Waste Management Licence Application for the Fine Ash Dam (FAD) 6 Cement-Ash Mixing Plant for Undermining Stabilisation of Portions of the ...

 
Waste Management Licence Application for the Fine Ash Dam (FAD) 6 Cement-Ash Mixing Plant for Undermining Stabilisation of Portions of the ...
Waste Management Licence
Application for the Fine Ash
Dam (FAD) 6 Cement-Ash
Mixing Plant for Undermining
Stabilisation of Portions of the
Brandspruit Mine under FAD 6
using a Cement/Ash Mixture
Draft Scoping Report
DEA Reference Number: To be Confirmed

Report Prepared for

Sasol South Africa (Pty) Ltd

Report Number 521412

Report Prepared by

March 2018
Waste Management Licence Application for the Fine Ash Dam (FAD) 6 Cement-Ash Mixing Plant for Undermining Stabilisation of Portions of the ...
SRK Consulting: 521412: FAD 6 Mixing Plant WML: Draft Scoping Report                                                Page i

         Waste Management Licence Application for
         the Fine Ash Dam (FAD) 6 Cement-Ash Mixing
         Plant for Undermining Stabilisation of Portions
         of the Brandspruit Mine under FAD 6 using a
         Cement/Ash Mixture

         Draft Scoping Report

         Sasol South Africa (Pty) Ltd

         SRK Consulting (South Africa) (Pty) Ltd.
         Block A, Menlyn Woods Office Park
         291 Sprite Avenue
         Faerie Glen
         Pretoria 0081
         South Africa

         e-mail: pretoria@srk.co.za
         website: www.srk.co.za

         Tel: +27 (0) 12 361 9821
         Fax:+27 (0) 12 361 9912

         SRK Project Number 521412/Draft Scoping Report

         March 2018
          Compiled by:                                                      Peer Reviewed by:

            Ndomupei Masawi                                                 Dr Laetitia Coetser
            Senior Environmental Scientist                                  Principal Scientist/Associate Partner

            Email: lcoetser@srk.co.za
            Authors:
            Ndomupei Masawi

MAND/COES                                 521412 20180328_ FAD6 WML Draft Scoping Report_Final                 March 2018
Waste Management Licence Application for the Fine Ash Dam (FAD) 6 Cement-Ash Mixing Plant for Undermining Stabilisation of Portions of the ...
SRK Consulting: 521412: FAD 6 Mixing Plant WML: Draft Scoping Report                                       Page ii

         Executive Summary
         Introduction
         Sasol South Africa (Pty) Ltd (Sasol Secunda) has commenced with the construction of the Fine Ash
         Dam (FAD) 6 at the Sasol Secunda Industrial Complex (SSIC) in Secunda. The need for FAD 6 stems
         from the fact that the currently operational FAD 5 is nearing its end of life and a new disposal site is
         required for the disposal of fine ash material generated from the production process at the SSIC.

         The following authorisations have been obtained for the construction and operation of FAD 6:

             Environmental Authorisation (2012) (Reference number 17/2/3 GS-6) in terms of the National
              Environmental Management Act (Act No. 107 of 1998) (NEMA);

             Environmental Authorisation amendment (2015) (Reference number 17/2/6/3 (1-60) GS-60 in
              terms of NEMA);

             Environmental Management Programme (EMPr) Amendment (2015) (Reference number
              1/3/1/16/5 G-01) in terms of NEMA;

             Waste Management Licence (WML) (2015) (Reference number 12/9/11/L45369/6) in terms of the
              National Environmental Waste Act (Act No. 59 of 2008) (NEM: WA);

             Water Use Licence (2016) (Reference number 27/2/2/C412/4/4) in terms of the National Water
              Act (Act No. 36 of 1998) (NWA);

             Various approvals in terms of General Authorisations for associated infrastructure in terms of the
              NWA.

         The FAD 6 will cover areas that were previously mined for coal by the Brandspruit Mine. The coal
         seam was mined underground at a depth of greater than 120 m. An assessment of the surface stability
         of FAD 6 to be located over underground workings was conducted by Professor Nielen van der Merwe
         of Stable Strata Consulting with Jones & Wagener (Pty) Ltd. The assessment concluded that certain
         of the underground mine panels should be backfilled to ensure the long-term stability of FAD 6.

         It is proposed that fine ash from Sasol Secunda be recycled in a cement-ash mixing plant. A cement-
         ash mix (also referred to as ash-crete) will be produced at the mixing plant which will be used as
         backfilling material. The cement-ash mixing plant will be located within the FAD 6 footprint area in
         close proximity to the area where backfilling will be required.

         The recycling of the fine ash from Sasol Secunda and the construction, operation, maintenance and
         decommissioning of the cement-ash mixing plant triggers activities listed in Category B of GNR 921 of
         the NEM: WA and will therefore require a WML from the Department of Environmental Affairs (DEA).
         All activities listed in Category B of the GNR 921 require that a full Environmental Impact Assessment
         (EIA) (Scoping and EIA) be conducted as part of the application for a WML.

         Who is conducting the EIA/EMPr?
         SRK Consulting (SA) (Pty) Ltd (SRK) has been appointed by Sasol Secunda as the independent
         Environmental Assessment Practitioner (EAP) to conduct the WML application process for the project.

