roads
drainage of stormwater from the site will take place through the
roadsrsquo drainage system
From Lea September [mailtoleailisocom]
Sent 11 March 2011 0935 AM
To Wayne Poulton
Cc Terry Baker
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Wayne
An Environmental Impact Assessment (EIA) will be undertaken for this project during the
next 10 to 12 months
We foresee that some of the key environmental impacts of the project will be in terms of air
quality water quality waste and hazardous substances
At this stage I am not able to give you any details regarding the potential toxicity of the
emissions andor effluent However specialist studies will be conducted as part of the EIA
that will determine the key impacts of the project Mitigation measures will also be identified
to avoid minimise or compensate any significant impacts
You are registered on the stakeholder database and you will be kept informed of progress in
the EIA process you will notably get the opportunity to access the reports produced and
provide any feedback on them
Please feel free to contact me should you need any further information
Best regards
Lea September
From Wayne Poulton [mailtowaynepbosuncoza]
Sent 07 March 2011 1257 PM
To Lea September
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
Please can you provide me with some more information as to the potential dangers including
the toxicity of this
Kind regards
Wayne
From Lea September [mailtoleailisocom]
Sent 04 March 2011 1123
To Lea September
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 March 2011 0745 AM
To Paul Martin
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 05 April 2011 0847 AM
To Paul Martin
Cc Terry Baker Renee von Gruenewaldt
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Thank you Paul for this information
I have downloaded a copy of the RoD and Scoping report you referred to and will make sure
these requirements are taken into account in the environmental assessment
Best regards
Lea September
From Paul Martin [mailtopmartinaxxesscoza]
Sent 04 April 2011 0955 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Further to my comments on 27311
Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in
the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega
IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised
scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions
including prohibiting and monitoring where possible visible emission plumes to the atmosphere
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Paul Martin
Sent Monday March 28 2011 745 AM
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 10 May 2011 0327 PM
To ElliotMotsoaholetransnetnet
Cc Terry Baker
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Mr Motsoahole
Thank you for your input on this issue
The Port of Ngqura will indeed be used for import and export At the moment the scope of
the traffic impact assessment only covers road traffic I have however relayed the matter to
our traffic specialist and we will consider this issue in the finalization of the Scoping Report I
will keep you informed of any developments in that regard
I trust this is acceptable to you
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]
Sent 10 May 2011 0855 AM
To Lea September
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
It has been noted that Casa Steel will source steel coils from various markets internationally and
in South Africa and the bulk of the plantrsquos production output will be exported to African countries
However there is no mention of logistic requirements
Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will
be used the scope of traffic impact assessment should also include the port
Regards
From Lea September [mailtoleailisocom]
Sent 04 May 2011 0747 AM
To Lea September
Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
Please find attached a letter announcing the EIA process underway for the proposed 80 000
tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as
a Background Information Document (BID) outlining the details of the project
Please contact me should you require any further information on this project
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
Elliot Motsoahole
Manager - Environment
Transnet National Ports Authority
Port of Nqqura
Port Control Building Klub Road Port Elizabeth 6212
PO Box 612054 Bluewater Bay 6212
+27 41 507 8450
+27 86 674 7729
Cell +27 83 542 5619
E-mail Elliotmotsoaholetransnetnet
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
DISCLAIMER The information contained in this communication is subject to copyright and
intended only for the use of leailisocom Unauthorised use disclosure or copying is
strictly prohibited Should a virus infection occur as a result of this communication the sender
will not be liable If you have received this communication in error please notify
elliotmotsoaholetransnetnet
From Lea September [mailtoleailisocom]
Sent 25 May 2011 1147 AM
To Jack Landile (ELS)
Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi
Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Landile
Thank you for your input
Contact has been made with the relevant Municipal Directorate and we will follow up with
them to obtain clarifications on all these issues
I have added both Lizna and yourself on the database and will keep you updated on
progress on this project
Best regards
Lea September
From Jack Landile (ELS) [mailtoJackLdwagovza]
Sent 24 May 2011 0524 PM
To Fourie Lizna (ELS)
Cc Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Hi Lizna
I missed you on this sorry
I linked Pieter twice Instead
Regards
Landile
From Jack Landile (ELS)
Sent 24 May 2011 0445 PM
To leailisocom
Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Lea
The e-mail you sent to Mr Kooverji dated 19 May 2011 refer
Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are
All steel sheets bathing unit must be under roof
The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project
Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal
Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer
Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality
Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines
Of note is the low volume of the proposed WWTW facility ie 250 cubmweek
And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles
generation
Regards
Landile
From Lea September [mailtoleailisocom]
Sent 19 May 2011 0947 AM
To Lea September
Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Stakeholder
Please find attached the remaining appendices to the draft Scoping report for the proposed
80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 June 2011 0411 PM
To Aphiwe Bewana
Subject RE Proposed 80 000 TPY Galvanizing plant in Coega
Dear Mr Bewana
Thank you for your input and apologies for the late reply
We have taken note of your comments and are will be taking them forward in the EIA phase
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Aphiwe Bewana [mailtoaphiwebewanagmailcom]
Sent 31 May 2011 1205 PM
To Lea September
Subject Re Proposed 80 000 TPY Galvanizing plant in Coega
Comment
Re Proposed 80 000 TPY Galvanizing plant in Coega
As SANParks we would like the EIA phase to investigate the potential effects of toxicity
andor influence of emissions waste and hazardous substances both in terrestrial and
marine fauna In the draft scoping report reference has been made with regards to the
terrestrial fauna but there is no attention to potential effects to marine fauna
Equally with regards to water usage where is the plant going to extract its waters used in
galvanization andor waste management process ie rainfall rivers or even from the sea)
and which avenues would be more environmental friendly and effective
Regards
Aphiwe Bewana
Marine Planner
South African National Parks
POBox 76693
NMMU
Port Elizabeth
6031
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 06 July 2011 1031 AM
To Lea September
Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Hi Lea
Irsquove reviewed the Final Scoping Report Herewith a few comments
1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the
Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a
revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the
NMBLP Please include only those in the IDZ as part of your IAP list
Regards
Andrea
From Lea September [mailtoleailisocom]
Sent Wednesday July 06 2011 859 AM
To Lea Septemberrsquo
Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Dear Stakeholder
The final scoping report for the above-mentioned project (attached) is available for comment
until 27 July 2011
The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic
commentaryrdquo tab
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 09 April 2012 1159 AM
To Lea September
Subject Comments on Galvanising Plant EIR Coega IDZ
Lea
Attached are my comments on the Draft EIR for the Coega IDZ galvanising
plant
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
Email attachment
COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ
Dr Paul Martin PO Box 61029
Bluewater Bay 6212 Tel 041 4665698
Email pmartinaxxesscoza
Compliance with CDC Permits amp Requirements
It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of
o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants
Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC
Air Emissions
Presumably permanent in stack monitoring will be required in terms of AEL permit requirements
Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions
Water
Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)
General
There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)
Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards
Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter
All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 11 April 2012 1245 PM
To Lea September
Subject Fw Comments on Galvanising Plant EIR Coega IDZ
Lea
One other comment on that I have on the Galvanising Plant Draft EIR
Hydrogen chloride is one of the main emissions There are no ambient air
quality guidelines for HCl and the EIR says concentrations will be well
within health parameters
However the main problem with HCl is its corrosive effect - there is
absolutely no mention of this in the draft EIR nor air specialist report
There needs to be some sort of comment assessment as to whether HCl
emissions are likely to impact on for example the adjacent Agni-Steel
Plant wrt corrosion - their factory structure will be made of steel
The EIR specialist rpt suggests monitoring HCl at ground level on the
property boundary and this is supported in case there are complaints from
neighbours
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Paul Martin ltpmartinaxxesscozagt
To Lea September ltleailisocomgt
Sent Monday April 09 2012 1158 AM
Subject Comments on Galvanising Plant EIR Coega IDZ
gt Lea
gt
gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising
gt plant
gt
gt
gt Dr Paul Martin
gt PO Box 61029
gt Bluewater Bay 6212
gt Tel 041 4665698
gt Cell 0732524111
gt email pmartinaxxesscoza
gt
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 12 April 2012 1139 AM
To Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Hi Lea
Hope yoursquore keeping well
I have requested comments from my colleagues and the CDC Casa team on the Draft EIR
Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report
Regards
Andrea
From Graham Taylor
Sent Thursday April 12 2012 838 AM
To Andrea Von Holdt Firhana Sam
Cc Johan Fourie Maria van Zyl Melikhaya Sihawu
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Andrea Firhana
Firhana if you could please ensure that the co-ordinates provided in the EIR correspond
with our records (pages 4-1 amp 4-2)
My comments are as follows
It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work
Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above
Regards
Graham Taylor
Spatial Development Manager - Infrastructure Development
Mobile 0832283055
Office 0414030454
Facsimile 0865185033
Email GrahamTaylorcoegacoza
Website wwwcoegacom
right PLACE | right TIME | right CHOICE
This email and all contents are subject to the following disclaimer
httpwwwcoegacomemaildisclaimerhtml
From Lea September [mailtoleailisocom]
Sent 04 May 2012 0411 PM
To Andrea Von Holdt
Cc Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Dear Andrea
We have taken note of the comments from the GIS Unit These issues have been rectified in
the final version of the EIR
Please can you forward to the relevant persons at the GIS Unit
Thank you
Best regards
Lea September
APPENDIX E
BACKGROUND INFORMATION
DOCUMENT
APPENDIX F
AIR QUALITY IMPACT ASSESSMENT
APPENDIX G
TRAFFIC IMPACT ASSESSMENT
APPENDIX H
WASTE MANAGEMENT AND HAZARDOUS
SUBSTANCES SPECIALIST STUDY
APPENDIX I
WATER QUALITY SPECIALIST STUDY
APPENDIX J
ENVIRONMENTAL MANAGEMENT
PROGRAMME
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-3
15 PROJECT TEAM
In addition to Terry Baker the ILISO project team consists of Dr Martin van Veelen
(water quality specialist) and Lea September (EAP) with specialist input from Renee
von Gruenewaldt (Air Quality) Pieter Smuts (waste management and hazardous
substances) and Seniel Pillay (Traffic Impact Assessor)
The Business Unit Head of the ILISO Environmental Management Discipline Group
Dr Martin van Veelen is a Professional Engineer with a PhD in aquatic health He is
a Fellow of the South African Institution of Civil Engineers a member of the South
African Society of Aquatic Scientists of the Environmental Scientific Association of
the International Water Association of the Water Institute of South Africa and of the
Vaal River Catchment Association He is a certified Environmental Assessment
Practitioner with 30 years experience who specialises in project management
environmental impact assessments and water resource planning He specifically has
extensive experience in water quality especially water quality management water
quality monitoring and water quality assessment Martin has experience in managing
projects that involve multi-disciplinary teams and public consultation and
participation in South Africa and abroad
Lea September is an Environmental Assessment Practitioner with a Masters degree
in Environmental Management She has experience in impact assessment and
environmental management and has been responsible for drafting impact
assessment reports and Environmental Management Programmes and conducting
public participation processes as well as high level environmental screenings for a
variety of projects in the energy water transport and industrial sectors
Renee von Gruenewaldt has nine-years experience in the field of air pollution
impact assessment and air quality management Prior to becoming involved in air
quality consultation she was part of the Highveld Boundary Layer Wind Research
Group based at the University of Pretoria Since joining Environmental Management
Services (the company now Airshed Planning Professionals) she has undertaken
numerous air pollution impact studies and has provided extensive guidance to both
industry and government on air quality management practices
Pieter Smuts graduated as a Civil Engineer and became involved in the field of
municipal engineering and infrastructure construction He has specialized during the
last twelve years in solid waste management He has completed waste management
plans feasibility studies and final designs of waste management facilities in South
Africa and abroad He was also responsible for drafting the EMP (part of the EIA) and
the review of the Mavoco hazardous waste landfill design in Maputo Mozambique
and completed a study on hazardous waste (textile factory sludge) management in
Maseru Lesotho
