DESCRIPTION OF THE ENVIRONMENTAL …fred.csir.co.za/project/smelter/eia_final_chapter_5.pdfPROPOSED ALUMINIUM PECHINEY SMELTER WITHIN THE COEGA IDZ 5. DESCRIPTION OF THE ENVIRONMENTAL

PROPOSED ALUMINIUM PECHINEY SMELTER WITHIN THE COEGA IDZ

CHAPTER 5:

FINAL ENVIRONMENTAL IMPACT REPORT CSIR, 2002

DESCRIPTION OF THE ENVIRONMENTAL

ASSESSMENT PROCESS: INCLUDING PUBLIC

PARTICIPATION


Contents

5. DESCRIPTION OF THE ENVIRONMENTAL ASSESSMENT PROCESS_______________________________________________________ 5-1

5.1 INTRODUCTION TO THE EIA PROCESS ______________________________5-1 5.2 OVERVIEW OF THE SCOPING PHASE________________________________5-4

5.2.1 Objectives of the Scoping phase________________________________________ 5-4 5.2.2 Steps in the Scoping Phase____________________________________________ 5-5 5.2.3 Focus of the EIA___________________________________________________ 5-11 5.2.2 Description of feasible alternatives ____________________________________ 5-13 5.2.3 Key environmental issues identified during Scoping _______________________ 5-15

5.3 APPROACH TO SPECIALIST STUDIES AND IMPACT ASSESSMENT______5-20 5.3.1 Method of assessing significance of impacts _____________________________ 5-21

5.4 OVERVIEW OF THE ENVIRONMENTAL IMPACT REPORT PHASE ________5-24 5.5 EIA STUDY TEAM________________________________________________5-28

List of Figures Figure 5.1: EIA process flow diagram (based on South African EIA Regulations)_______ 5-3 Figure 5.2: Identifying the focus of the Aluminium Pechiney EIA with respect to the

aluminium lifecycle ____________________________________________ 5-12 Figure 5.3: Specialist studies undertaken for the Aluminium Pechiney EIA in terms of the

components of sustainable development ____________________________ 5-21

List of Tables Table 5.1: Key issues identified through the Scoping process that were addressed in the

specialist studies and through inputs from the EIA team________________ 5-16 Table 5.2: Additional issues raised through Scoping that are addressed in the EIR ___ 5-18 Table 5.3: Issues raised in the Scoping process which were not included in the Aluminium

Pechiney EIA specialist studies and EIR ____________________________ 5-19 Table 5.4: EIA Study Team _______________________________________________ 5-28



5. DESCRIPTION OF THE ENVIRONMENTAL ASSESSMENT PROCESS

5.1 Introduction to the EIA process

The EIA for Aluminium Pechiney’s proposed aluminium smelter within the Coega IDZ is being conducted in accordance with the EIA Guidelines issued by the Department of Environmental Affairs and Tourism (April 1998). This process is summarised in Figure 5.1. Furthermore, the EIA has been prepared to meet the EIA process requirements of organisations such as the International Finance Corporation (IFC) as documented in the IFC’s Procedure for the Environmental and Social Review of Projects (IFC, 1998). The EIA process was based on accepted international best practice for impact assessment. This included:

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Appropriate and timely access to the process for all interested and affected parties (I&APs); Process and timing of the assessment is agreed upon in advance with participants; Process is aligned with the legal requirements and has clear purpose and well-defined responsibilities; Opportunities for stakeholders to contribute to the process are tailored according to their circumstances; Scoping focuses on identifying and reaching closure on the key issues to be addressed; Detailed terms of reference are developed for specialist studies and verified with I&APs; Specialist studies are peer reviewed to ensure objectivity and professionalism; The EIA informs the design and implementation phase of the project; The project is assessed in a holistic context, taking into consideration the goals of sustainable development; Information and outputs are presented in a readily understandable and usable format in order to assist decision-making.

The EIA process incorporates three overlapping, interactive processes, namely a technical process, a process with the lead agents and authorities, and a public participation process.


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The technical process includes development of an understanding of the technical issues involved in the project, development of terms of reference for specialist studies, undertaking the specialist studies and integration of


the specialist findings into an Environmental Impact Report (EIR). This process involves discussion and information sharing between the CSIR EIA team, the specialists, Aluminium Pechiney, the Coega Development Corporation and the National Ports Authority. The latter two organizations are involved in this process due to the fact that both would provide infrastructure and services to Aluminium Pechiney; are responsible for management of compliance with the Record of Decision (ROD) conditions for the IDZ and Port under which Aluminium Pechiney will be required to operate; and would be involved in the management of impacts associated with the project if it proceeds. The Eastern Cape provincial Department of Economic Affairs, Environment & Tourism (DEAE&T) has been given the responsibility for issuing the decision on whether or not to authorise Aluminium Pechiney’s application to construct and operate an aluminium smelter within the Coega IDZ. Over the course of the EIA the CSIR has engaged with DEAE&T and other relevant authorities (including the national Department of Environmental Affairs and Tourism) in order to ensure that issues and concerns raised by the authorities can be integrated and addressed at an early stage of the EIA process and to contribute towards the authorities’ understanding of potential environmental impacts and mitigatory measures. The public participation process was run by Sandy & Mazizi Consulting and conducted concurrently with the technical and lead agent / authority processes. Section 5.2 of this report summarises public participation for the Scoping Phase of the EIA and section 5.4 outlines the process for the Environmental Impact Report phase. For further information on the purpose and principles of public participation, refer to section 5.4 of the Final Scoping Report (CSIR, 2002a). As reflected in the Figure 5.1, a key component of the EIA is to ensure that stakeholder’s knowledge and concerns inform the environmental assessment. The EIA follows a step-by-step process, in consultation with stakeholders and specialists, to identify key issues and concerns related to the proposed development and to thoroughly investigate these. In this way it is possible to maximise the potential benefits of the proposed project for stakeholders as well as for Aluminium Pechiney; to mitigate the potentially negative impacts; and to identify any potential fatal flaws that may render the project environmentally unacceptable.