         The reports and documentation for the WML application process will be compiled and Finalised for
         submission to the DEA for the WML in terms of the NEMA for consideration and decision making. The
         DEA will consult with other government authorities as required in terms of Section 24(K) of the NEMA.

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         Who will evaluate the EIA/EMPr?
         Before the proposed development can proceed, approval has to be obtained from the regulatory
         authorities. The Scoping Report will be submitted to the DEA for review. The competent authorities
         will then advise the project team as to how the project should proceed for the impact assessment
         Phase of the project. The impact assessment Phase will entail detailed specialist investigations (the
         majority of the specialist studies have already been undertaken as part of the original FAD 6 EIA
         process), reporting and further stakeholder involvement. Only once a Final Environmental Impact
         Assessment Report (EIAR) and EMPr have been submitted to DEA, can a decision be taken by the
         Department as to whether the project may proceed or not.

         Description of the Proposed Development
         The FAD 6 footprint covers a portion of the areas mined for coal by Brandspruit Mine. The coal seam
         was mined underground at a depth of greater than 120 m. An assessment of the surface stability of
         FAD 6 to be located over underground workings was conducted by Professor Nielen van der Merwe
         of Stable Strata Consulting with Jones & Wagener (Pty) Ltd. The assessment concluded that certain
         of the underground mine panels should be backfilled to ensure the long-term stability of FAD 6.

         Approximately 150 000 m 3 of backfill material is required to stabilise the section of the underground
         workings identified. A compressive strength of 2.0 MPa is required for the backfilling material.

         Cement–ash mixtures varying between 3 and 7 % cement, using both dry (older) and wet (fresh) ash,
         were tested to determine the suitable cement–ash mixture ratio for meeting the required compressive
         strength.

         The 4% cement – wet ash and 6% cement - dry ash mixtures meet the required compressive strength
         required for the ash-cement mass not to crush in the Mine during the construction and operation of
         the FAD 6.

         In terms of SANS 10234, the fine ash was classified as a non-hazardous waste. In terms of the
         National Norms and Standards for the Assessment of Waste for Landfill Disposal, the 4% cement –
         wet ash and 6% cement - dry ash mixtures were assessed as Type 4 based on whole block leach.

         Fine ash produced by Sasol South Africa (Pty) Ltd at Secunda will be used in the mix. The cement-
         ash mixture will be prepared in above surface mixing plants on the FAD 6 footprint. Once the ash is
         recycled in the cement-ash mixing plant, the cement-ash mix (called ash-crete), would be considered
         a product and not a waste and therefore no additional waste management licence will be required for
         the placement of this ash-crete product in the underground workings.

         The cement-ash mixture will be transported to boreholes by cement trucks. Boreholes will be drilled
         at intervals at the surface to allow access to the undermined areas to be stabilised, and the cement
         will be pumped into the boreholes.

         The envisaged process per borehole is:

             Confirming the borehole position;

             Drilling of the borehole;

             Installation of casing through the upper dolerite sill;

             Inspection of the borehole by camera and logged to determine if a void is present, and at what
              depth;

             Insertion of a grouting pipe into the void (if present);

MAND/COES                                 521412 20180328_ FAD6 WML Draft Scoping Report_Final         March 2018
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             Pumping the cement-ash mix through the grouting pipe into the mining void and monitoring by
              camera through a neighbouring borehole;

             Extraction of the grouting pipe as the borehole fills to the top; and

             Capping of the borehole below the base of liner level.

         The following infrastructure is anticipated for the construction and operation of the cement-ash
         batching plant:

             Silos for the storage of cement;

             Stockpile areas for fine ash;

             Water storage tanks;

             Two batch lines with hoppers and conveyors to measure and discharge cement, fine ash and
              water into concrete mixers;

             A control room, laboratory and generator for the batch lines;

             Ablutions;

             Wash bay;

             Site office;

             Parking area, and

             Security fencing.

         Motivation for the Proposed Project
         FAD 6 will ensure the continual operation of the SSIC, which in turn will allow for the continuation of
         considerable economic benefits, both locally and within the greater area of the province and country
         as Sasol contributes significantly to the South African economy. The construction and operation of the
         ash-cement mixing plant, which is meant for the stabilisation of section of the FAD 6, will ensure that
         FAD 6 can be constructed and operated safely. Should the project not go ahead, it means that
         sections of the proposed FAD 6 will not be available for use as these will not be safe, limiting the
         amount of space available for ash disposal and the life of FAD 6.

         Over 27 000 people are employed by Sasol Secunda groups, of which approximately 140 000 people
         are supported by these staff members. Without an alternative means of ash deposition, Sasol
         Secunda will not be able to continue current operations beyond the life span of FAD 5, resulting in
         unemployment of a large sum of residents in Secunda and surrounding communities adding to the
         current 40% unemployment rate in the Gert Sibande Local Municipality.