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 1-4
Seniel Pillay is a transportation engineer with over 16 years experience in
transportation planning and traffic engineering He has been involved in a wide
range of projects ranging from developing the Transport Operations Plan for the
FIFA WC2010 SATM for Durban the Inner City Public Transport Distribution System
for Durban and the Bloemfontein Airport Precinct Transportation Plan to smaller
traffic impact assessments for inter alia road improvement schemes Of particular
relevance to this project his experience includes Heavy Goods Vehicle Study for
eThekwini Municipality VOPAK Terminal Durban Efficiency Project ndash Traffic Impact
Assessment Proposed Dig-out Port at the old Durban International Airport Site ndash
Preliminary Transportation Assessment
16 STRUCTURE OF THIS REPORT
The proposed project and the alternatives considered are described in Chapter 2
Chapter 3 details the approach adopted for the EIA phase
The biophysical and socio-economic environment affected by the activity is described
in Chapter 4
The environmental impacts identified are discussed in Chapter 5
The EIA methodology is described in Chapter 6 and Chapter 7 presents the results
of the impact assessment
The environmental impact statement is presented in Chapter 8
Finally Chapter 9 spell out the conclusions and recommendations
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-1
2 DESCRIPTION OF THE PROPOSED PROJECT
21 TECHNICAL ASPECTS
211 The galvanizing process
Galvanizing consists of coating steel with zinc in order to protect it from corrosion
Before steel strips can be galvanized they undergo a pre-treatment in order to
ensure that the steel sheets are free from any surface oxides as they enter the
molten zinc coating Bath This is done by removing the oil from the steel sheets (in
the degreasing unit) and then removing the rust from the surface of the sheet (in the
pickling unit)
The sheets are then dipped into a zinc bath (450degC to 460degC) to be galvanized The
melting zinc on the strip surface will be cooled and solidified through air cooling in the
cooling tower
Finally the galvanised steel sheets are dipped into a water quenching tank in order to
further cool the sheets from about 150degC to 40degC
It is possible to make galvanised steel more durable by chromating it Approximately
50 of the galvanised steel production output will receive chromate passivation
treatment after quenching the galvanised steel sheets will be sprayed with a chrome
solution (3 kgcm2)
After galvanizing and chromating the steel sheets are cut to achieve the desired coil
size and weight and transported to the storage yard
The process flow diagram below (Figure 1) illustrates the main stages of the
galvanizing process and indicates the major inputs and outputs as well as the
resulting effluent and atmospheric emissions
Draft Environmenal Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-2
Figure 1 Process flow diagram for proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 2-3
212 Main inputs and outputs in operational phase
In view of the above the main inputs will be as follows
Steel coils 85 000 tonsyear
Zinc 870 tonsyear
Electricity 2500 kVA
Water 2000 m3month (of which 400 m3 will be potable water)
Liquid Natural Gas (LNG) 270 NM3hour
Sodium hydroxide (NaOH) 1000 m3year
Hydrochloric acid (HCl) 800 m3year
Chrome (Cr+3) 10 m3year
The main outputs will be
Galvanized steel 80 000 tonsyear
Scrap metal 20 tonsyear
General waste 65 tonsyear
Hazardous waste 2 m3month
Wastewater 012 Mlweek
Atmospheric emissions lt 5 ppm
213 Installations on site
The bulk of the operations involved in the galvanizing process occur along a
continuous galvanizing line (See Figure 2 below) which is the main piece of
machinery required for the proposed galvanising plant
Figure 2 Continuous Galvanizing Line
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-4
Water is one of the major inputs and is used throughout the galvanizing process notably
for rinsing and cooling purposes and as a mixing agent for the various chemical
solutions The plant will have a water treatment plant on site to treat the water used in
the various processes (approx 250 m3
of wastewater per week) The wastewater
treatment facility will be operated by a professional water treatment company as Casa
Steel does not have the required expertise in house to treat its process water Sulphuric
acid (H2SO4) is used as part of the treatment process to reduce caustic soda The
neutralised water is discharged to the sewer while any sludge is disposed of as
hazardous waste It is estimated that 2 m3month (10 tons) of hazardous waste (liquid)
will be disposed of
Some critical areas of the galvanizing process such as the zinc pot require uninterrupted
power It is therefore proposed to install an LNG burner to maintain the zinc bath at a
temperature of between 450 and 460degC
22 LOCATION OF THE PROPOSED GALVANIZING PLANT
The proposed Galvanising Plant is located in the Coega IDZ about 23 km northeast
of Port Elizabeth in the Eastern Cape (Figure 3)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-5
Figure 3 Location of the proposed galvanizing plant
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-6
23 NEED AND DESIRABILITY
The profitability of the proposed project has been established by Casa Steel and a
pre-feasibility study has confirmed that the proposed project was feasible from a
technical and financial point of view The Coega IDZ is specifically designed to host
facilities such as a galvanizing plant and can provide the necessary infrastructure
and services to its investors It therefore constitutes a very suitable location for the
project
24 ALTERNATIVES IDENTIFIED
Zone 6 has been specifically earmarked for heavy ferrous metal industries and is
therefore a suitable location for the proposed galvanizing plant as such no site
alternatives have been provided for and assessed in this EIA However prior to the
commencement of the EIA process Casa Steel was presented with a number of
different sites to choose from in Zones 5 and 6 of the IDZ The main criteria in the
selection of the site were
(a) The dimensions of the land the site should be at least 200 m long and
50 m wide in order to accommodate the galvanizing line and adjacent lay
down area and additional land should be available next to the site for future
expansion
(b) The fiscal arrangements applying to the site the site should be located
within the future Custom Controlled Area (CCA) as the bulk of the
production output of the plant will be exported
The no-go alternative is assessed in this report
25 CONSTRUCTION ASPECTS
The construction phase of the project will take about 12 months and will essentially
consist of erecting a building to house the galvanizing line and other equipment and
preparing a concrete laydown area adjacent to the building
The CDC will provide an access point from the existing tarred road that will lead to
the site
Approximately 100 workers from the surrounding areas will be contracted for the
construction work
The requirements in terms of services during construction are listed below
Water 1000 m3month
Electricity 2500 kVA
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 2-7
The CDC will provide temporary services for the construction phase including a
conservancy tank for flush toilets Sewage infrastructure will only be provided for the
operational phase
26 OPERATION ASPECTS
Before the plant can become fully operational the equipment and machinery will be
tested for approximately 3 months The supplier will supervise these tests as part of
the transfer of know-how and training of staff on the plant
Casa Steel will start operating the plant at a reduced capacity (about 50 000
tonsyear) for a period of time (mostly determined by market aspects) before bringing
production to full capacity (80 000 tonsyear) This is done by operating the line for
longer hours
Approximately 50 to 60 people will be working on the plant Approximately 6-10 of
these will be unskilled 40-45 skilled and about 5 people in managerial positions
The requirements in terms of services during operation are as follows
Water 2000 m3month
Electricity 2500 kVA
Effluent discharge 24 m3day
The CDC has entered into agreements with the municipality to secure the provision
of services such as water and electricity to its tenants Tenants in the IDZ have their
own agreements with the NMBM for electricity while the agreements for water and
sewage are with the Facilities Unit of the CDC
Regarding discharge of wastewater to the sewer the municipality indicated that the
only requirement is that the water discharged complies with applicable municipal
discharge standards
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 3-1
3 APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMEMENT
31 OBJECTIVES
The main objectives of the EIA phase are to
Assess the significance of the environmental issues and impacts identified in the
scoping phase focusing on key impacts
Recommend appropriate measures to mitigate negative impacts and enhance the
benefits and include them in the draft EMP
Undertake a public participation process that provides opportunities for all
interested and affected parties (IampAPs) to be involved
32 AUTHORITY CONSULTATION
The Final Scoping Report was presented in August 2011 to the lsquoEnvironmental
Liaison Committeersquo (ELC) which comprises representatives of various authorities
including DEDEAT the Department of Environmental Affairs (DEA) and Department
of Water Affairs (DWA) as well as the Nelson Mandela Bay Municipality (NMBM) the
Coega Development Corporation (CDC) and Transnet National Ports Authority
(TNPA) The ELC has been specifically formed to facilitate EIA applications in the
IDZ
Authorities indicated that activity 14 of Listing Notice 3 (GN 546 of 2010) relating to
the clearance of vegetation should be included in the application A formal request
was sent to DEDEAT on 6 October 2011 to add the aforementioned activity to the
application and all registered stakeholders were informed of the request in writing on
19 October 2011
33 PUBLIC PARTICIPATION PROCESS CONDUCTED
On-site notices were replaced by a notification displayed on the CDCrsquos digital notice
board at the business centre in Zone 1 of the IDZ The eNotice was placed on
13 April 2011 and will remain for the full duration of the EIA process
Registered stakeholders will be notified in writing of the availability of the draft EIA
report and EMP which will also be advertised in a local newspaper Stakeholders
including state departments and the public will have forty (40) days to comment on
the draft EIA report and EMP The draft EIA report and EMP will be sent by email
where possible and made available for download on the ILISO website
(wwwilisocom)
A summary of all issues and comments received during the stakeholder consultation
process as well as of correspondence in that regard will be captured in an Issues
and Responses Report that will form an Appendix to the EIA Report
The list of registered IampAPs is included in Appendix A
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 3-2
34 LEGISLATION AND GUIDELINES CONSIDERED
The following legislation and guidelines were considered in the preparation of this
report
National Environmental Management Act Act No 107 of 1998
NEMA EIA Regulations 2010
National Environmental Management Air Quality Act Act No 39 of 2004
National Environmental Management Waste Act Act No 59 of 2008
Hazardous Substances Act Act 15 of 1993
Occupational Health and Safety Act Act 85 of 1993
Hazardous Chemical Substances Regulations 1995 (GNR 1179)
Major Hazard Installation Regulations 2001 (GNR 692)
National Water Act Act 36 of 1998
National Heritage Resources Act Act 25 of 1999
DEAT Integrated Environmental Management Information Series 1-5 and 12-15
NEMA draft Implementation Guideline
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Public Participation (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Guideline on Alternatives (2007)
Western Cape Department of Environmental Affairs and Development Planning
NEMA Environmental Impact Assessment Regulations Guideline and Information
Document Series ndash Draft Guideline for Determining the Scope of Specialist
Involvement in EIA Processes (2005)
IAIA guidelines
National air quality standard for thoracic particulates Government Gazette
No 32816
Listed activities and associated minimum standards identified in terms of section
21 of the National Environmental Management Air Quality Act Act No 39 of
2004 Government Notice 248 of 2009
Minimum Requirements for the Handling Classification and Disposal of
Hazardous Waste DWAF Waste Management Series (1998)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-1
4 DESCRIPTION OF THE AFFECTED ENVIRONMENT
41 LOCATION OF STUDY AREA AND PROPERTY DESCRIPTION
The proposed galvanizing plant will be built on a 91 ha site in Zone 6 of the Coega
IDZ (Figures 4 and 5) Zone 6 is situated approximately 35 km inland of Algoa Bay
to the north of the N2 highway between Port Elizabeth and Grahamstown east of the
Coega River
The co-ordinates of the corners of the site are shown in Table 1
Table 1 Coordinates of site corners for the proposed galvanizing plant
Point Longitude Latitude
A 25deg411126E 33deg45587S
B 25deg411156E 33deg45499S
C 25deg411938E 33deg45131S
D 25deg412174E 33deg45481S
E 25deg412508E 33deg45979S
F 25deg412634E 33deg451160S
G 25deg411782E 33deg451560S
H 25deg411692E 33deg451428S
J 25deg411314E 33deg45868S
Figure 4 Zone layout in the Coega IDZ
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-2
Figure 5 Site location
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-3
42 SOCIO-ECONOMIC CHARACTERISTICS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of the
NMBM There are no residents within the IDZ
As far as the broader NMBM and Eastern Cape Province are concerned the
following can be noted The NMBM is located within the Eastern Cape Province the
2nd largest Province in South Africa (3rd in terms of population) characterised by a
predominantly black population with low incomes and high levels of unemployment
(CES 2010)
The NMBM has a population of just above 11 million and covers an area of
1 950 km2 It is the main urban and industrial centre of the province and Port
Elizabeth in particular which forms part of the NMBM is the commercial capital of
the Eastern Cape 52 of the NMBM population is female and 37 is below the
age of 20 these two groups are particularly affected by unemployment
43 BIOPHYSICAL CHARACTERISTICS
431 Surface and ground water
No rivers occur in Zone 6 There is however a natural attenuation pond on the
southern most part of the site which will have to be avoided
The IDZ is underlain by calcrete sand and gravel deposits that overlie low
permeability clays These clays limit the vertical infiltration of rainwater and induce a
horizontal groundwater flow towards the Coega River channel which is the most
significant surface water feature in the Coega IDZ Consequently rapid run-off takes
place following precipitation (Jacobs 2008)
Groundwater levels at Coega are generally about 3 to 5 m below surface ie just
above the contact between the permeable sands and the underlying impermeable
clays The groundwater flow direction is to the southeast following the surface water
drainage direction (Jacobs 2008)
432 Climate and atmospheric conditions
Port Elizabeth has a warm temperate climate and the temperature ranges are not
extreme Exceptionally high temperatures may be experienced during berg wind
conditions which occur frequently during autumn and winter Extreme temperatures
