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The Proposed Establishment of a Clean

Technology Waste to Energy Facility


DRAFT SCOPING REPORT FOR COMMENT

A renewable, sustainable energy company

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APPLICABLE LEGISLATION

COMPETENT AUTHORITY REFERENCE NUMBER/S

NEMA EIA Regulations (2010)


(National DEA)

NEAS Reference: DEA/EIA/0000879/2011


DEA Reference: 12/12/20/2673

NEM: Waste Act (2009)


(National DEA)

AS ABOVE SAME COMPETENT AUTHORITY

NEM: Air Quality Act (2004)


Tshwane District Municipality
Report Title

9/16/1/2/13/R

Author (EAP)

Fabio Venturi (Terramanzi Environmental Consulting)

Specialist Sub-Consultants

Air Quality: Dr Lucian Burger of Airshed Planning Professionals

Draft Scoping Report for the proposed Eco2 Partnership SA (Pty)


Ltd Clean Technology Waste to Energy Facility

Major Hazard Installation: Mr Alfonso of Nature & Business


Alliance Africa (Pty) Ltd
Social-Economic: Mr Tony Barbour of Tony Barbour Consulting
Town Planning: Ms Lynette Groenewald of Urban Dynamics
Gauteng
Client

Eco2 Partnership SA (Pty) Ltd; C/O Ms Jeanne L Rose

Report Version

Draft Scoping Report for Public Participation June 2012

Submission Date for Comment

04 June 2012

Please use the following as a reference for this Report: Terramanzi Project # 110902 - Draft Scoping Report
Project Title: The proposed establishment of the Eco2 SA Partnership (Pty) Ltd Clean Technology Waste to
Energy Facility, Pretoria, Gauteng Province, South Africa

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Contents
1

EXECUTIVE SUMMARY ............................................................................................................... 8

DEFINITIONS AND TERMINOLOGY REFERRED TO IN THIS REPORT ............................................ 17

LEGISLATIVE TERMS OF REFERENCE ......................................................................................... 20

ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) DETAILS AND EXPERTISE ....................... 24

5 LEGISLATION, POLICY AND GUIDELINES CONSIDERED IN THE PREPARATION OF THIS SCOPING


REPORT ........................................................................................................................................... 25
6

INTRODUCTION ....................................................................................................................... 26

GENERAL DESCRIPTION OF PROPOSED ACTIVITY ...................................................................... 32


7.1

Broad Overview of the Proposed CTWEF (Process Flow for all Components)...................... 32

7.2

Receiving and Preparing the Feedstock (whole tyres to shredded tyres) ............................ 34

7.2.1

Receiving of Waste Tyres ............................................................................................ 34

7.2.2

Preparing the Waste Tyres for Feedstock .................................................................... 36

7.2.3

Tyre De- Beading (stripping of steel) ........................................................................... 37

7.2.4

Crumbing Process (tyre shredding) ............................................................................. 37

7.2.5

Internal Whole Tyre Reticulation (in preparation for shredding) ................................. 39

7.2.6

Internal Feedstock Reticulation (in preparation for gasification / pyrolysis) ................ 39

7.3

The Pyrolysis and Gasification System................................................................................ 41

7.3.1

An Overview of Waste to Energy Technology .............................................................. 41

7.3.2

A Broad Overview of the Proposed Clean Technology Waste to Energy Facility ........... 42

7.3.3

A Detailed Overview of the Eco2 SA Clean Technology Waste to Energy Facility .......... 44

7.4

Product Emissions from the CTWEF ................................................................................... 48

7.4.1

Liquid Emissions ......................................................................................................... 48

7.4.2

Gaseous Emissions...................................................................................................... 48

7.4.3

Solid Emissions ........................................................................................................... 48

7.5

Waste Emissions from the CTWEF ..................................................................................... 49

7.5.1

Liquid Emissions ......................................................................................................... 49

7.5.2

Gaseous Emissions...................................................................................................... 49

7.5.3

Solid Emissions ........................................................................................................... 49

7.6

Hours of Operation ............................................................................................................ 51

7.7

Electricity Generation (Steam Turbines and Wartsila Tri-Fuel Engines) ............................... 52

7.7.1

Steam Boiler and Turbine ........................................................................................... 52

7.7.2

Tri-Fuel (Wrtsil) Engines .......................................................................................... 53

7.7.3

Carbon Capture Unit (CCU) ......................................................................................... 53