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EIA Report

Plan of Studyfor Scoping

Development Proposal(with alternatives)

Report reviewed by:Authorities, Specialists & I&APs

Review of Plan by:Authorities

Submit application to relevant authority

Consultations with key stakeholders

Accept Planof Study

AcceptReport

Consider application

Identify Key Issues and Alternativeswhich need further investigation

Authorities Review of Plan by:

Plan of Studyfor EIA

Not Approved

Complete Specialist Studies

Scoping Report

Report reviewed by:Authorities, Specialists & I&APs

Accept Planof Study

Amend Plan

Amend Report

Decisions

Reports

Activities

LEGEND

Amend Plan

Amend Report

Consider application

Undertake development

Record of Decision

Accept Report

Approved Conditionsof Approval

Environmental Management Plan Monitoring SystemAppeal

Normal flow

Possibleiteration

Possibleflow

Technical Scoping –Initiate Specialist Studies

Public Scoping Process –Finalise Specialist Terms

of References

Figure 5.1: EIA process flow diagram (based on South African EIA Regulations)


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5.2 Overview of the Scoping phase

This section contains a summary of the Scoping for this EIA, including the public participation process for Scoping. The Final Scoping Report was published in July 2002 (CSIR, 2002a) and approved by the authorities in August 2002.

5.2.1 Objectives of the Scoping phase

The objectives of the Scoping Phase of an EIA are to:

define the scope of the project and the studies to be done in a way which would result in a thorough and scientifically defensible Environmental Impact Report (EIR) and, if the project proceeds at the end of the EIA, to ensure that the proposed development will be executed in an environmentally sound manner.

identify the key issues of concern that should be addressed in the EIA Specialist Studies;

design the required work to understand and evaluate these key issues, and to address shortcomings in existing information.

Sub-objectives of Scoping, which are directed at laying the foundation for the EIA, are as follows:

identify and inform a broad range of stakeholders about the proposed development, to empower them with sufficient information to be able to identify environmental issues and concerns for further investigation in the EIA process, and to provide ample opportunity to all parties to exchange information, and express their views and concerns;

obtain the buy-in of the stakeholders for the EIA process per se, so that they will accept the ultimate findings of the EIA;

understand and fully document the environmental issues underlying the concerns and questions raised by stakeholders to focus the study on reasonable alternatives and key issues.

enrich the ultimate decision making by creating awareness amongst all stakeholders (I&APs, the authorities, technical specialists and the development proponent) of the trade offs with regard to economic growth, social equity and ecological sustainability.


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5.2.2 Steps in the Scoping Phase A detailed description of the public participation process for Scoping is provided in section 5.4.3 of the Final Scoping Report, with a summary provided below. Step 1 Pre-application consultation and submit Plan of Study for Scoping

A pre-application consultation was held with Mr Leon Els and Mr Andries Struwig of the Department of Economic Affairs, Environment and Tourism (DEAE&T) on 7 March 2002, where it was established that DEAE&T is the relevant authority for this EIA process. This informed the preparation and submission of the Plan of Study for Scoping.

Step 2 I&AP identification, registration and the creation of an electronic database

The identification and registration of I&APs was based on the existing Coega database which included 1184 I&APs at the start of the project. Identification and registration of I&APs was ongoing for the duration of the study. Stakeholders from a variety of sectors, geographical locations (local, provincial, national, international) and/or interest groups have expressed an interest in the development proposal and been consulted as part of the public participation process. For example:

• National, Provincial and Local Government. • Coega Development Corporation (CDC) • National Ports Authority of South Africa (NPA) • Local interest groups (eg. rate payers associations and health groups) • Agriculture (formal and informal) • Citrus industry • Surrounding land owners • Industry and mining • Commerce • Tourism • Labour • Environment • Grassroots communities • Non Government and Community Based Organisations.


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The establishment of an electronic database and the customization of existing information to suit the needs of this project, assisted in conducting the Public Participation Programme (PPP). As of the 1 July 2002, the I&APs registered on the


database had grown to 1416 (Appendix B). Stakeholders for this EIA have been identified through the following mechanisms:

The existing database for previous EIA's conducted for the Coega project • • • •

Responses to advertisements placed in print media Attendance at the Public Open Day, networking and focus group meetings The proactive identification of I&APs based on the experience of the EIA team.

An additional mechanism to identify stakeholders is to ask other stakeholders during the course of networking to identify omissions from the existing database. I&APs on this database have received all project documentation (whether they request it or not); have been personally invited to attend public meetings and public open days; as well as being notified of the availability of reports for their comment and input. Communication and capacity building with I&APs was an ongoing activity for the duration of the EIA process. Step 3 Project announcement The development proposal and associated environmental assessment process was widely announced, with an invitation to the general public to register as I&APs and to actively participate in the PPP. This has been achieved via the following:

• A letter of invitation to all 1184 I&APs captured on the database at the outset of the EIA

• Print media advertisements in local and regional newspapers, requesting I&APs to register their interest in the EIA and attend an initial Public Meeting. Advertisements were placed in the following newspapers: o Die Burger o East Cape Weekender o The Herald

• Dissemination of a Briefing Paper (with letters of invitation), to key stakeholders and also to I&APs who registered as a result of advertising

• Provision of information on the website for the Aluminium Pechiney EIA, which is hosted by the CSIR (http://smelter.csir.co.za)

• A “Question and Answer Booklet” to facilitate communication and understanding on the proposed project was distributed to all I&APs on the database.


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Step 4 Consultation with I&APs (including authorities) A number of consultation meetings were held with authorities1 and key stakeholders. The purpose of these meetings was to provide I&APs with background information on the project, EIA and Public Participation Process in order for them to identify environmental issues and concerns for investigation in the EIA. The following meetings were held to facilitate input to the Draft Scoping Report:

A public meeting was held on 24 April 2002 at the Port Elizabeth City Hall, where I&APs had the opportunity to find out more about the EIA process and the proposed project, as well as to raise issues and concerns. Aluminium Pechiney’s technical manager and environmental manager for the PAS 2005 Smelter project were present at this meeting as well as representatives from the CSIR. Networking meetings formed an ongoing activity for the duration of the project. They were generally one-on-one meetings between the Public Participation Consultant and a specific group, organisation and/or individual e.g. Wildlife and Environment Society, a Ward Committee and its structures, or affected land owners. Telephonic consultations were also held with key I&APs to obtain their initial inputs into the process. Meetings were arranged by the CSIR (as the independent consultant) with the authorities at local, regional and national level throughout the environmental assessment process, particularly when milestones were reached. It should be noted that all public participation documents were also distributed to the authorities.