         The Socio-economic studies conducted for the construction and operation of FAD 6 found that FAD 6
         will have positive impacts on economic status due to the prolonged activities of Sasol South Africa
         (Pty) Ltd in Secunda as well as maintaining the current employment statistics. The positive impact
         resulting in the construction of the FAD 6 relates to the continued operation of the SSIC and associated
         mines. Ash generated at the SSIC is required to be disposed of in a safe manner in order to maintain
         optimal production and operation. Without the construction of an additional facility for the disposal of
         fine ash, the SSIC and associated mines will be faced with compulsory closure due to the inability to
         operate.

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         Alternatives Considered
         Two alternatives were considered in terms of the location of the mixing plant within the FAD 6
         development footprint, as follows:

             Preferred Option: The preferred location of the mixing plant (preferred alternative) is located on
              Portion 2 of Farm Rietvley 320 IS, on the Southeast corner of FAD 6; and

             Alternative Option: The alternative location is located on the Northeast corner of FAD 6 on the
              remainder of Portion 3 of Farm Rietvley 320 IS.

         Cement–ash mixtures varying between 3 and 7 % cement, using both dry (older) and wet (fresh) ash,
         were tested to determine the suitable cement–ash mixture ratio for meeting the required compressive
         strength.

         The assessment also included the “no-go “option.

         Anticipated Impacts
         Risks and potential impacts will be categorised according to the type of activity undertaken and the
         relation to each environmental variable. Findings from FAD 6 EIA specialist studies (where the mixing
         plant will be located) will be incorporated into the EIA for the proposed cement ash mixing plant and
         undermining stabilisation process. The specialist studies identified impacts and risks that FAD 6 will
         have on the environment and quantified the significance of the identified impacts. It is expected that
         the cement ash plant, which will be located on the footprint of the approved FAD 6, and will only be
         operational for approximately a year (until the stabilisation process is completed), will not have any
         additional long term impacts on the environment. The following impacts as described in Table ES-1
         are anticipated because of the construction, operation and decommissioning Phases of the project:

         Table ES – 1: Anticipated Impacts

         Element             of
                                  Potential Impact Descriptions
         Environment
                                  Possible job opportunities during the construction, operation and decommissioning
                                  Phases of the cement ash mixing facility. There will be possible impacts on the
         Socio-Economic
                                  economic status due to the prolonged activities of Sasol South Africa (Pty) Ltd in
                                  Secunda.
         Hydrogeology             Possible groundwater contamination.
         Surface water            Possible surface water contamination.
         Air Quality              Possible impact on air quality in the area.
                                  Possible generation of noise during construction, operation and decommissioning of the
         Noise
                                  cement-ash mixing plant.
                                  It is not anticipated that any visual impacts will be associated with the proposed cement-
         Visual
                                  ash mixing plant.
                                  As the cement ash mixing plant will be located within the existing approved footprint of
         Soils/Land Use/Land
                                  the FAD 6, no loss of soil resource and change in land capability and land use is
         Capability
                                  expected.
                                  As the cement ash mixing plant will be located within the existing footprint of the FAD
         Biodiversity
                                  6, no loss of biodiversity is expected.
         Wetland                  Possible sedimentation and contamination of wetlands.
         Element of
                                  Potential Impact Descriptions
         Environment

         Socio-Economic           Possible job opportunities during the construction, operation and decommissioning
                                  Phases of the cement ash mixing facility. There will be possible impacts on the

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         Element             of
                                  Potential Impact Descriptions
         Environment
                                  economic status due to the prolonged activities of Sasol South Africa (Pty) Ltd in
                                  Secunda.
         Hydrogeology             Possible groundwater contamination.

         Environmental Assessment Process
         Approach to the Environmental Impact Assessment
         An EIA seeks to identify the environmental consequences of a proposed project from the beginning,
         and helps to ensure that the project, over its life cycle, will be environmentally acceptable, and
         integrated into the surrounding environment in a sustainable way. Two parallel processes are followed
         during the scoping Phase being the Environmental technical process and Stakeholder engagement
         process.

         Stakeholder Engagement Process
         Activities that have been undertaken for the public involvement process during the scoping Phase are:

             Development of a stakeholder database:

               o    The stakeholder database comprises a variety of stakeholders identified from previous
                    projects in the area, newly identified stakeholders and through the initial registering process
                    of this project.

         The opportunity to participate in the EIA and to register as an Interested and Affected Party (I&AP)
         was announced in February 2018 through the following means:

             Letter of invitations to register and background information documents;

             Afrikaans, English and Zulu media advertisements were placed in the Bulletin and Echo
              newspapers;

             Site notices were erected at several places in and around the proposed study area;

             Collation of comments received into a Comments and Responses Register (CRR);

             Obtaining and documenting registration and comment sheets.

         The Draft Scoping Report will be made available for a 30-day commenting period. All issues,
         comments and suggestions received from stakeholders will be reviewed and collated into a CRR.
         Where necessary, comments from stakeholders will also be incorporated into the Final Scoping Report
         that will be submitted to the DEA for decision-making. Depending on the responses received during
         the registration period, a public meeting may be held during the Scoping Phase of the project.

         Once the DEA has accepted the Final Scoping Report, the EAP will compile the EIAR and EMPr,
         which will also be made available to the stakeholders for a 30 day review and comment period.
         Comments received will be incorporated into the Final EIAR and EMPr which will be submitted to the
         DEA for decision making. The comments will also be collated into the CRR, which will form an
         Appendix to the EIAR.