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7.7.4

Feeding the Electricity into the Grid ............................................................................ 54

7.7.5

Emergency Flaring and Shut-Down Process................................................................. 55

7.8

Bulk Services Required to Operate the CTWEF ................................................................... 55

7.8.1

Roads ......................................................................................................................... 55

7.8.2

Water ......................................................................................................................... 55

7.8.3

Electricity ................................................................................................................... 55

7.8.4

Sewage ....................................................................................................................... 55

GENERAL PURPOSE AND REQUIREMENT OF THE ACTIVITY AS PROPOSED BY THE APPLICANT .. 56

NEED AND DESIRABILITY OF THE ACTIVITY ............................................................................... 57


9.1

Legislative Framework ....................................................................................................... 57

9.2

Sustainable Development .................................................................................................. 58

10

STRATEGIC POLICY CONSIDERATIONS APPLICABLE TO THE PROPOSED CTWEF ...................... 59

10.1

The 12 National Lekgotla Outcomes ............................................................................... 59

10.2

Gauteng Growth and Development Strategy (2005) ....................................................... 60

10.3

Gauteng Medium Term Strategic Framework (2009) ...................................................... 60

10.4

Gauteng Employment, Growth and Development Strategy (2010).................................. 61

10.5

Gauteng Integrated Energy Strategy (2010) .................................................................... 62

10.6

Tshwane Metro (Renewable) Energy Policy .................................................................... 63

10.7

Draft National Waste Management Strategy (2010) ....................................................... 64

10.8

Gauteng Hazardous Waste Management Plan (2008) ..................................................... 65

11

DESCRIPTION OF PROPERTY ON WHICH THE PROPOSED ACTIVITY IS TO BE UNDERTAKEN .... 66

11.1

Location and Size of Property ......................................................................................... 66

11.2

Location of Activity on Proposed Property...................................................................... 67

11.3

Site Access ..................................................................................................................... 68

11.4

Current Land Use and Zoning ......................................................................................... 68

11.4.1

Current Land Use .................................................................................................... 68

11.4.2

Zoning ..................................................................................................................... 68

11.5

Strategic Planning Context ............................................................................................. 70

11.5.1

Guiding Principles of the Development Facilitation Act............................................ 70

11.5.2

The Integrated Development Plan (IDP) .................................................................. 72

11.5.3

The Spatial Development Framework (SDF) ............................................................. 75

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12
DESCRIPTION OF THE RECEIVING ENVIRONMENT THAT MAY BE IMPACTED BY THE PROPOSED
ACTIVITY.......................................................................................................................................... 78
12.1

Land Use Character of the Area Surrounding the Site ..................................................... 78

12.1.1

The Site ................................................................................................................... 78

12.2

Surface Slope & Elevations of the Site ............................................................................ 79

12.3

Geology ......................................................................................................................... 80

12.4

Sensitive Natural Features.............................................................................................. 80

13

12.4.1

Groundcover ........................................................................................................... 80

12.4.2

Hydrology (i.e. surface water and natural drainage features) .................................. 81

12.4.3

Sensitive Man-Made Features in the Immediately Adjacent Landscape ................... 81

12.4.4

Residential areas ..................................................................................................... 81

SOCIO-ECONOMIC CONTEXT ................................................................................................. 82

13.1

Socio-Economic Baseline Findings .................................................................................. 82

13.2

Socio-Economic Context ................................................................................................. 84

14

HERITAGE CONTEXT .............................................................................................................. 87

15

AIR QUALITY CONTEXT .......................................................................................................... 88

16

MAJOR HAZARD INSTALLATION CONTEXT ............................................................................. 88

17

TOWN PLANNING CONTEXT .................................................................................................. 89

18

POTENTIAL ENVIRONMENTAL IMPACTS IDENTIFIED .............................................................. 90

18.1

Potential Physical Impacts: ............................................................................................. 90

18.1.1

Dust ........................................................................................................................ 90

18.1.2

Noise ...................................................................................................................... 90

18.1.3

Vibration ................................................................................................................. 90

18.1.4

Light........................................................................................................................ 90

18.2

Potential Biophysical Impacts: ........................................................................................ 91

18.2.1

Air Quality ............................................................................................................... 91

18.2.2

Waste Impacts ........................................................................................................ 91

18.3

Potential Socio-Economic Impacts .................................................................................. 91

18.3.1

Strategic and Town Planning ................................................................................... 91

18.3.2

Major Hazard Installation ........................................................................................ 91