Step 5 Compile issues trail Based on the initial process of networking and consultation, the public participation consultant (Sandy and Mazizi Consulting) compiled a draft issues trail that included all relevant comments provided at public meetings, networking meetings and telephonic consultation or submitted via fax, email or telephone prior to the release of the Draft Scoping Report. The issues trail was updated regularly during the Scoping phase.


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1 The involvement of the authorities is not in a decision making capacity. Rather, the authorities will be invited to participate and contribute issues/provide guidance in relation to Scoping and the EIA.


Step 6 Prepare and distribute Draft Scoping Report

The Draft Scoping Report was then prepared based on environmental issues identified through both the specialist’s input and the public participation process. The CSIR obtained inputs from the EIA specialist team when evaluating and responding to issues raised through the public Scoping process. These technical inputs were important to understanding the nature and scope of issues that were addressed either through the Scoping Report or in the EIA. The Draft Scoping Report was made available to the public and authorities through the following mechanisms:

• Mailing a summary booklet to all I&APs on the database; • Presentations at Public Meetings on 3 - 5 June 2002 in the Nelson Mandela

Metropolitan area; • Poster displays at the Public Open Day on 4 June 2002 in Port Elizabeth; • Reports mailed or hand delivered to key authorities and key stakeholders; • Reports placed at 17 public libraries in the Port Elizabeth-Despatch-

Uitenhage area and the University of Cape Town; and • EIA website hosted by the CSIR (http://smelter.csir.co.za).

I&APs and the general public were notified of the availability of the Draft Scoping Report as follows:

• By written correspondence extending an invitation to all I&APs on the database to attend the Open Day and/or Public Meeting.

• Advertisements placed in the local and regional newspapers notifying I&APs of the availability of the Draft Report, Open Day and Public Meetings, namely

o Die Burger o The Herald o East Cape Weekender.

I&APs were also updated at various stages of the EIA process and notified of timeframes and opportunities for participation and input. Step 7 Obtaining comments on the Draft Scoping Report


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A 21-day comment period was provided for the Draft Scoping Report. A number of opportunities were provided for I&APs to interact around the Draft Scoping Report, namely, an Open Day, Public Meetings, networking and focus group meetings. The primary purpose of these interactions was to discuss the report and obtain detailed


comments from the general public and identify additional environmental issues and concerns for inclusion in the Final Scoping Report. These interactions are summarized below:

Open Day - A public Open Day, to which all I&APs on the database were invited, was held on the 4 June 2002 at the PE City Hall. At this event the Draft Scoping Report was presented in the form of a poster display and I&APs were invited to interact with representatives of the CSIR and Aluminium Pechiney who were present to engage with I&APs around the document. A total of 41 I&APs are registered as having attended this meeting.

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Public Meetings - The following Public Meetings, to which all I&APs on the database were invited, were held:

Date Venue Attendance 3 June 2002 Centenary Hall, New Brighton 206 4 June 2002 Raymond Mhlaba Sports Centre, Motherwell 64 5 June 2002 Valentine Hall, Addo 2 5 June 2002 Babs Madlakane Hall, Uitenhage 334

At the public meetings a presentation on the Draft Scoping Report and the proposed project was given to those present. Representatives of the CSIR and Aluminium Pechiney were present to engage with I&APs and respond to issues raised. Environmental issues raised by I&APs at these meetings were included in the issues trail of the Final Scoping Report . In addition, all public meetings were audio-recorded.

Networking Meetings - These one-on-one meetings between the Public Participation Consultant and key groups, organisations and individuals are discussed in Step 4 above. They form an important component of the public participation process in developing the capacity of I&APs to participate in the process and the identification of environmental issues and concerns for consideration by the specialist consultants.

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Focus Group Meetings - Three focus group meetings were held during the Scoping Phase of the EIA process. Focus group meetings are sector-based meetings as opposed to one-on-one meetings with an individual or a specific organisation. The purpose of these meetings is to develop the capacity of a specific sector to facilitate their input into and understanding of the EIA process. Sector meetings were held as follows:


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Sector Participants Invited Attendance Environmental Sector

Environmental groups, authorities, academic institutions, and SANParks

5

Labour Labour unions within Cosatu 148 Civil Society South African National Civics Organisation

(SANCO), alliance structures, ward representatives, community based organisations, NGOs, and Political Parties

74

At these meetings a detailed presentation was given on the Draft Scoping Report and I&APs were provided the opportunity to raise issues and concerns. The meeting with the environmental sector entailed a site visit to the Coega IDZ. As previous participation processes for the Coega project have entailed a site visit for the Civil Society and labour sectors, this was not done at this stage of the process.

Step 8 Updated Issues Trail The Issues Trail contained in Chapter 6 of the Final Scoping Report was updated by the Public Participation consultant, based on the feedback received during the Scoping process. Copies of written comments received via email, fax or mail is contained in Appendix H of the Final Scoping Report. Step 9 Final Scoping Report The Final Scoping Report was prepared based on the comments received on the Draft Scoping Report and submitted to the authorities for review and authorization by DEAE&T. Although not intended for further public comment, the Final Scoping Report was placed in public libraries, hosted on the EIA website and submitted to key stakeholders. All I&APs on the database were informed via written correspondence of the availability of the Final Scoping Report. Step 10 Authority review and approval of Final Scoping Report

The Final Scoping Report was submitted to DEAE&T and other authorities for review and decision-making; and approved by DEAE&T in August 2002.