         The stakeholders will be notified of DEA’s Final decision on the project once it has been communicated
         to the EAP and applicant (SSIC).

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         Specialist Studies
         During the original EIA for FAD 6, extensive specialist studies were conducted, which included
         collection of baseline data and quantification of impacts of FAD 6 on the environment. These specialist
         studies included:
             Biodiversity studies;
             Air quality assessment;
             Geohydrological assessment;
             Surface water assessment;
             Wetland delineation and assessment; and
             Heritage resources.

         Sasol Secunda is also currently implementing water quality and groundwater monitoring programmes
         around the complex as per approved environmental authorisations.

         The following specialist inputs are expected to be required for the proposed cement ash mixing plant:
             Groundwater impact assessment;
             Biodiversity;
             Surface water assessment;
             Wetland delineation and assessment;
             Heritage resources;
             Air quality; and
             Hydrology.

         Since the area where the cement ash mixing plant will be located is on the approved FAD 6 footprint,
         it is expected that the plant will not have any significant additional impacts on the environment
         (biodiversity, heritage resources, wetlands, air quality, traffic and hydrology) and that the available
         specialist studies’ information will suffice.

         The EAP will incorporate the findings from the FAD 6 specialist studies into the cement ash mixing
         plant impact assessment process and will quantify the impacts as described in Section 9.7. The EAP
         will also include an assessment of the impacts on the socio-economic environment, visual, noise,
         waste management; stormwater management, soils and land use.

         The drilling of the boreholes and the undermining process may potentially have additional impacts on
         the geohydrology of the area that is different from the impacts of FAD 6. A geohydrological
         assessment will therefore be conducted for the undermining stabilisation process. Since the baseline
         data for the project area was collected during the EIA for FAD 6 and the ongoing SSIC monitoring
         programmes, the specialist will not require fieldwork. The specialist will conduct a desktop review of
         the available information and based on that conduct an impact assessment of the proposed project on
         groundwater.

         Quantification of Impacts
         The anticipated impacts associated with the proposed project will be assessed according to SRK’s
         standardised impact assessment methodology which is presented Section 9.7. This methodology has
         been utilised for the assessment of environmental impacts where the consequence (severity of impact,
         spatial scope of impact and duration of impact) and likelihood (frequency of activity and frequency of

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         impact) have been considered in parallel to provide an impact rating and hence an interpretation in
         terms of the level of environmental management required for each impact.

         Conclusion and Recommendation
         The aim of this Scoping Report is to provide an indication of the identified, positive and negative
         environmental and socio-economic impacts associated with the proposed project activities. The
         stakeholder engagement in the scoping Phase will play an important role in determining possible
         impacts and allowing the concerns by the public to be adequately addressed, in the impact
         assessment Phase of the EIA process.

         Once the Draft Scoping Report comment period is concluded, the report will be updated with the
         additional issues, and submitted to DEA. An EIA, including a Draft EMPr, will be compiled and
         subjected to a round of public comment. The EIA will then be presented to the authorities for decision-
         making. On submission of the EIA and EMPr to the DEA, notification will be sent to registered I&AP’s
         to inform them of the submission of the documents; and the opportunity to request copies of the Final
         reports.

         Extensive consideration has been given to the proposed design of the project. No fatal flaws have
         been identified during the Scoping Phase of this project. The location of the proposed cement ash
         mixing plant is already affected by FAD 6 and it is the considered opinion of the EAP that there will be
         no impacts, except for potential minimal groundwater impacts, that will require additional specialist
         inputs. Findings from FAD 6 specialist studies will be incorporated into the EIAR during the EIA Phase.
         The proposed comprehensive stakeholder engagement process in the Plan of Study (PoS) will ensure
         that the stakeholders are involved in the process, from the conception of the WML process to the end.
         It is anticipated that implementation of the PoS presented in this report will result in an adequate EIA
         process which will result in the formulation of a sound EMPr to be integrated into the overall
         management system of the FAD 6 area.

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                     YOUR COMMENT ON THE SCOPING REPORT
   This Draft Scoping Report will be available for comment for a period of 30 days from 29 March 2018 to 29
   April 2018. Copies of the Scoping Report have been made available at the following public places for
   review:
     Public Place                                 Locality                                       Telephone
     Secunda Public Library                       Laurens Muller Street, Secunda                 (017) 620 6000
     eMbalenhle Municipal Library                 Stand No 2107, Khama Street,                   (017) 614 5666
                                                  eMbalenhle
     SRK Website                                  www.srk.co.za                                  (012) 361 9821

   An electronic copy will also be available on CD on request from the stakeholder engagement officers.
   I&AP’s are requested to provide comments and information on the following aspects of the proposed
   project:
            1. Information on how I&AP’s consider that the proposed activities will impact on them or their socio-
                economic conditions;

            2. Written responses stating their suggestions to mitigate the anticipated impacts of each activity;

            3. Information on current land uses and their location within the area under consideration;

            4. Information on the location of environmental features on site to make proposals as to how and to
                what standard the impacts on site can be remedied; and

            5. How to mitigate the potential impacts on their socio economic conditions and to make proposals
               as to how the potential impacts on their infrastructure can be managed avoided or remedied.