also occur during summer with little accompanying wind
The wind regime for the area largely reflects the synoptic scale circulation with
dominant westerly and northwesterly flow fields representing the pre-frontal
conditions and south-westerly flow fields representing the frontal conditions The
south-easterly and south-westerly wind flow (land breeze) increases during daytime
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-4
conditions with westerly and north-westerly wind flow increasing during the night (sea
breeze)
The sensitive receptors in the vicinity of the proposed Galvanising Plant consist of
Motherwell (~10 km southwest) KwaZahele (~15 km southwest) New Brighton (~15
km southwest) and Port Elizabeth (~23 km southwest)
An ambient air monitoring network has been established in the Coega IDZ which
consists of three monitors Saltworks Motherwell and Amsterdamplein Although
NO2 SO2 and PM10 are monitored the only pollutant of interest for cumulative
impacts due to the proposed Galvanising Plant is PM10 A maximum daily average
PM10 concentration of 277 μgmsup3 was recorded on 27 September 2008 The proposed
SA standard only allows for 4 days of exceedance per calendar year The 75 μgmsup3
was exceeded on 17 days in 2007 and 26 days in 2008
Existing sources of emissions in the vicinity of the proposed galvanizing plant include
industrial emissions biomass burning (veld fires) vehicle exhaust emissions and other
fugitive dust sources (von Gruenewaldt 2011b)
433 Geology and soils
Zone 6 is underlain by Tertiary Bluewater Bay Formation (T-Qb) alluvial sheet gravel
and sand underlain by Tertiary Alexandria formation calcareous sandstone shelly
limestone and conglomerate
434 Terrestrial ecology
This section draws from the EIA report compiled for the Agni Steel (formerly Afro-
Asia) steel processing facility which is adjacent to the proposed site for the
galvanizing plant (Jacobs 2008)
The area consists largely of grasses succulents and scrubby bush with alien
species making up the greater part of the more dense vegetation
Zone 6 falls within the inland vegetation and is characterised by a vegetation type
referred to as Grassridge Bontveld Bontveld occurs on the crests or plateaus in the
Coega IDZ and has been found to have three times the level of endemism of other
vegetation communities in the Coega IDZ Bontveld therefore has a high
conservation status Two Bontveld conservation areas have been identified within the
IDZ in terms of the CDCrsquos Open Space Management Plan (OSMP) (Figure 5)
Bontveld that will be destroyed as a result of development in the IDZ will be given
conservation status in these two areas
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-5
Figure 6 Coega IDZ Open Space Management Plan (OSMP)
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 4-6
Certain areas in the IDZ are invaded by alien plant species The most common
invader species is rooikrans (Acacia cyclops) which presently forms large
monospecific stands in areas throughout the Coega IDZ There are several other
aliens present that pose a threat to the flora of this area including the prickly pear
(Opuntia ficus-indica) and the long-leaved wattle (Acacia longifolia)
Loss of vegetation and alien plant invasion due to human activity has resulted in a
reduction in the diversity of terrestrial fauna
The majority of mammals present in the Coega IDZ are small or medium-sized Of
the 63 mammal species expected to occur in the Coega IDZ the pygmy hairy-footed
gerbil (Gerbillurus paeba exilis) is the only species endemic to the coastal regions of
Algoa Bay however it is not considered threatened The gerbil is common in
foredune and dune thicket habitat in the Coega region and is therefore unlikely to
occur on the proposed site
A diverse avifauna exists in the IDZ because of its varied habitats Over 150 bird
species are resident or common to the area Most diversity occurs in the thicket
although the coastal area also supports specialised avifauna Two species of tern
the Roseate tern (Sterna dougalli) and the Damara tern (Sterna balaenarum) as well
as the Cape gannet (Morus capensis) and the African penguin (Spheniscus
demersus) are either endangered or vulnerable while the Caspian tern (Hydroprogne
caspia) Chestnutbanded plover (Charadrius pallidus) Cape cormorant
(Phalocrocorax capensis) and the Greater (Phoeniconaias ruber) and Lesser
flamingos (Phoeniconaias minor) are near threatened Roseate and Damara terns
are two of the most endangered coastal species in South Africa Other bird species
of conservation concern include the Whitefronted plover (Charadrius marginatus)
African black oyster catcher (Haematopus moquini) Martial eagle (Polemaetus
bellicosus) Stanleyrsquos bustard (Neotis denhami) African marsh harrier (Circus
ranivorus) Secretary bird (Sagittarius serpentaris) and the Blue crane (Anthropoides
paradisea) Breeding pairs of Damara terns and African black oyster catchers have
been observed in the coastal dunes of the IDZ but should not be affected by
developments that fall outside the dune areas
The Eastern Cape supports nearly a third (approximately 133 species) of the reptile
species recorded in South Africa More than half of the Eastern Capersquos endemic
reptile species occur in the Algoa Bay area giving the region a high conservation
value A total of 63 reptile species are believed to occur within the Coega IDZ The
majority of these are found in Succulent Thicket and riverine habitats Only a few
reptile species occur in the coastal dunes and estuarine habitats More than a third of
the species are described as relatively tolerant of disturbed environments provided
that migration corridors of suitable habitat are maintained to link pristine habitats
Twenty two reptiles are of special concern including five endemic species (two of
which may also be endangered) four endangered sea turtles eight species listed
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-7
with CITES one rare species and four species at the periphery of their range
Fourteen of these species of special concern are confirmed as occurring on or within
2 km of the Coega IDZ
A total of 32 amphibian species and sub-species occur in the Eastern Cape
representing almost a third of the species recorded in South Africa However none of
the species are endemic or Red Data Book species Based on previous studies in the
area it is estimated that approximately 17 amphibian species occur within the Coega
IDZ Four species are listed as peripheral but none are threatened internationally
These include the Natal puddle frog (Phrynobatrachus natalensis) the bullfrog
(Pyxicephalus adspersus) the yellow-striped reed frog (Hyperolius semidiscus) and
the bubbling kassina (Kassina senegalensis)
The invertebrate fauna of the coastal dunefields of Algoa Bay and its associated
vegetation has not been extensively studied One grasshopper species Acrotylos
hirtus is endemic to the dunefields Three rare butterfly species the Wineland Blue
(Lepidochrysops bacchus) and two small coppers Aloeides clarki and Poecilmitis
pyroeis hersaleki are known to occur in the Coega IDZ The Wineland Blue occurs in
four localities in the Eastern Cape one of which is within the Coega IDZ The Coega
copper Aloeides clarki is endemic to this particular region of the Eastern Cape and
is currently known to occur in three localities two of which are in the Coega IDZ The
localities of Lepidochrysops bacchus and Aloeides clarki have been mapped in the
Coega IDZ and their distributions were taken into account when defining Coegarsquos
open space system and Development Framework Plan
435 Land use and topography
The land is currently undeveloped and earmarked for industrial development The
site is relatively flat ranging from an elevation of 66 masl on the northern-most
corner to 59 masl at the southern-most corner
436 Heritage and archaeological survey
Extensive studies have been undertaken in Zone 6 with respect to heritage aspects
Three HIArsquos were conducted in this zone by Webley (2007) and Kaplan (2008a
2008b) In addition a HIA for the whole IDZ covering palaeontological (Almond
2010) archaeological (Binneman 2010) and historical (Bennie 2010) aspects is
currently being finalised
Webleyrsquos survey for the Agni Steel (formerly Afro-Asia) Recycling and Processing
Facility which is adjacent to the proposed galvanizing plant site covered some 6 ha
in extent and was located next to the R102 road to Motherwell Kaplan conducted
HIArsquos for the Exxaro Alloystream Manganese Plant (15 ha) and the Kalagadi
Manganese Smelter (160 ha) (which was initially accommodated in Zone 6 but will
now be located in Zone 5)
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 4-8
The various archaeological investigations reached similar observations and
conclusions Stone tools of various densities and types were found throughout the
zone The majority of the stone tools were mainly of Earlier and Middle Stone Age
and occasional Later Stone Age origins (Figure 4)
Figure 7 Earlier and Middle Stone Age stone tools found in the cobblepebble
gravels exposed by tracks in Zone 6 (Source Binneman 2010)
The stone tools which comprised of quartzite flakes chunks flaked pebblecobble
and cores were randomly distributed across the landscape and are in secondary
context There were no lsquoconcentrationsrsquo of tools observed which suggested any
spatial patterning or activity areas although these may be present or covered by soil
and vegetation
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 5-1
5 DESCRIPTION OF ENVIRONMENTAL IMPACTS IDENTIFIED
The following environmental issues and potential impacts were identified in the
Scoping phase
51 AIR QUALITY
The galvanizing process generates atmospheric emissions with particulates and
hydrogen chloride representing the main pollutants of concern The plant is fitted with
air extraction as well as scrubber systems which are designed to retain the bulk of
pollutants and particles for each of the processes in such a way that less than 5 ppm
of gases and particles will be released into the atmosphere after the fume scrubber
Other sources of impact on air quality include emissions from the LNG burner as well
as emissions and dust from the transport of steel and other materials in trucks
Construction activities will also create dust and gas emissions due to the clearing of
groundcover tipping of material to storage pile levelling of area wind erosion from
storage piles vehicle and construction equipment activity and tailpipe emissions
from vehicles and construction equipment such as graders scrapers and dozers
Overall the air quality impact assessment (Gruenewaldt 2011b) found that
The predicted particulate oxides of nitrogen carbon monoxide and sulphur
dioxide concentrations are all below the National Ambient Air Quality Standards
for all averaging periods
The predicted off-site concentrations of hydrogen chloride are well below the
most stringent effect screening levels
No odour threshold exceedances for hydrogen chloride were predicted to occur
due to routine operations at the Steel Galvanising Plant The South Wales
Environmental Protection Authority stipulates that an odour unit of 20 is
acceptable for urban areas The odour unit would be lt10 directly off-site for
hydrogen chloride
Abnormal emissions can occur in exceptional circumstances Start-up will not
cause abnormal emissions as the scrubbers will be commissioned first and will be
functioning once the plant starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions would be emitted as a
building fugitive
The hourly hydrogen chloride ground level concentrations (directly offsite) were
predicted to be 239 microgmsup3 (based on the emissions of 5 ppm) and 868 microgmsup3 (based
on the emission limits as stipulated for listed activities for galvanising processes)
using a screen model which assumes worst case meteorological conditions The
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-2
health effect screening level for hourly HCl concentrations is 2100 microgmsup3 Assuming
abnormal emissions emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset conditions will still
be well within the health effect screening levels
Similarly the hourly particulate emissions from the building fugitives during upset
conditions would amount to 293 microgmsup3 (based on the emission limits as stipulated for
listed activities for galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1 January 2015) directly
off-site
Therefore if emissions are 5 times higher normal they will still be within health effect
screening levels and the daily PM10 NAAQS levels
In the case of a fire a cocktail of gases and particulates could be emitted and could
be over the recommended levels This situation will however be dealt with as an
emergency and normalised as quickly as is possible
52 HERITAGE AND ARCHAEOLOGICAL ASPECTS
The various HIAs conducted in the IDZ did not identify Zone 6 as sensitive in terms of
its heritage potential and there are no proposed protected geosites in Zone 6
Should any artefacts be discovered during construction procedures stipulated in the
draft EMP will apply
53 BIODIVERSITY AND CONSERVATION
Certain types of vegetation in the IDZ are of high conservation importance and the
CDC has compiled a list of protected species to be rescued
In terms of terrestrial fauna the CDCrsquos open space management plan provides for
the preservation of certain corridors The destruction of certain habitats as a result of
the development will therefore not automatically result in the loss of certain species
54 WATER QUALITY
There is a natural attenuation pond on the southern most part of the site which will be
avoided
The substances used in the galvanizing process and the effluent resulting from it are
potentially hazardous and can cause the contamination of water resources through
spills or leaks
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-3
This risk can however be minimized if not avoided altogether The floor of the factory
will be designed as a bunded area to contain any spills and the entire process will be
contained Potential spills or leaks will therefore be contained and will not impact on
water resources Storm water is therefore considered clean water under normal
operational conditions An oil trap will be placed at the exit of the site to ensure that
no grease from the laydown area enters the stormwater system
Spills and leaks can occur during the handling or the transport of hazardous
substances Best practice guidelines will be followed to ensure that this risk is
adequately managed
Wastewater discharged to sewer will be treated to comply with municipal discharge
standards and is not expected to have an impact on the chemical characteristics of
the sewage In terms of volume the 24 m3 (0024 Mℓday) that is expected to be
discharged from the plant is small in relation to the total volume received at the
Nelson Mandela Bay Municipalityrsquos Fishwater Flats Waste Water Treatment Works
(WWTW) The Fishwater Flats WWTW is designed for 132 Mℓday and is currently
operated at 61 of its capacity which is approximately 80 Mℓday Thus the
0024 Mℓ makes up 003 of the effluent that reaches the WWTW and will therefore
not have any significant impact on the WWTW
Periodic effluent and stormwater quality monitoring will be undertaken to ensure
compliance with the applicable standards
55 WASTE MANAGEMENT AND HAZARDOUS SUBSTANCES
The plant will generate a relatively small amount of solid waste in the form of scrap
metal (approx 20 tonsyear) and general domestic waste (approx 65 tonsyear)
The scrap metal may be sold to other steel processing facilities such as Agni Steel