18.3.3

Socio-Economic ....................................................................................................... 91

18.3.4

Climate Change ....................................................................................................... 91

18.3.5

Traffic ..................................................................................................................... 91

18.3.6

Bulk Services (e.g. sewage, water, electricity and solid waste) ................................. 91

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19
METHODOLOGY TO BE ADOPTED IN THE ASSESSMENT OF POTENTIAL IMPACTS DURING THE
ENVIRONMENTAL IMPACT PHASE.................................................................................................... 92
20

ALTERNATIVES ...................................................................................................................... 92

20.1

Legislative Requirements ............................................................................................... 92

20.2

The No Go Option (Mandatory Option) ....................................................................... 94

20.3

Layout Alternatives ........................................................................................................ 94

20.4

Activity Alternatives ....................................................................................................... 94

20.5

Sustainable Technology Alternatives .............................................................................. 94

21

PUBLIC PARTICIPATION PROCESS .......................................................................................... 95

21.1

Steps Taken to Notify Potentially Interested and Affected Parties .................................. 95

21.2

Authority Consultation ................................................................................................... 96

21.3

Summary of Application and Public Participation Process ............................................... 97

21.4

Proof of Notification....................................................................................................... 98

21.5

List of Registered Interested and Affected Parties (I&APs) ............................................. 98

21.6

Summary of Considerations Raised by Interested and Affected Parties .......................... 98

22

CONCLUSIONS....................................................................................................................... 99

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APPENDICE INDEX
Please note that the Appendices are located after the Scoping Report and have detailed
Cover Pages available to facilitate document navigation for the reader.

Appendix A:

Site Plans

Appendix B

Photographs

Appendix C

Facility Illustrations

Appendix D

Specialist Reports

Appendix E

Public Participation

Appendix F

Plan of Study for EIA (PosEIA)

Appendix G

Other Information (Application Forms and Responses from the Competent


Authorities)

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EXECUTIVE SUMMARY

Terramanzi Environmental Consulting has been appointed as the independent


Environmental Assessment Practitioner (EAP) to submit applications in terms of the NEMA
EIA Regulations (2010), the NEM: Waste Act (2009) and the NEM: Air Quality Act (2004) to
the respective Competent Authorities, on behalf of the Eco2 Partnership SA (Pty) Ltd (the
applicant) for the establishment of a Clean Technology Waste to Energy Facility (CTWEF)
to be located in Pretoria, South Africa.
This Draft Scoping Report is aimed at:
1. Broadly introducing the Project Proposal to Stakeholders
2. Identifying potential areas of impact (positive and negative)
3. Discussing how these areas will be assessed and addressed in the Environmental
Impact Assessment (EIA) Phase of the Permitting Process.
4. Inviting comment from Stakeholders to ensure a participatory and comprehensive
Environmental Permitting Process
In accordance with the NEMA EIA Regulations (2010), detailed assessment of the processes
in terms of their potential environmental considerations, will only take place during the
Environmental Impact Assessment (EIA) Phase of this Environmental Application, which will
be informed through the Scoping Process and the Public Participation Process.
The Project
The Applicant wishes to establish a Clean Technology Waste to Energy Facility, broadly
comprising a sophisticated and self-contained facility that will process waste tyres as
feedstock and evacuate up to 15MW of electricity into the Eskom National Grid. The facility
will take up approximately 4000m2 of warehouse space on an existing, decommissioned,
heavy industrial site that is approximately 23000m2 in size.
The Clean Technology Waste to Energy Facility will be located on an existing,
decommissioned, heavy industrial site (called an allotment) that is part of a much larger
heavy industrial site in the Pretoria West area of Gauteng, South Africa.
The site on which the CTWEF is proposed to be housed is located on part of Portion 124 of
the Farm Pretoria Town and Townlands 361 JR, commonly referred to as the Pretoria
Industrial Estate or Arcelor Mittal Steel South Africa, where existing heavy industries are
located.
The CTWEF is referred to as clean by the Applicant due to the fact that the product
manufacturers have noted that the sophisticated technology (most of which is protected by
International Intellectual Property rights) results in all of the emissions being either re-used
in the process or collected and sold as a value-added product.

The Project will also be applying for carbon credits through either a Gold Standard
(http://www.cdmgoldstandard.org) or VCS (http://v-c-s.org) type process.