                                           DUE DATE FOR COMMENT

                                                         30 April 2018

                   Please submit comments to the stakeholder engagement officers:

                                         Laetitia Coetser/Donne Du Toit
                                                 SRK Consulting
                                      P O Box 35290, Menlo Park, 0102
                                             Phone: (012) 361 9821
                                               Fax: (086) 231 3497
                                  Email: lcoetser@srk.co.za/ddutoit@srk.co.za

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Table of Contents

    Executive Summary ..................................................................................................................................... ii
    Disclaimer................................................................................................................................................... xv
    List of Abbreviations .................................................................................................................................. xvi
1 Introduction .................................................................................................................. 1
    1.1     Waste Management Licence Application Process .............................................................................. 2
    1.2     Location of the Proposed Activity........................................................................................................ 3
    1.3     Land Ownership .................................................................................................................................. 3
    1.4     Report Index in Relation to the NEMA Regulations ............................................................................ 5
    1.5     Contact Details .................................................................................................................................... 8
            1.5.1      Applicant .................................................................................................................................. 8
            1.5.2      Environmental Assessment Practitioner ................................................................................. 8
            1.5.3      Details of the Specialists ......................................................................................................... 9
            1.5.4      Competent Authority Details ................................................................................................... 9
            1.5.5      Municipality and Ward Details ...............................................................................................10
2 Legal and Policy Framework ..................................................................................... 12
    2.1     The Constitution of the Republic of South Africa ..............................................................................12
    2.2     National Environmental Management Act (107 of 1998) ..................................................................12
            2.2.1      EIA Regulations (GNR 982) ..................................................................................................13
    2.3     National Environmental Management: Waste Act (Act No. 59 of 2008) ...........................................13
    2.4     National Environmental Management: Air Quality Act (Act No. 39 of 2004) ....................................14
    2.5     National Heritage Resources Act (Act No. 25 of 1999) ....................................................................15
    2.6     National Water Act (Act No. 36 of 1998) ...........................................................................................15
    2.7     National Environmental Management: Biodiversity Act (Act No. 10 of 2004) ..................................16
    2.8     Promotion of Access to Information Act (Act No. 2 of 2000) ............................................................16
    2.9     Conservation of Agricultural Resources Act (Act No. 43 of 1983) ....................................................17
    2.10 Provincial and Municipal Bylaws .......................................................................................................17
    2.11 Guidelines .........................................................................................................................................17
3 Project Description..................................................................................................... 18
    3.1     Cement-Ash Mix Backfilling of Undermined Areas ...........................................................................18
    3.2     Undermining Stabilisation Process: ..................................................................................................19
    3.3     Infrastructure .....................................................................................................................................19
    3.4     Employment ......................................................................................................................................19
4 Scoping Study Methodology and Objectives ........................................................... 21
5 Alternatives Considered ............................................................................................ 22
    5.1     Preferred Option................................................................................................................................22
    5.2     Alternative 1 ......................................................................................................................................22
    5.3     No-Go Alternative..............................................................................................................................22

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6 Stakeholder Engagement Process............................................................................ 24
    6.1     Stakeholder Identification Interested and Affected Parties ...............................................................26
    6.2     Confirmation of Land Claims .............................................................................................................30
    6.3     Project Announcement ......................................................................................................................30
            6.3.1      Distribution of Notification Letters .........................................................................................30
            6.3.2      Site Notice Placements .........................................................................................................30
            6.3.3      Newspaper Advertisements ..................................................................................................30
    6.4     Public Review of the Scoping Report................................................................................................31
    6.5     Key Comments Received. ................................................................................................................31
    6.6     Comments and Response Report .....................................................................................................31
7 Need and Desirability of the Proposed Project ........................................................ 32
8 Description of the Baseline Environment ................................................................ 32
    8.1     Climate ..............................................................................................................................................33
            8.1.1      Regional Climate ...................................................................................................................33
            8.1.2      Mean Monthly and Annual Rainfall for the area ....................................................................34
            8.1.3      Mean Monthly, Maximum and Minimum Temperatures ........................................................34
            8.1.4      Monthly Mean Wind Direction and Speed .............................................................................35
    8.2     Topography .......................................................................................................................................35
    8.3     Soils and Land-Use ...........................................................................................................................36
    8.4     Land Capability .................................................................................................................................36
    8.5     Air Quality ..........................................................................................................................................37
            8.5.1      Mean Monthly Evaporation....................................................................................................40
            8.5.2      Incidences of Extreme Weather Conditions ..........................................................................40
            8.5.3      Relative Humidity and Mist ....................................................................................................40
    8.6     Surface Water ...................................................................................................................................40
            8.6.1      Regional and Local Context ..................................................................................................40
            8.6.2      Surface Water .......................................................................................................................41
    8.7     Geohydrology ....................................................................................................................................43
            8.7.1      Aquifers .................................................................................................................................43
            8.7.2      Groundwater ..........................................................................................................................46
    8.8     Wetlands ...........................................................................................................................................47
            8.8.1      Artificial Drainage Area ..........................................................................................................48
    8.9     Present Ecological Status and Ecological Importance and Sensitivity .............................................50
            8.9.1      Present Ecological State .......................................................................................................53
            8.9.2      Surface water user survey.....................................................................................................53
            8.9.3      Sensitive areas survey ..........................................................................................................53
    8.10 Fauna and Flora ................................................................................................................................53
    8.11 Archaeological Status of the Site ......................................................................................................54
    8.12 Visual ...............................................................................................................................................54
    8.13 Safety Health and Environment ........................................................................................................55
    8.14 Socio – Economical Environment .....................................................................................................55