which will be located next to the plant or collected and disposed of with the rest of
the solid waste by a licensed service provider
As mentioned previously there will be a wastewater treatment plant on site which will
neutralise process water (012 Mlweek) in order to ensure it is of a standard
acceptable for discharge to sewer Waste in the form of sludge from the
neutralization or spent acid must be disposed of as a hazardous waste Solid waste
from the filters used for air quality control is also in this category These wastes can
usually be tested and then delisted which means that it can be placed in a general
purpose landfill
Hazardous effluent from the galvanizing and chromating processes (approx
10 tonsmonth) will be collected by a licensed service provider to be disposed of off-
site at Aloes II Hazardous landfill site The volume of hazardous waste to be stored
and removed on a monthly basis is limited to 10 m3
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-4
A number of substances classified as hazardous are used in the galvanizing process
(Table 2) and the transport and handling of these is subject to certain rules and
guidelines In particular the material safety data sheets (cf Appendix H) should be
referred to for inter alia hazards identification accidental release measures
handling and storage precautions exposure controlpersonal protection ecological
information and transport information The Hazardous Chemical Substances
Regulations 1995 should also be adhered to in respect of the transport and storage
of hazardous chemical substances
Table 2 Hazardous materials to be used on site
Major Input Materials
Substance
listed in the
SABS 0228
Group II
hazardous
substances
Volumes to be
stored on site at
any one time
Diesel radic 2000 litres
Liquid petroleum radic 20 000 liters
Sodium hydroxide (NaOH)
(used for degreasing) 8 radic 1000m
3
Hydrochloric acid (HCI)
(used for pickling) 8 radic 800m
3
Zinc (used for galvanising) - TBD
Trivalent chromium (CR+3
)
(used for chromating) 8 radic 10m
3
Sulphuric acid (H2SO4) (used for
treatment of waste water on site) 8 radic TBD
Ammonium Hydroxide (NH4OH) 8 radic TBD
TBD ndash To be determined
Liquid Petroleum is stored in great quantities (20 000 litres stored on site at any one
time) and is classified as a flammable substance Specification for flammable storage
facilities in accordance with the requirements of the Nelson Mandela Bay
Metropolitan Municipalityrsquos Fire and Emergency Services Department dictates that for
quantities between 5000 and 20 000 liters the substance must be kept in a
flammable liquid store which complies with the requirements of a specification
obtainable from the Department Some of the requirements are
Flammable liquid and solid storage facilities are only permitted on the ground
floor
Decanting of flammable liquids and solids are not permitted within any building
Due to the fact that there are flammable materials on site a certificate may be
required from Nelson Mandela Bay Metropolitan Municipalityrsquos Fire and
Emergency Services Department to confirm that facilities for flammable storage
are in accordance with their requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-5
Because of the permanent installation and high quantity of liquid petroleum on site
the Major Hazard Installation Regulations 2001 promulgated under the Occupational
Health and Safety Act No 85 of 1993 applies A written application for approval of
the installation is required to be submitted to the chief inspector Department of
Labour provincial director Department of Labour and NMBM prior to construction
In addition a risk assessment should be formulated covering all hazardous materials
together with an emergency preparedness and response plan
56 HEALTH AND SAFETY
Several aspects of the galvanizing process present potential risks for the health and
safety of workers on site The handling of dangerous substances and the operation of
the equipment of the plant for instance present risks that should be prevented and
managed adequately in order to ensure the health and safety of workers on site
Storage transport and handling instructions as well as occupational exposure limits
are indicated in the material safety data sheets of the various substances used
Insofar as the operation of plant equipment and machinery is concerned the supplier
will provide quality control methods and standard operating procedures prepare
operation and maintenance manuals and train the staff in that regard as well as
provide site supervision including executing tests (individual test cold run and hot
run) during 3 months
New staff members will undergo induction and awareness training to sensitize them
about the environmental health and safety risks on site and the contents of the
EMP
In addition the emergency preparedness and response plan will cover the health and
safety aspects related to emergency situations
57 TRAFFIC
The volumes of traffic at the IDZ are currently relatively low and variable depending
on the different zones in the IDZ however these volumes will increase as more
developments are implemented
The construction phase of the Casa Steel development will take about 12 months
and will essentially consist of erecting a building to house the galvanizing line and
other equipment and preparing a concrete laydown area adjacent to the building
The traffic that would be generated during the construction phase can be expected to
be less than the traffic that would be generated by the Casa Steel development when
it is fully operational
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-6
In the operation phase the main sources of traffic will be the transport of personnel
and the transport of steel products (raw materials and galvanized steel coils) to and
from the Port of Ngqura
The road network within the Coega IDZ is shown in Figures 8 and 9 Access to the
Casa Steel development would be off Ring Road 1 The other roads of significance
for the Casa Steel development are the N2 Neptune Road MR435 and MR450
Access to the port is given by Neptune Road Road Link NEP-03 has not yet been
built
Figure 8 Coega IDZ road network identification
(Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007)
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-7
Figure 9 Coega IDZ road network
Adapted from (re-annotated) Drawing Title Master Plan ndash CDC East CDC Drawing No
01121_T_BAS_M_001_00Q_MPlan_A1 CDC Master Plan
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-8
The distribution of freight trips is fixed as the majority of trips will be made between
the Port of Ngqura and the Casa Steel site With regard to personnel trips there are
various points of origins (the surrounding residential areas) that could be used by
staff going to the Casa Steel site The distribution of personnel trips is based on
existing traffic count information and is shown in Figure 10
Figure 10 Trip distribution for freight and personnel trips
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The resultant expected Casa Steel traffic assignment is shown in Figure 11
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-9
Figure 11 Morning peak hour Casa Steel development traffic
Adapted from (re-annotated) Figure 54 Road Network Link Description BKS 2007
The traffic that is expected to be generated by the Casa Steel development is
expected to have a negligible impact on the road network (N2 Ring Road 1 MR435
MR450 and Neptune road) in terms of capacity since current traffic volumes are low
and the total traffic generated by Casa Steel is also relatively low (Iliso 2011)
Consultation has taken place with Transnet Port Authority (TPA) to establish the
impact of the galvanizing plant operations on traffic inside the port The additional
ships entering and exiting the port of Ngqura as a result of the proposed development
will have a negligible impact on port traffic and TPA indicated that it would be well
within the portrsquos capacity
58 NOISE
Noise is not foreseen to be a significant issue insofar as the noise levels inside the
plant and at the boundary of the site will not exceed the limits prescribed by the CDC
Noise levels on the boundary of the tenantrsquos premises may not exceed 70 decibels
during the day and 60 decibels at night
Mitigation of noise impacts will be addressed in the design of the noise-emitting
components of the plant and their enclosures
N
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 5-10
59 SOCIO-ECONOMIC ASPECTS
The IDZ is approximately 11 640 ha in extent and is situated on the outskirts of
NMBM There are no residents within the IDZ
The direct socio-economic impacts of the proposed project are thus limited to the
employment generated by the project during construction and operation Job creation
remains one of the cityrsquos top priorities as expressed in the IDP 2006-2011 (9th ed)
and the IDZ and Port of Ngqura are expected to become a significant catalyst to the
economic growth of the Municipality and the region with current investments at
Coega creating more jobs and stimulating the economy
In this context the proposed galvanizing plant will make a positive contribution
towards the achievement of these goals
There will be 50 to 60 employees during operation phase distributed as follows
Figure 12 Casa Steel organisation chart
Even though a large part of the inputs will be imported and the bulk of the production
output will be exported there will be some positive impacts for the economy of the
region and of South Africa in general Notably the requirements of the plant for
water electricity waste collection and disposal waste water treatment and transport
for example will create business for the various service providers and have an
indirect impact on employment and fiscal revenues as a result
From a visual impact point of view it can be anticipated that the landscape in the IDZ
will be significantly affected over time by developments related to the establishment
of the port and various industries
HEAD ( WORKS )
MGR ( COMM) MGR ( ADMNHR ) Manager marketing
MANAGER OPERATION MANAGER MANAGER MANAGER Q C
AC FIN PUR ampSTORE
PPC SH-GALV SH-tech
SR STAFF ShIch ShIch SR STAFF SR STAFF SR STAFF SECURITY PampA SR STAFF SR STAFF
1 NO 4 NOS 2NOS 1 NOS 1 NOS 1 NOS 2 NO 1 NO
JR STAFF JR STAFF JR STAFF JR STAFF 1 NOS JR STAFF JR STAFF
2 NOS 2 NOS 1 NOS 1 NOS 4 NOS (GALV) 1NO
WORKERS WORKERS 7NOS
15 7
RAW MAT amp
DESP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 6-1
6 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY
A description of the nature of the impact any specific legal requirements and the
stage (constructiondecommissioning or operation) will be given Impacts are
considered to be the same during construction and decommissioning The
significance of the potential impacts will be considered before and after identified
mitigation is implemented
The following criteria will be used to evaluate significance
Nature The nature of the impact will be classified as positive or negative and
direct or indirect
Extent and location Magnitude of the impact and is classified as
Local the impacted area is only at the site ndash the actual extent of the activity
Regional the impacted area extends to the surrounding immediate and
neighbouring properties
National the impact can be considered to be of national importance
Duration This measures the lifetime of the impact and is classified as
o Short term the impact will be for 0 ndash 3 years or only last for the period of
construction
o Medium term three to ten years
o Long term longer than 10 years or the impact will continue for the entire
operational lifetime of the project
o Permanent this applies to the impact that will remain after the operational
lifetime of the project
Intensity This is the degree to which the project affects or changes the
environment and is classified as
o Low the change is slight and often not noticeable and the natural functioning
of the environment is not affected
o Medium The environment is remarkably altered but still functions in a
modified way
o High Functioning of the affected environment is disturbed and can cease
Probability This is the likelihood or the chances that the impact will occur and
is classified as
o Low during the normal operation of the project no impacts are expected
o Medium the impact is likely to occur if extra care is not taken to mitigate
them
o High the environment will be affected irrespectively in some cases such
impact can be reduced
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 6-2
Confidence This is the level knowledgeinformation the environmental impact
practitioner or a specialist had in hisher judgement and is rated as
o Low the judgement is based on intuition and not on knowledge or
information
o Medium common sense and general knowledge informs the decision
o High Scientific and or proven information has been used to give such a
judgment
Significance Based on the above criteria the significance of issues will be
determined This is the importance of the impact in terms of physical extent and
time scale and is rated as
o Low the impacts are less important
o Medium the impacts are important and require attention mitigation is
required to reduce the negative impacts
o High the impacts are of great importance Mitigation is therefore crucial
Cumulative Impacts The possible cumulative impacts will also be considered
Mitigation Mitigation for significant issues is incorporated into the EMP for
construction
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 7-1
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS
71 IMPACTS DURING CONSTRUCTION
711 Air quality
Naturedescription of impact the impact of the project during construction on air quality will be in the form of dust related to debris
handling truck transport materials storage handling and transfer open areas (windblown emissions) and vehicle exhaust emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning Various local and far-a-field sources are expected to contribute to the suspended fine
particulate concentrations in the region Local sources include wind erosion from exposed areas fugitive dust from agricultural
operations vehicle entrainment from roadways and veld burning Long-range transport of particulates emitted from remote tall stacks
and from large-scale biomass burning may contribute to background fine particulate concentrations (von Gruenewaldt 2011b)
Commentmitigation dust control measures dust and fume level monitoring (see draft EMP)
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Fugitive particulate emissions (dust)
related to construction activities Regional
Short
term Medium High High Medium Regional
Short
term Low High High Low
Construction vehicle gas emissions Regional Short
term Medium High High Medium Regional
Short
term Low High High Low
712 Heritage and archaeological resources
Naturedescription of impact excavation activities may impact on unidentified heritage resources
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-2
Assumptions and limitations No heritage impact assessment (HIA) has been done for the site Assumptions have been made based
on the various HIAs conducted for Zone 6 and the IDZ as a whole as well as individual developments
Heritage and archaeological
resources Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on unidentified heritage
resources Local
Short
term
Medium -
high Low High Low
713 Biodiversity and conservation
Naturedescription of impact construction activities may impact on terrestrial fauna certain types of vegetation of high conservation
importance and cause soil contamination