FINAL ENVIRONMENTAL IMPACT REPORT CSIR, 2002 page 5-10


Step 11 Finalise Terms of Reference for specialist studies Once the key issues requiring further investigation were identified and all comments from I&AP’s and the authorities received, the EIA team reviewed whether any additional issues needed to be added to the specialist’s Terms of Reference, or whether any additional specialist studies were required. The finalized list of specialist studies and Terms of Reference was compiled into the Plan of Study for the EIA. 5.2.3 Focus of the EIA

Primary aluminium smelting comprises one stage of the aluminium life cycle. This life cycle starts with the mining of bauxite. Bauxite is refined to produce alumina, which is the raw material used in primary aluminium smelting. The final product of the smelting process (the aluminium ingots) are processed further prior to being used in the production of manufactured goods. At the end of the manufactured product’s life, the scrap can be collected and recycled by a secondary smelting process. Secondary smelting consumes up to 95% less energy than that required for the primary smelting process and aluminium can be repeatedly recycled without its quality being impaired. A range of environmental impacts are associated with different stages of the life cycle. Although impacts associated with different stages may be highly significant, it is beyond the scope of this EIA to conduct an environmental assessment of the full aluminium life cycle. The focus of the EIA is therefore confined to the construction and operation of a primary aluminium smelter within the metallurgical cluster in the Coega IDZ (Figure 5.2).



Figure 5.2: Identifying the focus of the Aluminium Pechiney EIA with respect to the aluminium lifecycle

Aluminium life cycle assessment

The International Aluminium Institute is undertaking a study to understand the positive and negative impacts of aluminium during the entire life cycle of the material and covering the main applications of aluminium. Reports of the use of aluminium in automobiles and in construction have been completed and can be found on the International Aluminium Institute’s website: http://www.world-aluminium.org

Source: International Aluminium Institute (2002) Although a detailed assessment of the impacts associated with electricity generation, is not included in this environmental impact assessment, the scale of the project and its associated electricity requirements warrant that this issue is taken into account in the decision-making process due to both the national and global implications this may have. The EIA does not include an assessment of occupational health and safety risks for employees working within the smelter. For example, the EIA has assessed the impact of noise of the smelter on the surrounding area (measured from the boundary of the site) but not on employees working within the smelter. However, it must be pointed out that Aluminium Pechiney undertake, as a minimum, to meet the requirements of South African labour legislation, for example, the Occupation Health and Safety Act (Act 85 of 1993).


Aluminium Pechiney EIA

http://www.world-aluminium.org/


An assessment of the impacts associated with the potential future expansion of the smelter (to include a second potline) is beyond the scope of this EIA. If, at some stage in the future, a second potline is proposed, then this will require a separate EIA in accordance with national legislation. Similarly, the assessment cannot consider the cumulative effects associated with other industries locating within the Coega IDZ in future and contributing to waste streams, emissions levels, traffic increases, noise levels or socio-economic impacts etc. There is currently no information available upon which to base such an assessment. The cumulative impacts can only be assessed when definite proposals for other projects are being considered. However, the specialist studies conducted for the Aluminium Pechiney EIA do take cognisance of the current situation and the existing stresses that may already exist. As such, the EIA does include the cumulative impacts on the current environment by taking cognisance of, for example, the current ambient air quality, current socio-economic characteristics of the area (e.g. poverty and unemployment levels) and the current capacity and status of existing waste disposal sites. Given the long-term nature of this project, and the uncertainty regarding future developments, it is not possible in this EIA to assess the environmental impacts associated with decommissioning.

5.2.2 Description of feasible alternatives The alternatives considered in this EIA fall into two categories – those associated with the “No Go” alternative, and those associated with the “Go” alternative. Each of these two categories includes a number of secondary alternatives, which are outlined below and are considered in the EIA.

Consideration of the “No Go” Alternative Future development options for the region:

The EIA identifies the potential opportunity losses/gains for the Eastern Cape, based on the premise that Aluminium Pechiney is not granted authorization to establish an aluminium smelter within the Coega IDZ (refer to section 17.4).



Consideration of the “Go” alternative

Process and technology alternatives

Based on the use of AP50 technology, specialist studies consider alternatives which may be feasible and which could be incorporated into the proposal, taking into account the specific design constraints of the aluminium smelting process and technology used. These may include, for example, alternative noise mitigation measures, alternative emission reduction options and alternative materials handling procedures.

Alternative associated infrastructure

A detailed assessment of the impacts of associated infrastructure required by the project during construction and operation is beyond the scope of this EIA. These impacts will be, or are currently being, assessed in separate EIA processes. However, the Aluminium Pechiney EIA includes a set of principles to be taken into account, for example, in the design of the water supply and stormwater management system and transport infrastructure.

Alternative waste management options

Alternatives for the management of the various waste streams (solid, liquid and gaseous) are considered, including the potential for minimization, re-use or recycling of waste. Alternative waste disposal options are also considered.

Alternative benefit enhancement mechanisms The EIA identifies possible options that may improve the potential for the project to promote economic growth in the Eastern Cape region and South Africa and improve social equity in the distribution of these benefits, without compromising the ecological integrity of the surrounding area.

The following alternatives are not considered within this EIR:

Alternative locations for development outside the Coega IDZ

Alternative sites were assessed by Aluminium Pechiney prior to the selection of the Coega IDZ as one of three sites at which to conduct further indepth studies. Currently, detailed engineering, planning and environmental studies are underway in Australia to assess the feasibility of this as an alternative to locating within the Coega IDZ.

Alternative locations for development within the Coega IDZ


Previous environmental assessment studies identified areas within the IDZ which would be best suited for particular types of industrial development, taking into account the geotechnical, slope and biological characteristics of different areas. The current IDZ layout therefore includes a metallurgical


cluster, automotive cluster, electronic and technical cluster, as well as “no go” areas for development. The proposed smelter site is located within the designated metallurgical cluster.

Alternative site layouts

The proposed siting and layout of the smelter within the metallurgical cluster of the IDZ has been optimized for a range of aspects such as general site geotechnical conditions, proximity of proposed IDZ and Port infrastructures and their relationship with smelter material flows, and compatibility with IDZ “no go” areas.