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9 Plan of Study for the Environmental Impact Assessment ...................................... 55
    9.1     Purpose of this Plan of Study ............................................................................................................56
    9.2     Purpose of the EIA/EMPr ..................................................................................................................56
    9.3     Methodology......................................................................................................................................56
    9.4     Stakeholder Engagement Going Forward ........................................................................................56
            9.4.1      Scoping Report ......................................................................................................................57
            9.4.2      Environmental Impact Assessment Report ...........................................................................57
            9.4.3      Environmental Management Programme .............................................................................57
            9.4.4      Submission of Environmental Impact Assessment Report and Environmental Management
                       Programme for Review..........................................................................................................57
            9.4.5      Authority Consultation ...........................................................................................................57
    9.5     Alternatives .......................................................................................................................................58
    9.6     Specialist Studies ..............................................................................................................................58
    9.7     Impact Assessment Methodology .....................................................................................................59
10 Anticipated Environmental, Social and Cultural Impacts ....................................... 61
    10.1 Socio Economic ................................................................................................................................62
    10.2 Hydrogeology ....................................................................................................................................62
    10.3 Surface water ....................................................................................................................................62
    10.4 Air Quality ..........................................................................................................................................62
    10.5 Noise ...............................................................................................................................................62
    10.6 Visual ...............................................................................................................................................63
    10.7 Soils, Land Use and Land Capability ................................................................................................63
    10.8 Biodiversity ........................................................................................................................................63
    10.9 Wetland .............................................................................................................................................63
    10.10Heritage .............................................................................................................................................63
    10.11Traffic ...............................................................................................................................................64
    10.12Cumulative impacts ...........................................................................................................................64
11 Undertaking of Oath by the EAP ............................................................................... 65
12 Conclusions and Recommendations........................................................................ 66
Appendices ...................................................................................................................... 68
Appendix A: Curriculum Vitae of the Project Team ...................................................... 69
Appendix B: Project Experience .................................................................................... 70
Appendix C: Stakeholder Engagement .......................................................................... 71
Appendix C 1: Stakeholder Database ........................................................................... 72
Appendix C 2: Announcement Phase Notifications..................................................... 73
Appendix C 3: Site Notices ............................................................................................ 74
Appendix C 4: Newspaper Advertisements .................................................................. 75
Appendix C 5: Comments and Responses Report ...................................................... 76
Appendix C 6: Stakeholder Communications .............................................................. 77

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Appendix C 7: Authority Correspondence ................................................................... 78
Appendix D: Minutes of the Meeting Held: Authorities ................................................ 79

List of Tables
Table 1-1: List of Affected Farms and Farm Portions Illustrating the Relevant Activities ................................. 3
Table 1-2: Requirements of Regulation 2 of GNR 982 ...................................................................................... 5
Table 1-3: Applicant Contact Details ................................................................................................................. 8
Table 1-4: Details of the Project Team .............................................................................................................. 8
Table 1-5: Specialist Studies ............................................................................................................................. 9
Table 1-6: Competent Authority Details ...........................................................................................................10
Table 1-7: Local and District Municipality Details ............................................................................................10
Table 2-1: NEM: WA Listed Activities Triggered by the proposed project ......................................................14
Table 6-1: List of Preferred and Alternative Farms and Farm Portions ...........................................................26
Table 6-2: List of Adjacent Farms and Farm Portions – Preferred Site ..........................................................26
Table 6-3: List of Adjacent Farms and Farm Portions – Alternative Site ........................................................26
Table 6-4: Site Notice Location and Coordinates ............................................................................................30
Table 6-5: Newspaper Advertisements ...........................................................................................................30
Table 6-6: List of places the Scoping Report will be places for public review .................................................31
Table 6-7: Key Comments Received ...............................................................................................................31
Table 8-1: Climate Information for Secunda ....................................................................................................33
Table 8-2: Mean Monthly Rainfall (mm) ..........................................................................................................34
Table 8-3: Mean monthly evaporation (Class A pan) (mm).............................................................................40
Table 8-4: Mean Relative Humidity at 08h00 and 14h00 (%) ..........................................................................40
Table 8-5: Extend of Various Wetland Types Recorded on Site .....................................................................47
Table 9-1: Criteria for Assessing Significance of Impacts ...............................................................................60
Table 9-2: Interpretation of Impact Rating .......................................................................................................61
Table 10-1: Summary of Potential Environmental Impacts Associated with the Proposed Development ......61