Cumulative impacts existing and future development in the IDZ will make the habitat less hospitable for certain species
Commentmitigation The CDC provides for the preservation of certain corridors within the IDZ in its open space management plan
and has compiled a list of protected species to be rescued (see draft EMP)
Biodiversity and conservation Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Loss of fauna and flora Local Perma
nent
Medium -
high High High High Local
Permanen
t Medium High High Medium
Soil contamination Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-3
714 Water related impacts
Naturedescription of impact construction activities may impact on the attenuation pond and water resources through stormwater
runoff spills and leaks Soil erosion
Commentmitigation Ensure restricted access to the area around the natural attenuation pond Prevention and detection of
spillsleaks Provide adequate sanitation Off-site vehicle maintenance Contain runoff water Environmental awareness Proper waste
disposal Stormwater quality monitoring (see draft EMP)
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Soil erosion Local Short
term Medium Medium High Medium Local
Short
term Medium Low High Low
715 Waste management
Naturedescription of impact construction activities will generate waste which may cause pollution if not adequately managed
Commentmitigation see draft EMP and waste management plan
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-4
Waste management Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Local
Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
716 Health and safety
Naturedescription of impact construction activities present inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Short
term
Medium -
high
Medium -
high High High Local
Short
term
Medium -
high Low High Low
717 Traffic
Naturedescription of impact the impacts on traffic during construction will consist of the transport of building materials and
construction workers from surrounding areas and transport of equipment from the port
Cumulative impacts The volumes of traffic in the IDZ and the surrounding road network are currently relatively low
Assumptions and limitations detailed design of the galvanizing plant and the ancillary structure on site has not been done and
accurate estimates of quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-5
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Increased traffic on N2 and within the
IDZ Regional
Short
term Low High High Low
718 Noise
Naturedescription of impact noise from construction activities may cause nuisance for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Short
term
Medium-
high High High Medium Local
Short
term Medium High High Medium
719 Socio-economic
Naturedescription of impact temporary employment will be created during the construction phase
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-6
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Temporary employment Regional Short
term Medium High High Medium
72 IMPACTS DURING OPERATION
721 Air quality
NatureDescription of impact gas and particulate emissions
Cumulative impacts The sources of gaseous emissions that occur in the region include industrial activity veld burning vehicle
exhaust emissions and household fuel burning
Various local and far-a-field sources are expected to contribute to the suspended fine particulate concentrations in the region Local
sources include wind erosion from exposed areas fugitive dust from agricultural operations vehicle entrainment from roadways and
veld burning Long-range transport of particulates emitted from remote tall stacks and from large-scale biomass burning may contribute
to background fine particulate concentrations (von Gruenewaldt 2011b)
Assumptions and limitations Potential release of CR6+
As no emission factors are available for trivalent chromium processing the
potential impacts due to these activities could not be quantified
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Dust emitted from traffic on paved roads Regional Long Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-7
Air quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
term
Hydrogen chloride emissions from
pickling process Local
Long
term Low High High Low
Particulate emissions (smoke) from
galvanizing process (due to the
volatilization of flux)
Local Long
term Low High High Low
Particulate oxides of nitrogen carbon
monoxide and sulphur dioxide emissions
from LNG burner
Local Long
term Low High High Low
Nuisance related to odour Local Long
term Low Low High Low
Abnormally high hydrogen chloride and
particulate emissions due to scrubber
malfunction
Local Short
term Medium Low High Medium
Gases (eg SOx NOx CO etc) and
smoke emitted in case of a fire Local
Short
term High Low High Medium
722 Water quality
NatureDescription of impact Impact on attenuation pond surface and groundwater contamination through spills or leaks
Commentmitigation see draft EMP
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-8
Water quality Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Surface and groundwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Stormwater contamination Regional Short
term
Medium -
high Medium High Medium Regional
Short
term
Medium -
high Low High Low
Impact on attenuation pond Local Short
term
Medium -
high Medium High Medium Local
Short
term
Medium -
high Low High Low
723 Waste management and hazardous substances
NatureDescription of impact Hazardous substances are used in the galvanizing process which will generate general and hazardous
waste both can affect environmental quality and human health
Commentmitigation see draft EMP and waste management plan
Waste management and hazardous
substances Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Soilwaterair pollution due to improper
waste handling storage and disposal Regional
Long
term High
Medium -
high High High Regional Long term High Low High Low
Soilwaterair pollution due to improper
transport storage and handling of
hazardous substances
Regional Long
term High
Medium -
high High High Regional Long term High Low High Low
Health hazard Local Long
term High
Medium -
high High High Local Long term High Low High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-9
724 Health and safety
Naturedescription of impact the operation of the galvanizing plant presents inherent risks to the health and safety of workers on site
Commentmitigation see draft EMP
Health and safety Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Health and safety hazards Local Long
term
Medium-
high
Medium-
high High High Local Long term
Medium-
high Low High Low
725 Traffic
Naturedescription of impact the transport of raw materials from the port and plant personnel from surrounding areas will impact on
the road network
Cumulative impacts The traffic counts (see Appendix A of Traffic Impact Assessment in Appendix G) reveal that the current peak
hour morning traffic volumes are very low and consequently a much higher volume of traffic could be accommodated on the road
network within Zone 6 of the IDZ (Iliso 2011)
Assumptions and limitations all managerial and skilled staff will use their private vehicles with vehicle occupancy of 1 (worst case)
Construction detailed design of the galvanizing plant and the ancillary structure on site has not been done and accurate estimates of
quantities and weights of materials and equipment are not yet available
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-10
Traffic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Impact on traffic and capacity of the N2 Regional Long
term Low High High Low
Impact on traffic and capacity of ring
road 1 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR435 Local
Long
term Low High High Low
Impact on traffic and capacity of the
MR450 Local
Long
term Low High High Low
Impact on traffic and capacity of
Neptune road Local
Long
term Low High High Low
726 Noise
Naturedescription of impact plant operations may cause noise pollution for neighbouring tenants and communities
Commentmitigation Noise levels will be comply with the IDZ norms (see draft EMP)
Noise Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Nuisance Local Long
term Medium High High Medium Local Long term Low High High Low
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 7-11
727 Socio-economic
Naturedescription of impact employment will be created during the operation phase and the operation of the plant will generate
revenue for the municipality and the region as a whole
Socio-economic Pre-mitigation Post-mitigation
Potential impact Extent Duration Severity Probability Confidence Significance Extent Duration Severity Probability Confidence Significance
Employment and economic growth Regional Short
term Medium High High Medium
73 COMPARATIVE ASSESSMENT OF IMPACTS
During construction impacts post-mitigation are low with the exception of noise and biodiversity While all impacts were assessed as
low during operation after mitigation
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 8-1
8 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME
The draft EMP outlines how negative environmental impacts will be managed and
minimized during and after construction The EMP fulfils the GN 543 requirements
Recommendations are given with regard to the responsible parties for the
implementation of the EMP
As a tenant operating in the IDZ Casa Steel will be required to comply with all
current and future CDC requirements as well as with the relevant conditions of
permits licences issued to CDC (eg Integrated Stormwater Masterplan for the
eastern side of the Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)
In particular the CDC has its own requirements regarding the monitoring of certain
aspects of the project such as the quality of the effluent and the noise levels These
have been incorporated into the EMP
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 9-1
9 ENVIRONMENTAL IMPACT STATEMENT
All predicted negative impacts can be mitigated to a low significance The only
exceptions are biodiversity as the construction of the plant will result in the
destruction of habitat and loss of fauna and flora and noise impacts inherent to
construction activities Mitigation measures have been included in the EMP for these
impacts and they have a medium significance post-mitigation
Specifically the following conditions should be adhered to
Plant rescue in accordance with the CDCrsquos requirements (pre-construction and
construction phases)
Regular monitoring of noise levels (construction and operation)
Regular monitoring of effluent and stormwater quality (operation)
The temporary jobs created during construction of the plant and permanent
employment and economic growth generated by operation are the main positive
impacts of the project
The no-go option will result in a status quo in terms of impacts in the short-term and
the maintenance of the baseline as described in chapter 4 although in the medium to
long term similar impacts are likely to occur due to ongoing developments in the IDZ
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 10-1
10 CONCLUSION AND RECOMMENDATIONS
The proposed project is ideally located within an area earmarked for industrial
development and will benefit from the proximity of the Port of Ngqura as well as
other infrastructure and services available in the IDZ
All potentially significant environmental impacts of the project have been identified
and assessed No fatal flaws have been identified
It is recommended that the project be approved subject to the conditions listed in
chapter 9 and adherence to the EMP requirements
Final Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
April 2012 11-1
11 REFERENCES
Almond JE (2010) Palaeontological Heritage Assessment of the Coega IDZ
Eastern Cape Province Report compiled for Eastern Cape Heritage Consultants
Bennie JS (2010) The historical component (built environment) of the Heritage
Impact Assessment of the greater Coega Industrial Development Zone (IDZ) Port
Elizabeth Nelson Mandela Bay Municipality Eastern Cape Province Report
compiled for Eastern Cape Heritage Consultants
Binneman J (2010) Phase 1 Archaeological Impact Assessment of the Greater
Coega Industrial Development Zone (IDZ) Near Port Elizabeth Nelson Mandela Bay
Municipality Eastern Cape Province Report compiled for Eastern Cape Heritage
Consultants
BKS (2006) Coega Industrial Development Zone Transport Study Volume 3
Demand Modelling Report Final Draft
Burgers CL and Gardiner R (2007) Coega Development Corporation Phase I
Preliminary Desktop Liability Assessment Report ndash Industrial Development Zone 6
Report compiled for SRK Consulting
Coastal amp Environmental Services (2010) Environmental Impact Assessment for the
Proposed Kalagadi Manganese Smelter in the Coega Industrial Development Zone
Volume 3 Environmental Impact Assessment Report CES Grahamstown
Coega Development Corporation (2008) Industry Waste Management Plan -
Strategic Master Plan Report
Coega Development Corporation (2007) Quality Standards for Stormwater ndashTenants
Report No CDCSHE 03 8122
Department of Water Affairs and Forestry (1998) Waste Management Series
ldquoMinimum Requirements For The Handling Classification And Disposal Of
Hazardous Wasterdquo Second Edition
Iliso Consulting (2011) Traffic Impact Assessment for the Proposed Steel Galvanising
Plant in the Coega Industrial Development Zone
Iliso Consulting (2011) Proposed 80 000 tonnes per year galvanizing plant in the
Coega Industrial Development Zone (IDZ) Specialist Water Study
Draft Environmental Impact Assessment Report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone
March 2012 11-2
Jacobs E (2008) Final Environmental Impact Report and Draft Environmental
Management Plan Proposed Steel Recycling and Processing Facility within the
Coega IDZ Report compiled for SRK Consulting
Pasco Waste amp Environmental Consulting CC (2011) Proposed 80 000 TPY
Galvanising Plant in the Coega Industrial Development Zone Waste Management
and Hazardous Substances Report compiled for ILISO Consulting
RSA National air quality standard for thoracic particulates (PM10) SA standards
(Government Gazette No 32816)
von Gruenewaldt RJ (2011a) Air Quality Baseline Assessment for the Proposed
Steel Galvanising Plant in the Coega Industrial Development Zone Eastern Cape
Report compiled for ILISO Consulting
von Gruenewaldt RJ (2011b) Air Quality Impact Assessment for the Proposed Steel
Galvanising Plant in the Coega Industrial Development Zone Eastern Cape Report
compiled for ILISO Consulting
Additional sources
Kaplan J (2008a) Phase 1 Archaeological Impact Assessment for the proposed
Exxaro Manganese Smelter Coega Industrial Development Zone Report prepared
for Coastal Environmental Services
Kaplan J (2008b) Phase 1 Archaeological Impact Assessment for the proposed
Kalagadi Manganese smelter in the Coega Industrial Development Zone Port
Elizabeth Eastern Cape Province Report prepared for Coastal Environmental
Services
Webley L (2007) Phase 1 heritage impact assessment of the proposed Afro-Asia
steel recycling facility at the Coega Industrial Development Area Port Elizabeth
Prepared for SRK Consulting Port Elizabeth
APPENDIX A
LIST OF INTERESTED AND
AFFECTED PARTIES
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
DEDEARegional Manager
and ELC chairpersonMr Jeff Govender Pvt Bag X5001 Greenacres 6057 041-5085811 041-5085865 071-6749710 dayalangovenderdeaetecapegovza
DEDEA Asst Director IEM Mr Andries Struwig Pvt Bag X5002 Greenacres 6057 041-5085840 041-5085865 079-5031762 andriesstruwigdeaetecapegovza
DEA Ocean and
CoastPollution Manager Mr Mulalo Tshikotshi PO Box 52126 Cape Town 8002 021-8192455 021-8192445 082-8307323 mtshikotenvironmentgovza