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The process involves whole tyres that are pre-processed (de-beaded) to remove the steel
beading and which are then further processed to produce shredded tyres (tyre crumbs),
which is used as the feedstock for the CTWEF.
The feedstock (shredded tyres) is processed by the CTWEF to consistently produce standard
fuel products (diesel fuel oil1, carbon black and methane gas2), which will be used to power
Steam Turbines and Wrtsil Tri-Fuel generators sets, which will then produce and evacuate
up to 15 megawatts (million watts or MW) of electricity to the Eskom National Grid through
the adjacent substation and power line which are located approximately 43m from the edge
of the site.

The rationale of the Applicant behind the Clean Technology Waste to Energy Facility is to:
i) address the waste tyre problem in South Africa through removing existing and future
waste tyres from the waste tyre cycle in an environmentally responsible manner;
ii) provide additional electricity generation capacity from a renewable resource to the
national Eskom grid; and
iii) create a sustainable business model with multiple local and international
partnerships

The CTWEF broadly consists of the following stages:


a) Receiving the tyre stock from suppliers and storing these on site in compressed tyre
bails
b) Processing the whole tyres into tyre feedstock through shredding the tyres
c) Conveying the feedstock to the pyrolysis and gasification facility
d) Pyrolysis / Gasification / Algal Bio-Reactor processes
e) Production of fuel products (syngas, carbon black, diesel fuel oil and biodiesel) from
Pyrolysis / Gasification / Algal Bio-Reactor
f) Electricity Production from a Steam Turbine and Wrtsil Tri-Fuel Generator Sets
running on the above-mentioned fuels
g) Evacuation of the electricity to the Eskom substation and National Grid

Product emissions (i.e. used in closed cycle system to generate electricity) include:
Pyro-Oil (also referred to as Diesel Fuel Oil or DFO in this Report)
Pyro-Gas (also referred to Methane Gas or Syngas in this Report)
Biodiesel (generated from an Algal Farm referred to in this Report as a Carbon
Capture Unit or CCU)
Carbon Black (also referred to as Carbon Char in this Report)
CO2 (Carbon Dioxide)
NOx (Oxides of Nitrogen)
SOx (Oxides of Sulphur)
Water Vapour
1
2

PLEASE NOTE: Diesel Fuel Oil (DFO) is also referred to in this Report as Pyro-Oil or Pyrolysis Oil and equates to the same substance
PLEASE NOTE: Methane gas is also referred to in this Report as Pyro-Gas, Pyrolysis Gas and Synthetic Gas (Syngas) and equates to the same substance

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Waste emissions (i.e. collected and sold as value-add products) include:


Gypsum
Bottom Ash
Steel

Figure 1: Schematic of the products typically associated with a


waste tyre, which include steel (beading), carbon, oil and gas
and which are captured and processed (except for the steel) by
the CTWEF. The oil is the Pyro-Oil, the Carbon is the Carbon
Black, the gas is the Pyro-Gas and the steel is the steel
beading.

Please note that the pre-processing (de-beading) of the tyres removes up to 99.9% of the steel and
approximately 0.1% of steel remains in a waste tyre prior to processing in the pyrolysis / gasification
system.

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Figure 2: Overview of the Operations of the CTWEP


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It is important to highlight that the proposed Clean Technology Waste to Energy Facility can
also process the following general, carbon based waste, which will all produce the same
products and emissions from the CTWEF, as waste tyres, although it is noted that the
products are produced in different proportions, depending on the feedstock type:

Municipal Solid Waste (MSW)


Plastics
Medical Waste (only carbon based waste, i.e. no radioactive waste etc.)
Coal or Coal dust
Agricultural Waste
Raw sewerage
Farm Manure

This CTWEF will however only be applying for Authorisation to process WASTE TYRES.
The Site
The Clean Technology Waste to Energy Facility will be located on an existing,
decommissioned, heavy industrial site (also called an allotment) that is part of a much larger
heavy industrial site in the Pretoria West area of Gauteng, South Africa. The site on which
the CTWEF is proposed to be housed is located on part of Portion 124 of the Farm Pretoria
Town and Townlands 361 JR, commonly referred to as the Pretoria Industrial Estate, where
existing heavy industries are located.

Figure 3: Proposed siting for the Clean Technology Waste to Energy Facility which is located in the
Arcelor Mittal Industrial Park, Pretoria West, Tshwane District Municipality, Gauteng, South Africa.