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List of Figures
Figure 1-1: Overview the Environmental Impact Assessment Process ............................................................ 3
Figure 1-2: Layout Plan and Affected Farm Portions ........................................................................................ 4
Figure 1-3: Relevant District and Local Municipalities Relevant to the Proposed Project ..............................11
Figure 5-1: Alternative Locations for the proposed ash-cement mixing plant .................................................22
Figure 6-1: Integrated EIA and Stakeholder Engagement Process ................................................................25
Figure 6-2: Preferred Project Location ............................................................................................................28
Figure 6-3: Alternative Project Location ..........................................................................................................29
Figure 8-1: Secunda average monthly rainfall .................................................................................................34
Figure 8-2: Wind Roses of Air Quality Monitoring Stations Operated by Sasol Synfuels ...............................38
Figure 8-3: Location of Air quality Monitoring Stations Operated by Sasol Secunda .....................................39
Figure 8-4: Surface water monitoring points and the major catchment basin in Secunda ..............................42
Figure 8-5: Groundwater Sampling Positions ..................................................................................................45
Figure 8-6: Natural and Artificial Wetlands in Relation to the Study Area .......................................................49
Figure 8-7: Present Ecological Status .............................................................................................................51
Figure 8-8: Ecological Importance and Sensitivity ..........................................................................................52

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         Disclaimer
         The opinions expressed in this Report have been based on the information supplied to SRK Consulting
         (South Africa) (Pty) Ltd (SRK) by Sasol South Africa (Pty) Ltd (Sasol) The opinions in this Report are
         provided in response to a specific request from Sasol to do so. SRK has exercised all due care in
         reviewing the supplied information. Whilst SRK has compared key supplied data with expected values,
         the accuracy of the results and conclusions from the review are entirely reliant on the accuracy and
         completeness of the supplied data. SRK does not accept responsibility for any errors or omissions in
         the supplied information and does not accept any consequential liability arising from commercial
         decisions or actions resulting from them. Opinions presented in this report apply to the site conditions
         and features, as they existed at the time of SRK’s investigations, and those reasonably foreseeable.
         These opinions do not necessarily apply to conditions and features that may arise after the date of this
         Report, about which SRK had no prior knowledge nor had the opportunity to evaluate.

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         List of Abbreviations
         BID:                                  Background Information Document

         CARA:                                 Conservation of Agricultural Resources Act, 1983 (Act 43 of 1983)

         DAFF:                                 Department of Agriculture, Forestry and Fisheries

         MDARDLEA:                             Mpumalanga Department of Agriculture, Rural Development, Land
                                               and Environmental Affairs

         DEA:                                  Department of Environmental Affairs

         DEAT:                                 Then Department of Environmental Affairs and Tourism now
                                               Department of Environmental Affairs

         DWS:                                  Department of Water and Sanitation

         EAP:                                  Environmental Assessment Practitioner

         EIA:                                  Environmental Impact Assessment

         EIAR:                                 Environmental Impact Assessment Report

         EMPr:                                 Environmental Management Programme

         FAD:                                  Fine Ash Dam

         GDP:                                  Gross Domestic Product

         GNR:                                  Government Notice Regulation

         GNR:                                  Government Notice Regulation

         HIA:                                  Heritage Impact Assessment

         I&AP’s:                               Interested and Affected Parties

         IDP:                                  Integrated Development Plan

         mamsl:                                Meters Above Mean Sea Level

         MBCP:                                 Mpumalanga Biodiversity Conservation Plan

         MHSA:                                 Mine Health and Safety Act, 1996 (Act 29 of 1996)

         NEM:BA:                               National Environmental Management: Biodiversity Act (Act 10 of
                                               2004)

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

         NEMA:                                 National Environmental Management Act (Act No. 107 of 1998)

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         NEM:WA:                               National Environmental Management: Waste Act, 2008 (Act No. 59
                                               of 2008)

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

         NWA:                                  National Water Act (Act No. 36 of 1998)

         PAIA:                                 Promotion of Access to Information Act (Act No. 2 of 2000)

         PoS:                                  Plan of Study

         PPP:                                  Public Participation Process

         SAHRA:                                South African National Heritage Resources Agency

         SANS:                                 South African National Standards

         SDF:                                  Spatial Development Framework

         SSIC:                                 Sasol Secunda Industrial Complex

         ToR:                                  Terms of Reference

         WADS:                                 Waste Ash Disposal Sites

         WMA:                                  Water Management Area

         WML:                                  Waste Management Licence

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1        Introduction
         Sasol South Africa (Pty) Ltd (Sasol Secunda) has commenced with the construction of the Fine Ash
         Dam (FAD) 6 at the Sasol Secunda Industrial Complex (SSIC) in Secunda. The need for FAD 6 stems
         from the fact that the currently operational FAD 5 is nearing its end of life and a new disposal site is
         required for the disposal of fine ash material generated from the production process at the SSIC.

         The following authorisations have been obtained for the construction and operation of FAD 6:

             Environmental Authorisation (2012) (Reference number 17/2/3 GS-6) in terms of the National
              Environmental Management Act, 1998 (Act 107 of 1998) (NEMA);

             Environmental Authorisation amendment (2015) (Reference number 17/2/6/3 (1-60) GS-60 in
              terms of NEMA);

             Environmental Management Programme (EMPr) Amendment (2015) (Reference number
              1/3/1/16/5 G-01) in terms of NEMA;

             Waste Management Licence (2015) (Reference number 12/9/11/L45369/6) in terms of the
              National Environmental Waste Act (Act No. 59 of 2008) (NEMWA);

             Water Use Licence (2016) (Reference number 27/2/2/C412/4/4) in terms of the National Water
              Act (Act No. 36 of 1998) (NWA);

             Various approvals issued in terms of General Authorisations for associated infrastructure in terms
              of the NWA.