Demand alternatives

The increasing demand for primary aluminium metal is a motivating factor for the Aluminium Pechiney project proposal. The option of meeting this demand through other means, such as aluminium recycling and secondary smelting, will not be assessed in this EIA. Secondary smelting is not an option that Aluminium Pechiney is considering as a feasible alternative for their proposed project and for meeting the projected demand growth. A secondary smelting project would therefore need to be proposed by another proponent, and evaluated on the basis of that particular proposal.

Alternative aluminium smelting technology

Existing aluminium smelters make use of older technology such as AP 18 and AP 30. While these are feasible technology alternatives, Aluminium Pechiney has selected to use the new generation AP 50 technology due to the significant capital and operating cost advantages that this presents.

Alternative economic sector development opportunities

This EIA is based on the premise that these alternatives were taken into account in previous decision-making processes that led to the authorisation of the Coega IDZ and approval of the Rezoning EIA by the national Department of Environmental Affairs and Tourism.

5.2.3 Key environmental issues identified during Scoping


The full list of issues and concerns identified during the Scoping phase, both through the public participation process (including interested and affected parties and relevant authorities) and through technical Scoping with the specialists and Aluminium Pechiney were included in the Final Scoping Report (CSIR, 2002a). The issues and concerns raised were analysed using professional judgement, knowledge of the affected environment, previous experience of southern African aluminium smelters and available information, in order to identify key issues that would require further


assessment in the next phase of the environmental impact assessment, i.e. the specialist studies and impact assessment phase. Some issues were comments/questions that could be responded to immediately in the Final Scoping Report and did not require further investigation. The remaining issues fall into the following three categories:

• Key issues within the scope of this EIA that are addressed in the specialists

studies or through additional inserts sourced by the CSIR EIA team, and covered in this EIR (Table 5.1);

• Key issues that fall beyond the direct scope of this EIA, but on which information is provided in this EIA in order to place the proposed smelter project in context (eg. electricity generation issues) (Table 5.2);

• Issues that are not addressed in this EIA because they either fall beyond the scope of the EIA or are addressed in other environmental assessments and related studies (Table 5.3).

To assist in the identification of key issues the following criteria were used:

1. Whether or not the issue raised falls within the scope and responsibility of the Aluminium Pechiney EIA process?

2. Whether or not the issue raised has associated implications for environmental permit and licence applications?

3. Whether or not sufficient information is available to respond to the issues or concern raised without further specialist investigation?

Table 5.1: Key issues identified through the Scoping process that were addressed in the specialist studies and through inputs from the EIA team

Specialist Study Key Issues Materials handling and

solid waste Identification of potential dust generation points and potential spillage risks during handling of materials (at the Port of Ngqura and at the smelter). Impacts to be assessed in the Water use and liquid waste specialist study, as well as in the Water discharges to the marine environment specialist study. Impacts on existing landfill capacities due to the volume of waste generated. Impacts of alternative disposal of hazardous wastes. Identification of the best practicable environmental option for the disposal of spent potlinings. Safe storage and handling of hazardous materials and waste. Identification of opportunities for re-use and recycling of by-products.

Air quality Impacts on human health in neighbouring communities and at the port. Compliance with air quality guidelines.



Specialist Study Key Issues

Identification of conditions under which plumes would be visible from the smelter. Contributions to South Africa’s greenhouse gas emissions (both as a result of direct smelter emissions, as well as a result of emissions generated in the production of electricity at coal-fired power stations).

Air emission impacts on plants and animals

Impacts on natural vegetation. Impacts on key local agricultural crops (eg. citrus and vegetables). Impacts on animals (e.g. rare butterfly species, angora goats and wild animals)

Water use and liquid waste

Impacts on existing local water supply capacities and water rates. Impacts of domestic wastewater discharge on existing capacity of the treatment works. Impacts of stormwater and process water discharge on the receiving environment (surface water and groundwater). Compliance with DWAF water quality guidelines. Identification of the best practicable environmental option for stormwater discharge from the Aluminium Pechiney site.

Water discharges to the marine environment

Impacts associated with the disposal of stormwater (including process water) on the marine environment and other users. Compliance with marine water and sediment quality guidelines. Identification of the best practicable environmental option for the location of the stormwater-process water discharge point. Impacts of potential spillages of raw materials at the port during unloading operations.

Traffic and

transportation Impacts on existing and planned road network capacity associated with the transport of personnel, raw materials, finished products and waste. Impact on road safety Impacts on the existing and planned road infrastructure. Impact on the biophysical environment due to the transportation of hazardous materials. Impacts of increased shipping traffic on the capacity of the Port Elizabeth harbour and the Port of Ngqura. Opportunities for alternative modes of transport.

Noise Impacts of increased noise generated during construction and operation by the smelter. Compliance with South African and World Bank noise standards.

Visual impacts Impacts on current landscape and “sense of place” Impact from critical viewpoints, in particular from the Greater Addo Elephant National Park. Magnitude of lighting at the St Croix and Jahleel islands and possible impacts on birds breeding on these islands Compliance with IDZ building and architectural guidelines.



Specialist Study Key Issues

Social impacts Employment equity in the recruitment process Impacts of in-migration of job-seekers Identification of training and capacity building opportunities Potential for SMME development Impacts on human health Impacts on local tourism

Macro-economics Impact on direct and indirect employment opportunities during construction and operations. Impact on Gross Domestic Product and Gross National Product. Impacts on upstream and downstream industries. Impact on national and local government revenues and the national balance of payments.

The following additional key issues were investigated by the integrative writers on the CSIR’s EIA team, drawing on available literature and expert opinion. These issues have been integrated into the EIR and are summarised below:

Table 5.2: Additional issues raised through Scoping that are addressed in the EIR

Issue Section of the Final EIR where this

issue is addressed The relative contribution of the Aluminium Pechiney smelter to the air and water emissions associated with electricity generation in South Africa.

This issue is considered to fall beyond the direct scope of this EIA. Nonetheless, information is provided in Section 16.1 of the Final EIR in order to provide a wider context of possible positive and negative impacts associated with the proposed project.

The impacts of constructing the conveyor belt along the western edge of the Coega estuary and across “Butterfly Valley”.