DEA Ocean and
Coast
Oceanographer land-
based sources of
marine pollution
Ms Thilivhali Meregi PO Box 52127 Cape Town 8002 tmeregienvironmentgovza
DEA Mr John Geeringh Pvt Bag X447 Pretoria 0001 012-3103491 012-3207539 083-6327663 JGeeringhenvironmentgovza
CDC Executive Manager Mr Themba Koza Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6550292 thembakozacoegacoza
CDCEnvironmental
Project
Manager
Ms Andrea von Holdt Pvt Bag X6009 Port Elizabeth 6000 041-4030400 041-4030401 082-6574648 andreavonHoldtcoegacoza
TNPAPort of Ngqura
Environmental
Manager
Mr Elliot Motsoahole PO Box 612054 Bluewater Bay 6212 041-507 8220 086 674 7729 083-5425619 Elliotmotsoaholetransnetnet
NMBMEnvironmental
ManagerMr Joram Mkosana PO Box 11 Port Elizabeth 6000 041 506 5464 041 505 4491 082-7821014 jmkosanamandelametrogovza
NMBMEnvironmental
ManagerMs Kithi Ngesi PO Box 11 Port Elizabeth 6000 041-506 1398 041 585 7261 082 782 0408 kngesimandelametrogovza
DWA Manager Mr Vien Kooverji PO Box 7019 East London 5205 043 722 3805 043 743 3910 083-6275928 kooverjivdwagovza
DWA Mr Pieter Retief Pvt Bag X6041 Port Elizabeth 6000 041 586 4884 041 586 4210 082-8876293 RetiefPdwagovza
WESSASenior Conservation
Officer EP RegionMorgan Griffith 041 585 9606 morganwessaepcoza
Zwartkops
ConservancyChairperson Dr Hugh Laue 041 4661815 041 4667702 082 853 0700
hughlauegmailcom
zwartkopstrustiafricacom
SANParksNational Marine
CoordinatorAneacute Oosthuizen 046 622 5121 AneOosthuizennmmuacza
Department Of
LabourMr Petrus Jonker 086 694 8777 082 9399 771 petrusjonkerlabourgovza
NMBM Air Quality
Division
Assistant
DirectorAir
Pollution and Noise
Templeton Titima 079 490 0574 Ttitimamandelametrogovza
NMBM Air Quality
DivisionAir Pollution Officer Mr Kobus Slabbert 041 506 5210 079 490 0358 kslabbertmandelametrogovza
NUMSARegional
RepresentativeVuyo Bikitsha 041 363 1010 041 363 1038 vuyobnumsaorgza
Affiliation Position Title FirstName Surname Postal address City Code Tel Fax Cell EMail
Department of
HealthNadiema
van der
Bergh083 378 2103
nadiemavanderberghimpiloecprovgov
za
DWA Chief Services
Officer
Joseph Jacobs 041 586 4884 jjacobsdwafgovza
EMC ECO for Coega IDZ Dr Paul Martin 041 466 5698 073 252 4111 pmartinaxxesscoza
NUMSecretary of union
officesZandile Xhentsa 043 743 6597 zxhentsanumorgza
DMR Mrs Deidre Watkins 041 396 3900 072 782 3624 deidrewatkinsdmrgovza
Dynamic
CommoditiesFinancial Manager Mr Marc Larter 041-4059888 082 4957796 marcdynamicfoodcom
EC Biomass CEO Mr Willie Claasen 041 405 8000 082 9607826 willieecbiomasscoza
Acoustex HR Manager Mrs Gillian Solom 041 405 0217 084 0922774 gilliansacoustextrimcoza
UTI Branch Manager Mr Danie Gerber 041 405 0400 082 492 3223dgerber2zago2uticom
lprincezago2uticom
Cerebos Mr John Drinkwater 041-4863530 082 6549507 johndcereboscoza
Digistics DC Manager Mr Brett Williams 041 403 0300 BrettWdigisticscoza
Absa Mr Johann Steyn 082 3775820 johannstabsacoza
Bosun Brick Regional Manager Mr Wayne Poulton 041 405 0100 waynepbosuncoza
PE Cold Storage Manager Mr Len Cowely 041 405 0800 083 2833767 lenpecoldstoragecoza
Universal
EquipmentDirector Mr Marc Rogers 041 453 1810 041 451 4501 kasmirauniversalequipmentcoza
Cape Concentrates Mr Leon Wait 082 453 0079 leonwaitcapeconcentratecoza
GMSA Plant Manager Mr Jose Espinosa 082 728 0608 joseespinosagmcom
Discovery Health Service Executive Mr Patrick Barrett 083 454 1863 patrickbdiscoverycoza
NTI Mr Mark Snyman 074 241 6982 snymanmarkyahoocom
DWA Water Regulation and UseMr Andrew Lucas 043 604 5403 082 802 8564 lucasadwagovza
DEDEA Provincial Air Quality OfficerMr Lyndon Mardon P Bag X0054 Bisho 5605 043 605 7128 071 865 3914 lyndonmardondeaetecapegovza
TNPA Manie Coetzee 041 507-8428 083 302-5889 maniecoetzeetransnetnet
DWA Mr Landile Jack JackLdwagovza
DWA Ms Lizna Fourie FourieL4dwagovza
APPENDIX B
NOTICE OF ATMOSPHERIC
EMISSIONS LICENCE APPLICATION
AND ADVERTISEMENT
APPENDIX C
NOTICE OF COMMENT PERIOD FOR
DRAFT SCOPING REPORT
APPENDIX D
SUMMARY OF ISSUES RAISED AND
RESPONSES THERETO
April 2012
1
PPRROOPPOOSSEEDD 8800 000000 TTOONNSSYYEEAARR SSTTEEEELL GGAALLVVAANNIIZZIINNGG PPLLAANNTT IINN TTHHEE CCOOEEGGAA IINNDDUUSSTTRRIIAALL
DDEEVVEELLOOPPMMEENNTT ZZOONNEE ((IIDDZZ))
IIssssuueess aanndd RReessppoonnsseess RReeppoorrtt
AAppppeennddiixx ttoo tthhee FFiinnaall EEnnvviirroonnmmeennttaall IImmppaacctt RReeppoorrtt
This report provides a formal and integrated record of all the issues raised by Interested and Affected Parties (IampAPs) and the responses
provided by the independent Environmental Assessment Practitioner during the scoping and impact assessment phases of the EIA process
conducted for the proposed 80 000 tonsyear galvanizing plant in the Coega IDZ up to 18 April 2012 It is presented as an Appendix to the
Final Environmental Impact Report Copies of correspondence related to commentsissues have also been included in this Appendix
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
2
IssueCommentQuestion Date
received Origin Response
1 Please provide more information with respect to the potential
dangers including the toxicity of the proposed project
07032011
By email
Wayne Poulton
(Bosun Brick
tenant at the
IDZ)
An Environmental Impact Assessment (EIA) was undertaken
which assessed the potential toxicity of the emissions and
effluent Mitigation measures were also recommended in the draft
Environmental Management Programme (EMP) to avoid
minimise or compensate any significant impacts The Draft
Environmental Impact Report and draft EMP were made available
to stakeholders for comment in March 2012
2 Do you have a Background Information Document (BID) or
similar that provides more information on the project
27032011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The BID was sent to all registered IampAPs on 4 May 2011
3 The RoD issued to the CDC on 632007 for the change in
land use for the remaining area of the Coega IDZ includes a
number of requirements with respect to
atmospheric emissions that should be considered in the
Atmospheric Emissions Licence (AEL) application such as
prohibiting and monitoring where possible visible emission
plumes to the atmosphere In particular the
recommendations on pp87-91 of the final revised Scoping
Report dated Nov 2006 must be implemented (clause 421)
04042011
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
We have obtained copies of the documents referred to and ensure
that these requirements were taken into account in the
environmental assessment and AEL application
4 If the Port of Ngqura is used for import and export the scope
of the traffic impact assessment (TIA) should also include the
port
10052011
By email
Elliot
Motsoahole
(TNPA Port of
Ngqura)
The scope of the TIA was extended to include port related traffic
The TNPA at the Port of Ngqura was consulted and does not
have any objection to the project TNPA has indicated that the
development would require a minimum number of vessels per
year which would have minimal impact on the Port operations
However due notice would have to be given to the Port of Ngqura
before a vessel is scheduled to arrive so that the vessel can be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
3
IssueCommentQuestion Date
received Origin Response
accommodated at an available berth
5 Concerns with respect to potential stormwater pollution
draining into the Coega catchment and the port of Ngqura
The port needs to be dredged and heavy metals present a
risk in that regard
16052011
By
telephone
Andrew Lucas
(Department of
Water Affairs)
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination by effluent waste or
hazardousdangerous substances is very low
Thus no metals oils or other contaminants are expected to be
present in the stormwater
However stormwater pollution can occur in exceptional
circumstances such as accidents and emergencies The
emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
6 All steel sheets bathing unit must be under roof
7 The sludge out of the decreasing bath will be high in Na and
pH Therefore handling and disposal must be clarified up front
in this project
8 Per se the wastewater from decreasing bath will have high
ph and the component from the pickling unit will have low ph
Then it may be assumed that both streams will neutralize
each other Please then clarify proposed sewer discharge
with Nelson Mandela Bay Municipality up-front for acceptance
of influent as per the documented proposal
9 Pickling may result in dissolved metals How does your team
expect to deal with this As it is planned for discharge into
24052011
By email
Landile Jack
(Department of
Water Affairs)
All bathing units will be under roof
Effluent from the degreasing and pickling baths will be discharged
to the wastewater treatment plant The respectively alkaline and
acidic effluents will mix and neutralise each other in the
wastewater treatment plant Calcium or gypsum will be added if
required to complete the neutralisation process Effluent from the
treatment plant will be discharged to sewer Contact has been
made with the relevant officials and the Municipalityrsquos
requirements have been obtained The effluent discharged to
sewer will notably comply with the applicable discharge standards
Traces of metals (eg iron) may be present but will not exceed
prescribed thresholds The necessary authorisation will be
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
4
IssueCommentQuestion Date
received Origin Response
sewer Clarity and acceptance needs to be agreed with
Nelson Mandela Bay Municipality Who owns the sewer
10 Quenching unit will results to Zinc particles How will this
affect sewer discharge This again must be dealt with within
the negotiations with the Municipality
11 Once all has been agreed with the Municipality and at the
same time due negotiations must be done with hazardous
waste courier and disposal facility to accept the hazardous
waste identified in all production lines
12 Of note is the low volume of the proposed WWTW facility ie
250 cubmweek And the no discharge of the quenching
water ie over-flow and cooling only Hence Zinc particles
generation
obtained from the municipality
The sludge from the treatment plant will be collected by a licensed
service provider and disposed of at a permitted site
The quenching bath will be periodically emptied (every 6 months)
and the water discharged will go to the water treatment plant Zinc
particles will settle in the sludge which will be disposed of at a
permitted site
Contact has been made with EnviroServ who manages the
Aloes II HH waste site regarding collection and disposal of
hazardous waste (See waste management report)
13 Investigate the potential effects of toxicity andor influence of
emissions waste and hazardous substances both in
terrestrial and marine fauna
14 With regards to water usage where is the plant going to
extract its waters used in galvanization andor waste
management process ie rainfall rivers or even from the
sea) and which avenues would be more environmental
friendly and effective
31052011
By email
A Bewana
(SANPARKS)
Emissions waste and hazardous substances are not expected to
affect terrestrial or marine ecosystems The air quality study
concluded that atmospheric emissions would not be harmful to
human health and by extension terrestrial fauna There are no
standards for air quality for defining faunal impacts therefore by
ensuring that standards for humans are complied with the impact
on fauna is deemed to be acceptable In this case the impact of
emissions on terrestrial and marine fauna are thus not significant
Solid and liquid wastes both general and hazardous as well as
hazardous substances will be stored handled and disposed of
appropriately to as not to cause harm to terrestrial or marine
fauna
Due to the design of the plant and mitigation measures in place
(ie contained process bunded areas oil trap specified
procedures for the transport storage and handling of
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
5
IssueCommentQuestion Date
received Origin Response
hazardousdangerous substances) it is considered that
stormwater leaving the site will be clean under normal conditions
and the risk of stormwater contamination and hence land-based
marine pollution by effluent waste or hazardousdangerous
substances is very low
The risk of emissions waste and hazardous substances to
terrestrial and marine fauna is thus very low
However pollution of terrestrial and marine ecosystems can occur
in exceptional circumstances such as accidents and emergencies
The emergency preparedness and response plan and remediation
procedures will be developed and will deal with such
circumstances
The CDC has an agreement with the NMBM to supply potable
water to the Coega IDZ Currently the infrastructure to supply
return effluent (RE) to the IDZ is not in place therefore Casa Steel
will be supplied with potable water up until such time as the
following 2 options of RE are available
1) Upgrading of the existing Fishwater Flats waste water
treatment works (between IDZ amp PE) including RE plant
and infrastructure to pipe RE to the IDZ (EIA for the
upgrade is underway)
2) Construction of a new waste water treatment works
including RE plant in Zone 9 of the Coega IDZ
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option should be investigated further between Agni and Casa The
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
6
IssueCommentQuestion Date
received Origin Response
CDC can facilitate discussions between the 2 investors
Compliance with CDC Permits amp Requirements
15 It should be made clear that tenants will be required to
comply with CDC requirements and the relevant conditions of
permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water
Licence for its Storm Water Systems on the
East Side of the Coega River that tenants will
need to take cognizance of The contents of the
ldquoIntegrated Stormwater Masterplan for the
eastern side of the Coega IDZ Oct 2010rdquo
especially the Table of best practice p53
onwards may need to be taken cognizance of
o CDC is developing an Operations
Environmental Management Plan that will place
certain obligations on tenants
16 Environmental audits and data collected during monitoring
(eg stack emissions stormwater) will need to be shared with
CDC
Air Emissions
17 Presumably permanent in stack monitoring will be required in
terms of AEL permit requirements
18 Abnormal operating conditions resulting in air emissions ndash I
could find nothing in the EIR to indicate under what
circumstances these could occur (eg start-up) potential
frequency and duration and the impact on ambient air quality
ndash these events usually result in the most problems wrt air
emissions
09042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
15 Compliance with the CDCrsquos Permits amp Requirements has
been included explicitly as a requirement in the EIR (p8-1) and
EMP (pp18 and 25) in the following terms
ldquoAs a tenant operating in the IDZ Casa Steel will be required to
comply with all current and future CDC requirements as well as
with the relevant conditions of permits licences issued to CDC
(eg Integrated Stormwater Masterplan for the eastern side of the
Coega IDZ Operations Environmental Management Plan Water
Use Licence etc)rdquo
16 The need to communicate with the CDC on monitoring and
auditing activities was emphasised in Chapter 8 of the EMP The
following paragraphs were added
ldquoDuring construction the environmental officer will be responsible
for monitoring compliance with the EMP and authorisation
conditions and keeping records as required in the EMP andor
authorisation conditions
The ECO will conduct site inspections every two weeks audit the