         The FAD 6 will cover areas that were previously mined for coal by the Brandspruit Mine. The coal
         seam was mined underground at a depth of greater than 120 m. An assessment of the surface stability
         of FAD 6 to be located over underground workings was conducted by Professor Nielen van der Merwe
         of Stable Strata Consulting with Jones & Wagener (Pty) Ltd. The assessment concluded that certain
         of the underground mine panels should be backfilled to ensure the long-term stability of FAD 6.

         Approximately 150 000 m 3 of backfill material is required to stabilise the section of the underground
         workings identified. A compressive strength of 2.0 MPa is required for the backfilling material.
         Cement–ash mixtures varying between 3 and 7% cement, using both dry (older) and wet (fresh) ash
         were tested to determine the suitable cement–ash mixture ratio for meeting the required compressive
         strength.

         The 4% cement – wet ash and 6% cement - dry ash mixtures meet the required compressive strength
         required for the ash-cement mass not to crush in the Mine during the construction and operation of
         the FAD 6. It is noted that the fine ash to be used for the proposed backfilling has been classified in
         terms of the South African National Standards (SANS) 10234 as a non-hazardous waste. In terms of
         the National Norms and Standards for the Assessment of Waste for Landfill Disposal, the 4% cement
         – wet ash and 6% cement - dry ash mixtures were assessed as Type 4 based on whole block leach.

         Fine ash produced by Sasol South Africa (Pty) Ltd at Secunda will be used in the mix. The cement-
         ash mixture will be prepared in above surface mixing plants on the approved FAD 6 footprint. Once
         the ash is recycled in the cement-ash mixing plant, the cement-ash mix (called ash-crete), would be
         considered a product and not a waste and therefore no additional waste management licence will be
         required for the placement of this ash-crete product in the underground workings.

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         The cement-ash mixture will be transported to boreholes by cement trucks. Boreholes will be drilled
         at intervals at the surface to allow access to the undermined areas to be stabilised, and the cement
         will be pumped into the boreholes.

         The recycling of the fine ash from Sasol Secunda and the construction, operation, maintenance and
         decommissioning of the cement-ash mixing plant triggers activities listed in Category B of GNR 921 of
         the National Environmental Management: Waste Act, 2008 (Act 59 of 2008) (NEM: WA) and will
         therefore require a Waste Management Licence (WML) from the Department of Environmental Affairs
         (DEA). All activities listed in Category B of the GNR 921 require that a full Environmental Impact
         Assessment (EIA) (Scoping and EIA) be conducted as part of the application for a WML.

         SRK Consulting (SA) (Pty) Ltd (SRK) has been appointed by Sasol Secunda as the independent
         Environmental Assessment Practitioner (EAP) to conduct the WML application process for the project.

         The reports and documentation for the WML application process will be compiled and Finalised for
         submission to the DEA for the WML in terms of the NEMA for consideration and decision-making. The
         DEA will consult with other government authorities as required in terms of Section 24(K) of the NEMA.

1.1      Waste Management Licence Application Process
         The first Phase of the WML application process is the scoping Phase, which will inform the Impact
         Assessment Phase. This Phase provides Interested and Affected Parties (I&AP’s) an opportunity to
         provide the EAP with issues and concerns with respect to the proposed project in order to inform the
         technical studies so that they can evaluate these concerns during the EIA Phase of the project.

         This Draft Scoping Report provides a description of the proposed project and sets out the proposed
         scope of the EIA and EMPr that will be undertaken for the proposed recycling of the fine ash from FAD
         6 and the construction, operation, maintenance and decommissioning of the cement-ash mixing plant.
         This includes alternatives that will be evaluated for various aspects of the project, the anticipated
         potential environmental impacts, issues raised by stakeholders, the specialist studies that will be
         undertaken including the terms of reference of the specialist studies, and the qualifications and
         experience of the study team.

         Stakeholder engagement is a key element of the environmental decision-making process, and
         stakeholder engagement forms part of the scoping Phase as well as the impact assessment Phase.

         The Draft Scoping Report will be made available for public review prior to submission to DEA for
         authorisation. All the comments received will be captured and addressed where feasible in the Scoping
         Report as well as the Environmental Impact Assessment Report (EIAR).

         This document is intended to guide the EIA process and specialist studies by:

             Providing an overview of the legal requirements with regard to the proposed project, the proposed
              project description and anticipated environmental and social issues and impacts that will be further
              investigated in the EIA; and

             Setting out the scope of the EIA process and the Terms of Reference (ToR) for specialist studies
              and outlining the approach and methodologies to be used in the EIA process, e.g. the proposed
              impact rating methodology. This report will be submitted to the DEA for their decision. Figure 1-1
              provides an illustration of the proposed EIA process that will be followed.

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