This issue had been addressed in the Subsequent Port of Ngqura EIA (CES, 2001). Relevant information and suggested mitigation is, however, included in Section 16.2 of the Final EIR.

A number of issues were identified through the Scoping Process which were not addressed in the specialist studies or the Environmental Impact Report. The following table (Table 5.3) summarises the issues that were excluded based on the reasoning provided above.



Table 5.3: Issues raised in the Scoping process which were not included in the Aluminium Pechiney EIA specialist studies and EIR


Issues addressed in other environmental assessments and related studies

Issues beyond the scope of the aluminium Pechiney EIA

Subsequent Port of Ngqura EIA(CES, 2001) • Impacts of cut-and-fill activities to

establish aluminium and liquid pitch storage facilities at the Port of Ngqura.

• Impacts of the construction and operation of the Port of Ngqura on neighbouring abalone farms.

• Conditions of the EIA related to the future of neighbouring abalone farms.

• Future employment opportunities of the employees at the existing Saltworks.

IDZ Rezoning EIA (CES, 2000) • Impacts of sewage discharge from the

Fishwater Flats sewage treatment works to the marine environment.

• Impacts of the Port of Ngqura and the wider Coega IDZ on existing landuse and economic activities within, or neighbouring the IDZ.

• Impacts from provision of a conveyor corridor from the Port to the IDZ

EIA for the new regional general & hazardous waste disposal facility (being undertaken Bohlweki Environmental) • Impacts associated with the

development of a new hazardous waste disposal site.

CDC Training Providers Capacity Audit (prepared by CDC and Tramanser, 2002) • Capacity of local training institutions to

provide necessary skills training. • Availability of relevant local skills. EIA for construction village (Metroplan, 2002) • Impacts of the construction village on

Motherwell and Wells Estate Eskom EIA for powerlines from Grassridge to Coega (being undertaken Bohlweki Environmental) • Impacts associated with the construction

of transmission lines from the Grassridge substation to the smelter site.

Wider IDZ development • The potential future discharge of sewage to

the marine environment from a dedicated IDZ sewage treatment works.

• Impacts associated with the potential future expansion of the commuter rail line from Uitenhage to Motherwell.

• Detailed transportation planning for the IDZ, including future potential commuter and freight rail options.

• Impacts of blasting at Coega Kop on surrounding industries, houses and hazardous waste disposal sites.

• Cumulative impacts of other developments which may establish within the IDZ in future.

• Impacts associated with the provision of infrastructure to the IDZ (roads, wider IDZ stormwater system etc)

• Comparison of job creation potential of tourism and agriculture versus industrial development.

Aluminium Pechiney development • Occupational health and safety risks of

employees working at the smelter. • Assessment of the potential for

establishing a secondary aluminium smelting plant as an alternative to the primary aluminium smelter.

• Assessment of opportunities for conserving an equivalent area of Bontveld to replace loss of vegetation on the smelter site.

• Detailed assessment of alternative recruitment processes ie. Direct recruitment vs use of CDC Labour and Business Management Services.

• Detailed assessment of the future employment options of construction workers following the completion of the Aluminium Pechiney smelter.

• Impacts associated with any future expansion of the aluminium smelter.

• Feasibility assessment for the development of downstream aluminium industries in the area (either by Aluminium Pechiney or


Issues addressed in other environmental assessments and related studies

Issues beyond the scope of the aluminium Pechiney EIA

other industries). • Detailed assessment of impacts associated

with decommissioning. Electricity generation and supply • Detailed assessment of the impacts and

externality costs associated with electricity generation to meet the requirements of the smelter.

• Potential future expansion of the powerlines to the Coega IDZ in the event that additional power is required.

• Detailed assessment of the impact of Aluminium Pechiney’s electricity demand on electricity costs within the NMMM.

Monitoring and enforcement capacity of authorities • Capacity audit of the authorities

responsible for future monitoring and enforcement of conditions of the ROD and permits.

Other • Opinion of Australian ratepayers to the

possibility of establishing the smelter in Australia.

5.3 Approach to specialist studies and impact assessment


Ten specialist studies were commissioned to assess and determine the significance of the key issues identified through the Scoping phase which may negatively or positively impact on the biophysical, social and economic environment (Figure 5.3). Where negative impacts are identified, mitigation objectives (i.e. ways of reducing negative impacts) are identified and attainable mitigation actions recommended. Where no mitigation is feasible, clear reasons are given. Where positive impacts are identified, actions to enhance the benefit are recommended. In addition, monitoring and review programmes have been recommended in order to assess the effectiveness of mitigation. Quantifiable standards for measuring the effectiveness of management actions, monitoring and review should be set as part of the proposed Environmental Management Plan.


ECONOMICBIOPHYSICAL

SOCIAL

• Materials handling and solid waste

• Air quality

• Air emission impacts on vegetation and agriculture

• Water use and liquid waste

• Water discharges to the marine environment

• Traffic and transportation

• Noise

• Visual impacts

• Social Impacts

• Macro-economics

SUSTAINABLE

DEVELOPMENT

Figure 5.3: Specialist studies undertaken for the Aluminium Pechiney EIA in terms of the components of sustainable development The scope of the studies, as well as the final terms of reference were informed by comments received through the public participation process during the Scoping phase, as well as by the experience of the project team from previous EIAs conducted for aluminium smelters and large industrial developments. Responses from the specialists to the issues raised during the public participation processes have been included as appendices to the specialist studies contained in the Specialist Studies Report (CSIR, 2002b). Linkages between the specialist studies were identified from the outset of the process in order to ensure that all key issues would be assessed and that duplication of work would be avoided. In some cases the results of one specialist study formed the basis of assessing impacts down the line.

5.3.1 Method of assessing significance of impacts


The classification of an issue as a ‘key issue’ during the Scoping phase does not necessarily imply that a significant impact will result. The significance of


the impact can only be ascertained once a specialist study has been conducted. After such an assessment it is possible that a key issue may turn out to have an impact of low significance. The following methodology for assessing impacts and assigning significance to the key issues identified through the Scoping process is applied in the specialist studies and the Environmental Impact Report. Assessment of impacts

The significance of potential impact has been described as follows:

Low: Where the impact would not have an influence on the decision or

require to be significantly accommodated in the project design; Medium: Where it could have an influence on the environment which would

require modification of the project design or alternative mitigation; High: Where it could have a ‘no-go’ implication for the project regardless

of any possible mitigation.