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The Broader Region


Pretoria is a city situated approximately 50km north of Johannesburg in the north-east of
South Africa, in a transitional belt between the plateau of the Highveld to the south and the
lower-lying Bushveld to the north at an altitude of about 1350m above sea level, in a warm,
sheltered, fertile valley, surrounded by the hills of the Magaliesberg range. It is one of the
country's three capital cities, serving as the executive (administrative) and de facto national
capital. The other two capital cities areas are Cape Town, the legislative capital, and
Bloemfontein, the judicial capital. Pretoria itself is also referred to as "Tshwane". Pretoria
is contained within the City of Tshwane Metropolitan Municipality as one of several
constituent former administrations (among which also are Centurion and Soshanguve).
The Permitting Process
The proposed CTWEF triggers several listed activities in terms of:
1. The National Environmental Management Act (No. 107 of 1998) (NEMA) and the
NEMA EIA Regulations, 2010, as amended.
2. The National Environmental Management: Air Quality Act (No. 39 of 2004)
(NEM:AQA)
3. The National Environmental Management: Waste Act (No. 59 of 2008) (NEM:WA)
The following applications have therefore been submitted to the respective Competent
Authorities3
1. EIA Application to the National Department of Environmental Affairs (DEA)
2. Waste Management License Application to the National Department of
Environmental Affairs (DEA)
3. Atmospheric Emissions License (AEL) Application to the Tshwane District
Municipality (TMM)

Figure 4: Illustration of the joint Environmental Authorisation Process in terms of the NEMA.

competent authority, in respect of a listed activity or specified activity, means the organ of state charged by the relevant Act with
evaluating the environmental impact of that activity and, where appropriate, with granting or refusing an environmental authorisation in
respect of that activity
2

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The Applicant is required by law to undertake the above-mentioned application processes


and obtain Authorisation, prior to any of the activities proceeding in the form of
construction on site.
In terms of the National Environmental Management Act (No. 107 of 1998) (NEMA), a
joint Application Process will be followed, in other words, the three distinct Authorisations
required above will be applied for through a single Application Process (using GN No. R 543
of the NEMA EIA Regulations 2010, as amended).

This joint process will also ensure a coherent and robust and efficient permitting
procedure as well as ensure that all stakeholders are presented with a holistic and
complete picture and project proposal.
The Public Participation Process
In terms of the National Environmental Management Act (No. 107 of 1998) (NEMA) and
the NEMA EIA Regulations, 2010, as amended, a joint Public Participation Process (PPP)
will also be run for the same reasons mentioned above. This is allowed and encouraged in
terms of the NEMA and was also discussed and agreed by the various Competent
Authorities involved with the process.
This PPP is illustrated below for ease of reference, for the various phases of the
Environmental Application process.
Public Participation for the Draft Scoping
Report (40 Calender Days)
Public Participation for the Final Scoping
Report (21 Calender Days)
Public Participation for the Draft EIA Report
(40 Calender Days)
Public Participation for the Final EIA Report
(21 Calender Days)
Figure 5: Illustration of the Public Participation Process for the joint Environmental Authorisation
Process in terms of the NEMA.

This draft Scoping Report forms part of the Initial Public Participation Phase of the Project.

All interested and affected Stakeholders (I&APs) are required by law to register before participating
in the above-mentioned process. Please refer to Appendix E of this Scoping Report for more detailed
information on how to register as a Stakeholder for this Project. Registered stakeholders are
encouraged to submit comments, concerns and any suggestions that will assist in making the
Application Process as comprehensive and participatory as possible.

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Potential Impacts (positive and negative) Identified


A number of potential environmental, economic and social considerations have been
identified during the Scoping stage of this project, which need to be considered and
assessed in more detail during the EIA stage.
These include:
Bulk Infrastructure considerations (e.g. roads, sewage, electricity and solid waste);
Noise, dust, light and vibration considerations;
Social and economic considerations;
Strategic Policy and Planning considerations;
Major Hazard Installation (MHI) considerations;
Climate Change considerations;
Air Quality considerations; and
Waste considerations
Specialist studies recommended by the EAP for the EIA stage should include:
Social Assessment;
MHI Assessment;
Town Planning Assessment;
Air Quality Assessment