records kept by the environmental officer and submit an
environmental compliance report every two months to the
authorities and the CDC (via the Environmental Monitoring
Committeersquos ECO)
During operation the health and safety officer will monitor
compliance with the EMP and the conditions of the Environmental
Authorisation Data collected during monitoring activities and any
environmental audits conducted will be shared with authorities
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
7
IssueCommentQuestion Date
received Origin Response
Water
19 Large volumes of (2000 m3mth) of water are required of
which only 400m3 needs to be potable The NMBM return
effluent system will provide non-potable water once it is
constructed What other water recycling initiatives can be
utilized to reduce potable water requirements (the ISWMP for
the eastern side of the Coega IDZ has some best practice
guidelines collecting rainwater from the roof etc)
General
20 There is no mention of how the CDC Architectural Guidelines
will be incorporated into the development (eg to prevent a
stark uniform warehouse type development)
21 Does NMBM have adequate fire services to cover this
development Apart from the large petroleum store are there
any other large fire hazards
22 Reports from the tenantrsquos ECO during construction and from
the SHE Officer during operations should be channeled to the
Coega Environmental Monitoring Committee This can be
directly or preferably via the EMCrsquos ECO (this will be while
the EMC and ECO are in place) A precedent has been set
for this in the Environmental Authorisations for Agni-Steel and
Kalagadi Manganese Smelter
23 All mitigation actions emanating from the EIR should be
summarized (preferably in a table) If compliance with them is
to be part of the Environmental Authorization from DEDEAT
then they (or the ones that DEDEAT deems to be applicable)
and the CDC (via the Environmental Monitoring Committeersquos
ECO)
The ECO (during construction) and the health and safety officer
(during operation) will report to the Coega Environmental
Monitoring Committee (EMC) via the EMCrsquos ECO (this will be
while the EMC and ECO are in place)rdquo
17 The draft EMP recommends regular monitoring of emissions
from the scrubbers and from the chromating process Additional
emissions monitoring requirements will be confirmed once the
AEL is issued Mention has been made in the EMP (pp11 and 19)
that all AEL conditions including monitoring and reporting
requirements should be adhered to
18 Abnormal emissions can occur in exceptional circumstances
Start-up will not cause abnormal emissions as the scrubbers
will be commissioned first and will be functioning once the plant
starts operating However abnormal emissions could be
caused if scrubbers are malfunctioning These emissions
would be emitted as a building fugitive
The hourly hydrogen chloride ground level concentrations
(directly offsite) were predicted to be 239 microgmsup3 (based on the
emissions of 5 ppm) and 868 microgmsup3 (based on the emission limits
as stipulated for listed activities for galvanising processes) using a
screen model which assumes worst case meteorological
conditions The health effect screening level for hourly HCl
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
8
IssueCommentQuestion Date
received Origin Response
should be attached to the EA as an Appendix (otherwise no
one knows about them or takes cognizance of them)
concentrations is 2100 microgmsup3 Assuming abnormal emissions
emanating from the building are five times higher than routine
emissions the hourly predicted HCl concentrations due to upset
conditions will still be well within the health effect screening
levels
Similarly the hourly particulate emissions from the building
fugitives during upset conditions would amount to 293 microgmsup3
(based on the emission limits as stipulated for listed activities for
galvanising processes) well within the daily PM10 NAAQS (ie
120 microgmsup3 applicable immediately and 75 microgmsup3 applicable 1
January 2015) directly off-site
Therefore if emissions are 5 times higher normal they will still be
within health effect screening levels and the daily PM10 NAAQS
levels
In the case of a fire a cocktail of gases and particulates could be
emitted and could be over the recommended levels This
situation will however be dealt with as an emergency and
normalised as quickly as is possible
The above has been added to the impact identificationdescription
and assessment sections of the EIR
19 The CDC has an agreement with the NMBM to supply
potable water to the Coega IDZ Currently the infrastructure to
supply return effluent to the IDZ is not in place therefore Casa
Steel will be supplied with potable water up until such time as the
infrastructure is in place
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
9
IssueCommentQuestion Date
received Origin Response
Agni Steel an investor located in Zone 6 has commenced with
construction Once operational Agni Steel will be generating
effluent which may be considered for use by Casa Steel This
option will be investigated further between Agni and Casa The
CDC has come forward to facilitate discussions between the two
investors
Other water recycling initiatives such as rainwater harvesting
have been considered but are not practical
20 The CDCrsquos Architectural and Landscape Design guidelines
contain requirements pertaining to such aspects as the height
orientation and mass and form of buildings as well as guidelines
for landscaping and signage in order to ensure an attractive
development and achieve an architectural integrity within the
Coega IDZ The plans for the proposed galvanizing plant will be
submitted to the Design Review Committee for approval as
required by the CDC
21 Casa Steel will be required to install fire hydrants according
to the NMBMrsquos standardsrequirements The CDC will provide
potable water (up until such time as return effluent is available)
and a connection to the boundary of the site which will be
connected to the fire hydrants The installation of the fire hydrants
will require approval by the Metrorsquos Fire Chief as was done for
Agni-Steel one of the investors in Zone 6
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
10
IssueCommentQuestion Date
received Origin Response
The Coega IDZ falls within the NMBM and therefore the rates and
taxes paid by the CDC covers the fire services for which the Metro
is responsible Currently the Metro has sufficient capacity to
provide fire services to the tenants within the IDZ This was
confirmed in discussion with the CDCrsquos Infrastructure
Development Unit It is however unknown at which point the
Metrorsquos Disaster Management Plan would not be able to
accommodate servicing tenants in the IDZ
The LNG burner is the only major fire hazard on the plant
22 See response to item 16 above
23 Key mitigation and management measures emanating from
the EIR were recapitulated in Chapter 9 of the EIR to form part of
the conditions attached to the Environmental Authorization from
DEDEAT All mitigation measures recommended as a result of the
impact assessment are presented in a table in the draft EMP
which is appended to the EIR (Appendix J)
24 Hydrogen chloride is one of the main emissions There are no
ambient air quality guidelines for HCl and the EIR says
concentrations will be well within health parameters
However the main problem with HCl is its corrosive effect -
there is absolutely no mention of this in the draft EIR nor air
specialist report
There needs to be some sort of comment assessment as to
whether HCl emissions are likely to impact on for example
the adjacent Agni-Steel Plant wrt corrosion - their factory
structure will be made of steel
11042012
By email
Dr Paul Martin
(Environmental
Control Officer
Coega IDZ)
The atmospheric corrosion of metals is a complex process with
both the extent of deterioration and the mechanisms varying
considerably depending on the metal Depending on the way
pollutants are transported from the atmosphere to the corroding
surface two types of deposition processes are recognized in
atmospheric corrosion ndash dry deposition and wet deposition Wet
deposition refers to precipitation whereas dry deposition refers to
the remaining processes including gas phase deposition and
particle deposition The most important pollutants acting as
corrosive agents are sulphur and nitrogen compounds including
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
11
IssueCommentQuestion Date
received Origin Response
The EIR specialist rpt suggests monitoring HCl at ground
level on the property boundary and this is supported in case
there are complaints from neighbours
secondary pollutants and particulates Pollutants can contribute to
corrosivity individually however there may be a synergistic effect
when more than one of these pollutants is present in the
environment being affected In the field of atmospheric corrosion
sulphur dioxide is the single most investigated gaseous pollutant
and the quantification of the direct contribution of sulphur dioxide
to the corrosion process of metallic materials is comparatively well
understood (Tidblad amp Kucera 1998)
Very little work has reported on the effect of HCl on the
degradation of materials in the environment with no local dose-
response thresholds developed for corrosion occurring due to HCl
exposures This is probably because HCl which is present
outdoors in markedly reduced concentrations when compared
with SO2 has not been considered to contribute to significant
degradation of materials (Syed 2006) For this reason the
incremental corrosion due to HCl from the Coega Galvanising
Plant cannot be quantified
25 It is unacceptable for ILISO to be using CDC maps (see
figure 9 ndash pg5-6) without these maps being referenced
accordingly particularly when it appears that a CDC map has
been used and then overlaid with features by an unknown
author (ie CASA steel site Port (where the boundaries
depicted are incorrect) and a North legend which is out of
keeping with the overall cartographic intent of the original
work
26 Figure 10 is not referenced appropriately and I believe that I
commented previously in respect to references to roads not
12042012
By email
Graham Taylor
(Spatial
Development
Manager -
Infrastructure
Development
CDC)
This has been rectified in the final version of the report
Proposed 80 000 TPY Galvanizing plant in the Coega Industrial Development Zone DEDEA Ref ECm1LN2M11-24
Issues and Responses Report
April 2012
12
IssueCommentQuestion Date
received Origin Response
yet built As a result Figure 10 is confusing and clarity needs
to be provided in terms of referencing In addition the Port
shape is irregular and similar to the comment above
27 I acknowledge the emergency preparedness and response
plan but please confirm that this includes pro-active routine
monitoring of storm water leaving your premises to verify that
your assumptions of clean storm water are correct
13042012
By post
Andrew Lucas
(Director
WRampU
Department of
Water Affairs)
Pro-active routine monitoring of stormwater leaving the premises
will be undertaken This has been explicitly emphasised in
chapter 8 of the draft EMP
28 Will portablechemical toilets be used during construction
29 What provisions have been made for storm water drainage
during construction
18042012
By
telephone
Department of
Water Affairs
Port Elizabeth
Chemical toilets will be used during construction
The Casa Steel site will be located at the corner of two roads
drainage of stormwater from the site will take place through the
roadsrsquo drainage system
From Lea September [mailtoleailisocom]
Sent 11 March 2011 0935 AM
To Wayne Poulton
Cc Terry Baker
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Wayne
An Environmental Impact Assessment (EIA) will be undertaken for this project during the
next 10 to 12 months
We foresee that some of the key environmental impacts of the project will be in terms of air
quality water quality waste and hazardous substances
At this stage I am not able to give you any details regarding the potential toxicity of the
emissions andor effluent However specialist studies will be conducted as part of the EIA
that will determine the key impacts of the project Mitigation measures will also be identified
to avoid minimise or compensate any significant impacts
You are registered on the stakeholder database and you will be kept informed of progress in
the EIA process you will notably get the opportunity to access the reports produced and
provide any feedback on them
Please feel free to contact me should you need any further information
Best regards
Lea September
From Wayne Poulton [mailtowaynepbosuncoza]
Sent 07 March 2011 1257 PM
To Lea September
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
Please can you provide me with some more information as to the potential dangers including
the toxicity of this
Kind regards
Wayne
From Lea September [mailtoleailisocom]
Sent 04 March 2011 1123
To Lea September
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 March 2011 0745 AM
To Paul Martin
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 05 April 2011 0847 AM
To Paul Martin
Cc Terry Baker Renee von Gruenewaldt
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Thank you Paul for this information
I have downloaded a copy of the RoD and Scoping report you referred to and will make sure
these requirements are taken into account in the environmental assessment
Best regards
Lea September
From Paul Martin [mailtopmartinaxxesscoza]
Sent 04 April 2011 0955 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Further to my comments on 27311
Please ensure that the AEL takes cognisance of all the requirements wrt atmospheric emissions in
the RoD issued to CDC on 632007 for the change in land use for the remaining area of the Coega
IDZ In particular clause 421 requires all the recommendations on pp87-91 of the final revised
scoping rpt dd Nov 2006 to be implemented The Scoping Rpt includes several issues wrt emissions
including prohibiting and monitoring where possible visible emission plumes to the atmosphere
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Paul Martin
Sent Monday March 28 2011 745 AM
Subject RE Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Paul
In terms of the Air Quality Act we need to notify all IampAPs of the AEL application before
submitting any application forms to the authorities and starting with the EIA process
We have now submitted all applications (for AEL waste licence and environmental
authorisation) and have started with the scoping process
A BID is being drafted as well and I will send it through to you and other registered
stakeholders as soon as it is ready
I trust this answers your question
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Paul Martin [mailtopmartinaxxesscoza]
Sent 27 March 2011 0647 PM
To Lea September
Subject Re Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Lea
Please Register me as an IampAP for this project
My comment
Do you have a BID document or similar that provides more information on the project
It is difficult to comment without knowing what is involved
Dr Paul Martin
Environmental Control Officer
Coega IDZ Port of Ngqura
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Lea September
To Lea September
Sent Friday March 04 2011 1122 AM
Subject Notice of Application for Atmospheric Emissions Licence proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
You have been identified as a potential Interested andor Affected Party in relation to the
above-mentioned project
Please find attached correspondence in this regard