The assessment of impact significance was based on the following convention:

Nature of impact - this reviews the type of effect that a proposed activity would have on the environment and should include “what would be affected and how?”

Extent - this should indicate whether the impact would be limited to the site; local (limited to within 5km of the development); or whether the impact may be realised regionally, nationally or even globally.

Duration - this should review the lifetime of the impact, as being short term (0 - 5 years), medium (5 - 15 years), long term (>15 years but where the impacts would cease after the operation of the site), or permanent.

Intensity - here it should be established whether the impact is destructive or innocuous and should be described as either low (where no functions and processes are affected), medium (where the environment continues to function but in a modified manner) or high (where functions and processes are altered such that they temporarily or permanently cease).


Probability - this considers the likelihood of the impact occurring and should be described as improbable (low likelihood), probable (distinct possibility), highly probable (most likely) or definite (impact would occur regardless of prevention measures).


The status of the impacts and degree of confidence with respect to the assessment of the significance, was stated as follows:

Status of the impact - A description as to whether the

impact would be positive (a benefit), negative (a cost), or neutral.

Degree of confidence in predictions - The degree of confidence in the predictions, based on the availability of information and specialist knowledge.

Other aspects taken into consideration in the assessment of impact significance are:

Impacts should be described both before and after the proposed mitigation and management measures have been implemented.

Impacts should be evaluated, where possible, for the full lifecycle of the proposed development, including construction, operation and decommissioning. (Note: Pre-construction activities are not included, as the initial site preparations for the smelter plant will be undertaken by the Coega Development Corporation in accordance with conditions stipulated in the Record of Decision issued for the Rezoning EIA for the IDZ.). Given the long life of the smelter, impacts associated with decommissioning could not be assessed in this EIA.

The impact evaluation should, where possible, take into consideration the cumulative effects associated with this and other facilities which are either developed or in the process of being developed in the IDZ.

The impact assessment should attempt to quantify the magnitude of potential impacts (direct and cumulative effects) and outline the rationale used. Where appropriate, national standards should be used as a measure of the level of impact.

The impact assessment should identify the best practicable environmental option (BPEO).

Defining “Best Practicable Environmental Option”


The best practicable environmental option (BPEO) is defined as being the option that provides the most benefit, or causes the least damage to the environment as a whole, at a cost acceptable to society, in the long-term as well as in the short-term (National Environmental Management Act, No 107 of 1998). In terms of the Aluminium Pechiney proposal, the identification of the BPEO is differentiated from impact mitigation and benefit enhancement measures in that the identified option involves a decision regarding fundamental design alternatives for the project.


5.4 Overview of the Environmental Impact Report phase The results of the specialist studies were integrated into a draft Environmental Impact Report (CSIR, 2002c). This was made available to relevant authorities and was made available to the interested and affected parties for comment. This section outlines the public participation process for the review of the Draft Environmental Impact Report, and the additional consultation with authorities during this stage of the EIA.

Step 1 Notification to I&APs of the Release of the Draft EIR for Comment The availability of the Draft Environmental Impact Report for a 28-day comment period from the 23 September 2002 to the 21 October 2002 was widely announced. I&APs were notified of the availability of the report, public meetings to be held and the time period to submit comments. Announcements were made via the following mechanisms:

• Print media advertisements in local and regional newspapers, notifying I&APs of the availability of the Draft EIR, time period to comment and opportunities to attend an Open Day and Public Meetings (Appendix A): o Die Burger o East Cape Weekender o The Herald.

• A letter of notification sent to all I&APs on the database (1440 at the time) notifying them of the availability of the Draft EIR, the Open Day, Public Meetings to be held and the time period to comment (Appendix C). (The final I&AP database is provided in Appendix B).

• Inclusion of dates and times of meetings and comments period on the EIA project website (http://smelter.csir.co.za).

Step 2 Availability of the Draft EIR and Information Sharing

The Draft EIR was made available locally, nationally and internationally through the EIA website hosted by the CSIR (http://smelter.csir.co.za). In addition, it was made available as follows:

• Copies of the Draft EIR were placed at 17 public libraries in the Port Elizabeth-Despatch-Uitenhage area and the University of Cape Town;


• Key Authorities and key I&APs were provided with a printed copy or CD of the Draft EIR and/or specialist studies report;


• A summary book of the Draft Environmental Impact Report was mailed to

all 1440 I&APs on the database, and made available at all public meetings, focus group meetings and the Open Day.

• A poster display of the findings of the Draft EIR was available for review at the Open Day; and

• A presentation on the findings of the Draft Environmental Impact Report was made to authorities and at all public meetings and focus group meetings

Step 3 Obtaining comments on the Draft Environmental Impact Report A 28-day comments period was provided for the Draft Environmental Impact Report. A number of opportunities were provided for I&APs to interact around the Draft EIR, as described above. The primary purpose of these interactions was to present and discuss the key findings of the Draft EIR and obtain detailed comments from I&APs and the general public. These interactions are summarized below:

Open Day - A public Open Day, to which all I&APs on the database were invited, was held on the 1 October 2002 at the East Cape Training Centre. At this event the Draft EIR was presented in the form of a poster display and I&APs were invited to interact with representatives of the CSIR and Aluminium Pechiney who were present to engage with them around the document. A total of 21 I&APs are registered as having attended this meeting.

•

•

Public Meetings - The following Public Meetings, to which all I&APs on the database were invited, were held:

Date Venue Attendance 1 October 2002 Centenary Hall, New Brighton 185 2 October 2002 Raymond Mhlaba Sports Centre, Motherwell 289 3 October 2002 Babs Madlakane Hall, Uitenhage 280

No Public Meeting was held at Addo for the release of the Draft EIR due the poor attendance during the Scoping Phase; and taking into account that CSIR and Aluminium Pechiney met separately with the Sundays River Citrus Company.