The Alternatives Identified


Based on the available information, the EAP, in conjunction with reference to various
specialist opinions for the site has considered the following alternatives, which will, at the
EIA Phase, be determined for further comparative assessment, only once they have passed
the feasible and reasonable test as detailed in the NEMA EIA Regulations (2010):
1. Layout considerations (to address potential hazards associated with the fuel
storage tanks and site logistics);
2. Technology Alternatives (to address carbon emissions, i.e. using a CCU vs.
not using a CCU above a certain tonne per day processing threshold, for
example)
3. Activity considerations (to address the treatment of the waste stream, i.e.
tyres to landfill, incineration or the Eco2 SA CTWEF, for example); and
4. The No-Go consideration (this is a mandatory option)

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The Findings of the Scoping Phase of the Environmental Application


The findings of the Scoping Phase of the Environmental Application, which has been
informed by independent, professionally competent experts, suggests that the proposed
CTWEF is broadly aligned with the socio-economic, strategic policy, receiving environment
and town planning considerations necessary in the assessment of this application. These
findings will be assessed in detail at the EIA Phase of the Project.

Therefore, it is reasonable to conclude, that at this (draft scoping) stage of the process,
there have been no fatal flaws identified.

The findings of the Scoping Phase will be subject to detailed scrutiny in the EIA Phase of the
Environmental Application Process. The Project Assessment will also be informed by the
public participation process, which is key to a collaborative and participatory Environmental
Application Process and interested persons, organisation and identified stakeholders are
strongly encouraged to participate in this Environmental Application Process.

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DEFINITIONS AND TERMINOLOGY REFERRED TO IN THIS REPORT

Alternatives, in relation to a proposed activity, means different means of meeting the


general purposes
And requirements of the activity, which may include alternatives to
(a) the property on which, or location where, it is proposed to undertake the activity;
(b) the type of activity to be undertaken;
(c) the design or layout of the activity;
(d) the technology to be used in the activity;
(e) the operational aspects of the activity; and
(f) the option of not implementing the activity.
applicant, means a person who has submitted or who intends to submit an application.
competent authority, means the authority who in terms of the provisions of the NEMA
and the EIA Regulations is identified as the authority who must consider and decide on an
application in respect of a Specific listed activity.
Note: the competent authority in terms of an application for environmental authorisation
for an Activity listed in listing notice 1, 2 or 3, is not necessarily the same authority as the
licensing Authority in terms of the NEMA:WA or NEM: AQA.
Days means calendar days. Note: when a period of days must in terms of these
regulations be reckoned from or after a particular Day, that period must be reckoned as
from the start of the day following that particular day to the end of the last day of the
period, but if the last day of the period falls on a Saturday, Sunday or public holiday, that
period must be extended to the end of the next day which is not a Saturday, Sunday or
public holiday. The period of 15 December to 2 January must be excluded. In the reckoning
of days, where a timeframe is affected by the 15 December to 2 January period, the
timeframe must be extended by the number of days falling within the 15 December to 2
January period. Where a timeframe is affected by one or more public holidays, the
timeframe must be extended by the number of public holiday days falling within that
timeframe.
department, means the western cape department of environmental affairs and
development planning;

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environmental assessment practitioner (EAP), means the individual responsible for


planning, management and coordination of environmental impact assessments, strategic
environmental assessments, environmental management programmes or any other
appropriate environmental instrument introduced through the regulations.
Note: if exemption from the appointment of an EAP has been applied for, the applicant
must perform the tasks required of an EAP, as indicated in this guideline.
environmental authorisation, means the authorisation by a competent authority of a
listed activity or specified activity in terms of this act, and includes a similar authorisation
contemplated in a specific environmental management act.
interested and affected party (I&AP), for the purposes of chapter 5 of the NEMA and in
relation to the assessment of the environmental impact of a listed activity or related
activity, means an interested and affected party contemplated in section 24(4)(a)(v), and
which includes(a) any person, group of persons or organisation interested in or affected by such operation
or activity; and
(b) any organ of stale that may have jurisdiction over any aspect of the operation or activity.
NEMA EIA regulations, mean the environmental impact assessment regulations
promulgated in terms of the national environmental management act, 1998 (act no. 107 of
1998) (NEMA)12.
no-go option means the option of not implementing the activity;
organ of state, means (a) any department of state or administration in the national, provincial or local sphere of
government; or
(b) any other functionary or institution
I. Exercising a power or performing a function in terms of the constitution or a provincial
constitution; or
Ii. Exercising a public power or performing a public function in terms of any legislation
But does not include a court or a judicial officer.
Note: examples of organs of state include: municipalities (both the district and local
municipality), Heritage western cape, CapeNature, the department of water affairs, etc.