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 10 May 2011 0327 PM
To ElliotMotsoaholetransnetnet
Cc Terry Baker
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Mr Motsoahole
Thank you for your input on this issue
The Port of Ngqura will indeed be used for import and export At the moment the scope of
the traffic impact assessment only covers road traffic I have however relayed the matter to
our traffic specialist and we will consider this issue in the finalization of the Scoping Report I
will keep you informed of any developments in that regard
I trust this is acceptable to you
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From ElliotMotsoaholetransnetnet [mailtoElliotMotsoaholetransnetnet]
Sent 10 May 2011 0855 AM
To Lea September
Subject RE Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per
year Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Lea
It has been noted that Casa Steel will source steel coils from various markets internationally and
in South Africa and the bulk of the plantrsquos production output will be exported to African countries
However there is no mention of logistic requirements
Kindly advice if Casa Steel intend to use the Port of Ngqura for import and export If Ngqura will
be used the scope of traffic impact assessment should also include the port
Regards
From Lea September [mailtoleailisocom]
Sent 04 May 2011 0747 AM
To Lea September
Subject Notice of Environmental Impact Assessment (EIA) process proposed 80 000 tons per year
Galvanizing Plant in the Coega Industrial Development Zone (IDZ)
Dear Stakeholder
Please find attached a letter announcing the EIA process underway for the proposed 80 000
tons per year Galvanizing Plant in the Coega Industrial Development Zone (IDZ) as well as
a Background Information Document (BID) outlining the details of the project
Please contact me should you require any further information on this project
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
Elliot Motsoahole
Manager - Environment
Transnet National Ports Authority
Port of Nqqura
Port Control Building Klub Road Port Elizabeth 6212
PO Box 612054 Bluewater Bay 6212
+27 41 507 8450
+27 86 674 7729
Cell +27 83 542 5619
E-mail Elliotmotsoaholetransnetnet
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
DISCLAIMER The information contained in this communication is subject to copyright and
intended only for the use of leailisocom Unauthorised use disclosure or copying is
strictly prohibited Should a virus infection occur as a result of this communication the sender
will not be liable If you have received this communication in error please notify
elliotmotsoaholetransnetnet
From Lea September [mailtoleailisocom]
Sent 25 May 2011 1147 AM
To Jack Landile (ELS)
Cc Fourie Lizna (ELS) Retief Pieter (PLZ) Kooverji Vien (ELS) Kama Bolekwa (ELS) Sigabi Mlungisi
Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Landile
Thank you for your input
Contact has been made with the relevant Municipal Directorate and we will follow up with
them to obtain clarifications on all these issues
I have added both Lizna and yourself on the database and will keep you updated on
progress on this project
Best regards
Lea September
From Jack Landile (ELS) [mailtoJackLdwagovza]
Sent 24 May 2011 0524 PM
To Fourie Lizna (ELS)
Cc Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Hi Lizna
I missed you on this sorry
I linked Pieter twice Instead
Regards
Landile
From Jack Landile (ELS)
Sent 24 May 2011 0445 PM
To leailisocom
Cc Retief Pieter (PLZ) Kooverji Vien (ELS) Retief Pieter (PLZ) Kama Bolekwa (ELS) Sigabi Mlungisi
Subject FW Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Lea
The e-mail you sent to Mr Kooverji dated 19 May 2011 refer
Please register Ms LFourie of Water Affairs as Interested and Affected Party and our comments are
All steel sheets bathing unit must be under roof
The sludge out of the decreasing bath will be high in Na and Ph Therefore handling and disposal must be clarified up from in this project
Per say the wastewater from decreasing bath will have high ph and the component from the prickling unit will have low ph Then it may be assumed that both streams will neutralize each other Please then clarify proposed sewer discharge with Nelson Mandela Bay Municipality up-front for acceptance of influent as per the documented proposal
Pickling may result in dissolved metals How does your team expect to deal with this As it is planned for discharge into sewer Clarity and acceptance needs to be agreed with Nelson Mandela Bay Municipality Who owns the sewer
Quenching unit will results to Zinc particles How will this affect sewer discharge This again must be dealt with within the negotiations with the Municipality
Once all has been agreed with the Municipality and at the same time due negotiations must be done with hazardous waste courier and disposal facility to accept the hazardous waste identified in all production lines
Of note is the low volume of the proposed WWTW facility ie 250 cubmweek
And the no discharge of the quenching water ie over-flow and cooling only Hence Zinc particles
generation
Regards
Landile
From Lea September [mailtoleailisocom]
Sent 19 May 2011 0947 AM
To Lea September
Subject Proposed 80 000 TPY Galvanizing plant - Appendices to Draft Scoping report
Dear Stakeholder
Please find attached the remaining appendices to the draft Scoping report for the proposed
80 000 tonsyear galvanizing plant in the Coega Industrial Development Zone (IDZ)
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Lea September [mailtoleailisocom]
Sent 28 June 2011 0411 PM
To Aphiwe Bewana
Subject RE Proposed 80 000 TPY Galvanizing plant in Coega
Dear Mr Bewana
Thank you for your input and apologies for the late reply
We have taken note of your comments and are will be taking them forward in the EIA phase
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
This e-mail is intended only for the individual or entity named above and may contain information that is confidential and privileged If you are not the intended recipient you are hereby
notified that any dissemination distribution or copying of this e-mail is strictly prohibited Opinions conclusions and other information in this message that do not relate to the official
business of our firm shall be understood as neither given nor endorsed by it
Please consider the environment before printing this email
From Aphiwe Bewana [mailtoaphiwebewanagmailcom]
Sent 31 May 2011 1205 PM
To Lea September
Subject Re Proposed 80 000 TPY Galvanizing plant in Coega
Comment
Re Proposed 80 000 TPY Galvanizing plant in Coega
As SANParks we would like the EIA phase to investigate the potential effects of toxicity
andor influence of emissions waste and hazardous substances both in terrestrial and
marine fauna In the draft scoping report reference has been made with regards to the
terrestrial fauna but there is no attention to potential effects to marine fauna
Equally with regards to water usage where is the plant going to extract its waters used in
galvanization andor waste management process ie rainfall rivers or even from the sea)
and which avenues would be more environmental friendly and effective
Regards
Aphiwe Bewana
Marine Planner
South African National Parks
POBox 76693
NMMU
Port Elizabeth
6031
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 06 July 2011 1031 AM
To Lea September
Subject RE Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Hi Lea
Irsquove reviewed the Final Scoping Report Herewith a few comments
1 Page 2-2 Header on LHS top still refers to Draft Scoping Report 2 Page 4-7 436 The HIA for the IDZ is still being finalized Wersquore waiting for the
Heritage Management Plan to be completed 3 Appendix A list of IAPs Jan van As no longer works at the DME Attached is a
revised ELC member list 4 Attached also is a list of all the tenants currently located in the IDZ as well as the
NMBLP Please include only those in the IDZ as part of your IAP list
Regards
Andrea
From Lea September [mailtoleailisocom]
Sent Wednesday July 06 2011 859 AM
To Lea Septemberrsquo
Subject Proposed 80 000 TPY Galvanizing plant - Final Scoping report available for comment
Dear Stakeholder
The final scoping report for the above-mentioned project (attached) is available for comment
until 27 July 2011
The report and its appendices can also be downloaded from wwwilisocom under the ldquopublic
commentaryrdquo tab
Best regards
Lea September
Environmental Management Tel +27(0)12 685 0900 I Fax +27(0)12 665 1886 I Mobile +27(0)73 729 0101
Email leailisocom
ILISO House 203 Witch-Hazel Ave Highveld Technopark Centurion South Africa
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 09 April 2012 1159 AM
To Lea September
Subject Comments on Galvanising Plant EIR Coega IDZ
Lea
Attached are my comments on the Draft EIR for the Coega IDZ galvanising
plant
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
Email attachment
COMMENTS ARISING FROM DRAFT ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PROPOSED GALVANISING PLANT ZONE 6 COEGA IDZ
Dr Paul Martin PO Box 61029
Bluewater Bay 6212 Tel 041 4665698
Email pmartinaxxesscoza
Compliance with CDC Permits amp Requirements
It should be made clear that tenants will be required to comply with CDC requirements and the relevant conditions of permits licences issued to CDC Eg
o CDC may soon be issued with a DWA Water Licence for its Storm Water Systems on the East Side of the Coega River that tenants will need to take cognizance of The contents of the ldquoIntegrated Stormwater Masterplan for the eastern side of the Coega IDZ Oct 2010rdquo especially the Table of best practice p53 onwards may need to be taken cognizance of
o CDC is developing an Operations Environmental Management Plan that will place certain obligations on tenants
Environmental audits and data collected during monitoring (eg stack emissions stormwater) will need to be shared with CDC
Air Emissions
Presumably permanent in stack monitoring will be required in terms of AEL permit requirements
Abnormal operating conditions resulting in air emissions ndash I could find nothing in the EIR to indicate under what circumstances these could occur (eg start-up) potential frequency and duration and the impact on ambient air quality ndash these events usually result in the most problems wrt air emissions
Water
Large volumes of (2000 m3 mth) of water are required of which only 400m3 needs to be potable The NMBM return effluent system will provide non-potable water once it is constructed What other water recycling initiatives can be utilized to reduce potable water requirements (the ISWMP for the eastern side of the Coega IDZ has some best practice guidelines collecting rainwater from the roof etc)
General
There is no mention of how the CDC Architectural Guidelines will be incorporated into the development (eg to prevent a stark uniform warehouse type development)
Does NMBM have adequate fire services to cover this development Apart from the large petroleum store are there any other large fire hazards
Reports from the tenantrsquos ECO during construction and from the SHE Officer during operations should be channeled to the Coega Environmental Monitoring Committee This can be directly or preferably via the EMCrsquos ECO (this will be while the EMC and ECO are in place) A precedent has been set for this in the Environmental Authorisations for Agni-Steel and Kalagadi Manganese Smelter
All mitigation actions emanating from the EIR should be summarized (preferably in a table) If compliance with them is to be part of the Environmental Authorization from DEDEAT then they (or the ones that DEDEAT deems to be applicable) should be attached to the EA as an Appendix (otherwise no one knows about them or takes cognizance of them)
-----Original Message-----
From Paul Martin [mailtopmartinaxxesscoza]
Sent 11 April 2012 1245 PM
To Lea September
Subject Fw Comments on Galvanising Plant EIR Coega IDZ
Lea
One other comment on that I have on the Galvanising Plant Draft EIR
Hydrogen chloride is one of the main emissions There are no ambient air
quality guidelines for HCl and the EIR says concentrations will be well
within health parameters
However the main problem with HCl is its corrosive effect - there is
absolutely no mention of this in the draft EIR nor air specialist report
There needs to be some sort of comment assessment as to whether HCl
emissions are likely to impact on for example the adjacent Agni-Steel
Plant wrt corrosion - their factory structure will be made of steel
The EIR specialist rpt suggests monitoring HCl at ground level on the
property boundary and this is supported in case there are complaints from
neighbours
Dr Paul Martin
PO Box 61029
Bluewater Bay 6212
Tel 041 4665698
Cell 0732524111
email pmartinaxxesscoza
----- Original Message -----
From Paul Martin ltpmartinaxxesscozagt
To Lea September ltleailisocomgt
Sent Monday April 09 2012 1158 AM
Subject Comments on Galvanising Plant EIR Coega IDZ
gt Lea
gt
gt Attached are my comments on the Draft EIR for the Coega IDZ galvanising
gt plant
gt
gt
gt Dr Paul Martin
gt PO Box 61029
gt Bluewater Bay 6212
gt Tel 041 4665698
gt Cell 0732524111
gt email pmartinaxxesscoza
gt
From Andrea Von Holdt [mailtoAndreaVonHoldtcoegacoza]
Sent 12 April 2012 1139 AM
To Lea September
Subject FW Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Hi Lea
Hope yoursquore keeping well
I have requested comments from my colleagues and the CDC Casa team on the Draft EIR
Please take note of the comments from our GIS Unit regarding 2 of the maps in the Report
Regards
Andrea
From Graham Taylor
Sent Thursday April 12 2012 838 AM
To Andrea Von Holdt Firhana Sam
Cc Johan Fourie Maria van Zyl Melikhaya Sihawu
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Andrea Firhana
Firhana if you could please ensure that the co-ordinates provided in the EIR correspond
with our records (pages 4-1 amp 4-2)
My comments are as follows
It is unacceptable for ILISO to be using CDC maps (see figure 9 ndash pg5-6) without these maps being referenced accordingly particularly when it appears that a CDC map has been used and then overlaid with features by an unknown author (ie CASA steel site Port (where the boundaries depicted are incorrect) and a North legend which is out of keeping with the overall cartographic intent of the original work
Figure 10 is not referenced appropriately and I believe that I commented previously in respect to references to roads not yet built As a result Figure 10 is confusing and clarity needs to be provided in terms of referencing In addition the Port shape is irregular and similar to the comment above
Regards
Graham Taylor
Spatial Development Manager - Infrastructure Development
Mobile 0832283055
Office 0414030454
Facsimile 0865185033
Email GrahamTaylorcoegacoza
Website wwwcoegacom
right PLACE | right TIME | right CHOICE
This email and all contents are subject to the following disclaimer
httpwwwcoegacomemaildisclaimerhtml
From Lea September [mailtoleailisocom]
Sent 04 May 2012 0411 PM
To Andrea Von Holdt
Cc Terry Baker
Subject RE Proposed 80 000 TPY Galvanizing plant - Draft EIR and EMP available for comment
Dear Andrea
We have taken note of the comments from the GIS Unit These issues have been rectified in
the final version of the EIR
Please can you forward to the relevant persons at the GIS Unit
Thank you
Best regards
Lea September
APPENDIX E
BACKGROUND INFORMATION
DOCUMENT
APPENDIX F
AIR QUALITY IMPACT ASSESSMENT
APPENDIX G
TRAFFIC IMPACT ASSESSMENT
APPENDIX H
WASTE MANAGEMENT AND HAZARDOUS
SUBSTANCES SPECIALIST STUDY
APPENDIX I
WATER QUALITY SPECIALIST STUDY
APPENDIX J
ENVIRONMENTAL MANAGEMENT
PROGRAMME
Top Related