At the public meetings a presentation on the Draft Environmental Impact Report and the proposed project was given to those present. Representatives of the CSIR and Aluminium Pechiney were present to engage with I&APs and respond to questions and queries. Appendix D


contains notes from the Public Meetings. Comments made at these meetings have been summarised and are included in the Comments and Response Trail which is included as Chapter 17 of this report. In addition, all public meetings were audio-recorded.

Focus Group Meetings - Two focus group meetings were held during the Draft EIR Comments Period. The purpose of these meetings was to provide an additional platform for key I&AP groupings to receive information on the outcome of the Draft EIR and make their comments. These meetings also play a role in developing the capacity of a specific sector to facilitate their input into and understanding of the EIA process. Sector meetings were held as follows:

•

Sector Participants Invited Attendance Environmental Sector

Environmental groups, authorities, academic institutions, and SANParks

10

Civil Society South African National Civics Organisation (SANCO), Labour Unions, alliance structures, ward representatives, community based organisations, NGOs, and Political Parties

27

At these meetings a detailed presentation was given on the Draft Environmental Impact Report and I&APs were provided the opportunity to raise queries and make comments. Appendix E contains the notes from these meetings. Other Meetings – In addition to the meetings held above the CSIR (as the independent consultant for the EIA process) arranged additional meetings with the authorities at local, regional and national level to present and discuss the findings of the draft EIR. Furthermore, meetings were also arranged with other key stakeholders, for example SANParks and the Sundays River Citrus Company.

•

Step 4 Comments and Response Trail

The comments made at all meetings, received in writing or via email have been summarised and included in the Comments and Response Trail contained in Chapter 17 of this report. These comments were forwarded to the CSIR for the coordination of responses from the relevant sources and for consideration in the preparation of the Final EIR.



Step 5 Compile and submit final EIR

The Final EIR (this report, dated November 2002) incorporates comments on the draft report provided by a wide range of sectors. Comments were provided by communities, NGOs, businesses, environmental groups; as well as the authorities and parastatal bodies, such as DWAF, DEAT, Coega Development Corporation (CDC), National Ports Authority and Eskom. A summary of comments is included in the Comments and Response Trail (Chapter 17). Responses are provided by CSIR, and where necessary from Aluminium Pechiney and CDC. This Final EIR was submitted in early November 2002 to the relevant authority, DEAE&T.

Step 6 Authority review of final EIR and record of decision

A four week period, from early November to early December 2002, is proposed for authority review of the Final EIR. Thereafter, the relevant authority (DEAE&T) will issue the Record of Decision with regard to this EIA application. All interested and affected parties will be informed by the CSIR/Sandy and Mazizi Consultants as soon as the Record of Decision has been issued. The EIA regulations allow for a 30 day appeal period should interested and affected parties be concerned with the decision and wish to submit an appeal.

Step 7 Preparation of environmental management plan

An Environmental Management Plan for the construction and operational phases of the project will be prepared by the CSIR. This will incorporate and further detail the recommendations made by specialists and included in the EIR.




5.5 EIA study team The EIA study team is provided in Table 5.4. Table 5.4: EIA Study Team

EIA integration role EIA team member and their affiliation EIA Project Manager Paul Lochner, CSIR EIA Technical Manager Rob Hounsome, CSIR Integrative writing Frauke Munster, CSIR

Dr Mike Burns, CSIR Internal review and quality control Patrick Morant, CSIR Public Participation Process: Manager Sandy Wren, Sandy and Mazizi Consulting Public Participation Process: Facilitator Mazizi Msutu, Sandy and Mazizi Consulting Public Participation Process: Wandile Junundu, Sandy and Mazizi Consulting

Lumka Betela, Sandy and Mazizi Consulting Specialist study Specialist(s) and their

affiliation Independent reviewer

1. Materials handling and solid waste

Sanjeev Raghubir, CSIR Auntony Mukhwanazi, CSIR Dr Sibbele Hietkamp, CSIR

Dr Dave Baldwin Environmental & Chemical Consultant

2. Air quality Including impacts of emissions on human health

Dr Mark Zunkel, CSIR Ridwan Haffejee, CSIR Yvonne Hong, CSIR Riëtha Oosthuizen, CSIR

Prof. Harold Annegarn Atmosphere and Energy Research Group, University of the Witwatersrand

3. Air emission impacts on vegetation and agriculture

Dr Amanda Botha, private consultant

Dr Bob Scholes, CSIR

4. Water use and liquid waste Philip de Souza, CSIR Grant Mackintosh, CSIR

Dr Andrew Brown Wates, Meiring & Barnard

5. Water discharges to the marine environment

Stephen Luger, CSIR Dr Pedro Monteiro, CSIR Roy van Ballegooyen, CSIR Susan Taljaard, CSIR Dr Trevor Probyn, Embecon

Dr Robin Carter Specialist Consultant, Applied Marine Sciences

6. Traffic and transportation Theuns Lamprecht, CSIR Dave Jones, CSIR

Derek Cosijn Calyx Environmental cc

7. Noise Klaus Weber, Vibracoust Francois Malherbe Acoustic Consulting cc

8. Visual impacts Bernie Oberholzer, Bernard Oberholzer Landscape Architects Quinton Lawson, Meirelles Lawson Architects

Alan Cave Cave, Klapwijk & Associates

9. Social impacts Johan van der Walt, ACER Africa Xolisa Ngwadla, ACER Africa Ashleigh McKenzie, ACER Africa Dr Dieter Heinsohn, ACER Africa

John Reynolds John Reynolds Consulting

10. Macro-economics Prof James Blignaut, University of Pretoria Prof NJ Schoeman, University of Pretoria

Dr Martin de Wit, CSIR Tony Leiman, School of Economics, University of Cape Town

Documents

DESCRIPTION OF THE ENVIRONMENTAL …fred.csir.co.za/project/smelter/eia_final_chapter_5.pdfPROPOSED ALUMINIUM PECHINEY SMELTER WITHIN THE COEGA IDZ 5. DESCRIPTION OF THE ENVIRONMENTAL