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previous regulations means the environmental impact assessment regulations published


in terms of: sections 26 and 28 of the ECA, by government notice no. R. 1183 of 5
September 1997; or NEMA, by government notice no. R. 385 in the government gazette of
21 April 2006.
public participation process, means a process by which potential interested and affected
parties are given an opportunity to comment on, or raise issues relevant to, an application.
state department, means any department or administration in the national or provincial
sphere of Government exercising functions that involve the management of the
environment or that administer a law relating to a matter affecting the environment.
Note: examples of state departments include: the department of water affairs, department
of agriculture, etc. Whilst all state departments are organs of state, not all organs of state
are state departments (e.g. Municipalities are organs of state, but not state departments).
registered interested and affected parties means
A) all persons who, as a consequence of the public participation process conducted in
respect of an application, have submitted written comments or attended meetings with the
applicant or EAP;
B) all persons who, after completion of the public participation process, have requested the
applicant or the EAP managing the application, in writing, for their names to be placed on
the register; and
C) all organs of state which have jurisdiction in respect of the activity to which the
application relates.
Note: to be registered as an interested and affected party the persons referred to in (a) and
(b) above must provide their names, contact details and addresses to the EAP managing the
application process.
Registered IA&Ps must ensure that they notify the EAP if their contact details and/or
address changes during the application process.
A registered I&AP is entitled to comment, in writing, on all written submissions made to the
department by the applicant or the EAP, provided that comments are submitted within the
specified timeframes and the I&AP discloses any direct business, financial, personal or other
interest which that party may have in the approval or refusal of the application.

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LEGISLATIVE TERMS OF REFERENCE

The proposed Clean Technology Waste to Energy Facility triggers three different sets of
legislative requirements, housed under the National Environmental Management Act (Act
107 of 1998 as amended).

EIA Regulations
The NEMA EIA Regulations (August 2010) were published on 18 June 2010 and deal
with activities that may have an impact on the environment.
The National Department of Environmental Affairs is the Competent Authority
Waste Regulations
The NEM: Waste Act was published on 03 July 2009 and deal with waste related
permitting activities in South Africa.
The National Department of Environmental Affairs is the Competent Authority
Air Quality Regulations
The NEM: Air Quality Act was published on April 2010 and deals with air quality
related permitting activities in South Africa.
The District Municipality (Tshwane) is the Competent Authority

Accordingly, the following approach to the Environmental Application process for the
proposed Activity is based on the provisions stipulated in the above EIA Regulations
contained in Government Notice No.s R. 543, R. 544, R. 545 and R. 546, which dictate that a
single SCOPING AND EIA type Application process be followed.

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EIA Regulations Listed Activities


Based on the information currently available on the proposed development, it is anticipated
that the following Listed Activities contained in Listing Notice 1 require a Basic Assessment
process in terms of the NEMA:
Listing Notice 1: Activity 1
The construction of facilities or infrastructure for the generation of electricity where:
(i) the electricity output is more than 10 megawatts but less than 20 megawatts; or
(ii) the output is 10 megawatts or less but the total extent of the facility covers an area in excess of 1hectare.
Listing Notice 1: Activity 13
The construction of facilities or infrastructure for the storage, or for the storage and handling, of a dangerous
good, where such storage occurs in containers with a combined capacity of 80 but not exceeding 500 cubic
metres.

There are no Listing Notice 2 Activities that have been identified.


Waste Regulations Listed Activities
Based on the information currently available on the proposed development, it is anticipated
that the following Listed Activities contained in Category A of the NEM: Waste Act
necessitate the need to conduct a Basic Assessment process in terms of the NEMA:
Category A: Activity 1
The storage, including the temporary storage, of general waste at a facility that has the capacity to store in
excess of 100m3 of general waste at any one time, excluding the storage of waste in lagoons

Category A: Activity 4
The storage of waste tyres in a storage area exceeding 500m 2
Category A: Activity 5
The sorting, shredding, grinding or bailing of general waste at a facility that has the capacity to process in
excess of one ton of general waste per day

Category A: Activity 7
The recycling or re-use of general waste of more than 10 tons per month
Category A: Activity 18
The construction of facilities for activities listed in Category A of this Schedule

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The following Listed Activity contained in Category B may also be applicable and require a
Scoping and EIA process in terms of the NEMA:
Category B: Activity 2
The reuse and recycling of hazardous waste
Category B: Activity 4
The biological, physical or physic-chemical treatment of hazardous waste at a facility that has the capacity to
receive in ex cess of 500kg of hazardous waste per day

Category B: Activity 5
The treatment of hazardous waste using any form of treatment regardless of the size or capacity of such a
facility to treat such waste

Category B: Activity 8
The incineration of waste regardless of the capacity of such a facility

Air Quality Act Listed Activities


Based on the information currently available on the proposed development, it is anticipated
that the following listed activity is applicable.
Activity 8
Burning of General and Hazardous waste. Facilities where general waste and hazardous waste including
health care waste, crematoria and veterinary waste are incinerated.

As the development proposal is of National significance, this application for environmental


authorisation will be submitted to and considered by the National Department of
Environmental Affairs and (DEA) as the appropriate Competent Authority for the NEMA EIA
Regulations (2010) and the NEM: Waste Act (2009). The NEM: AQA (2010) Application (Air
Quality Emissions License or AEL) will be considered by the District Municipality (Tshwane)
as the Competent Authority.
Based on the above and in terms of GN No. R. 543 of the NEMA EIA Regulations (2010), a
single SCOPING AND EIA PROCESS must be followed.
In terms of the NEMA (Act 107 of 1998 as amended), the three (3) applications above can
take place through a SINGLE application process with THREE (3) separate (or an integrated)
decision being issued by the respective Competent Authorities.
The regulatory
methodology above ensures a coherent, integrated and efficient permitting process for all
parties involved.

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The Scoping and EIA Process can be broadly broken down into the following key phases.

Application
Form
Environmen
tal Decision
of
Application

Initial Public
Particpation

Scoping and EIA


Process (NEMA
2010)

Final EIR

Draft
Scoping
Report

Final
Scoping
Report

Draft EIR

Environmen
tal Decision

Figure 6: Overview of the NEMA EIA (2010) Scoping and EIA Process

The phases highlighted in yellow above illustrate phases currently underway or already
completed. The process proposed is in keeping with the requirements stipulated in the
NEMA EIA Regulations (2010).
The application requirements as set out in Notice No.s R. 543, R. 544, R. 545 and R. 546,
promulgated in terms of Chapter 5 of the National Environmental Management Act (Act 107
of 1998) and the requirements of DEA have been followed in the preparation of this Scoping
Report.

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ENVIRONMENTAL
EXPERTISE

ASSESSMENT

PRACTITIONER

(EAP)

DETAILS

AND

Terramanzi Environmental Consulting (www.terramanzi.co.za) has been appointed as the


Independent Environmental Practitioner (EAP) to undertake this Application for
Environmental Authorisation on behalf of the Applicant.
Fabio Venturi, through Terramanzi Environmental Consulting, who is responsible for this
Report, has a wealth of strategic environmental assessment and environmental
management expertise in both government and the private sectors, stretching over a
decade within the industry.
Fabio Venturi is a certified Environmental Scientist registered with the Southern African
Institute of Ecologists and Environmental Scientists (SAIEES), sits on the Western Cape
Committee Branch of the South African Affiliate of the International Association for Impact
Assessment (IAIAsa), is a founding member of the Environmental Assessment Practitioners
Association of South Africa (EAPASA), is a member of the Zoological Society of South Africa
(ZSSA), is a Certified Carbon Footprint Analyst and Energy Efficiency Auditor and is
qualified as an Accredited Professional (AP) with the Green Building Council of South Africa
(GBCSA), as well as being a member of the Carbon Protocol of South Africa and the
Southern African Alternative Energy Association (SAAEA).

Terramanzi Environmental Consulting (TM) hereby declares that they have no conflicts of
interest related to the work of this Report. Specifically, TM declares that they have no
personal financial interests in the property and/or activity being assessed in this report, and
that they have no personal or financial connections to the relevant property owners,
developers, planners, financiers or consultants of the property or activity, other than fair
remuneration for professional services rendered for this Report to the Competent
Authority. TM declares that the opinions expressed in this Report are independent and a
true reflection of their professional expertise.
Terramanzi Environmental Consulting is a Level 4 Broad Based Black Economic
Empowerment Company and is professionally accredited with a number of relevant
industry bodies as well as being an approved supplier on the Western Cape Supplier
Database (WCSD), in line with the Preferential Procurement Policy Framework Act No. 5 of
2000 (PPPFA).

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LEGISLATION, POLICY AND GUIDELINES CONSIDERED IN THE PREPARATION


OF THIS SCOPING REPORT

The National Environmental Management Act, Act 107 of 1998.


Regulations in terms of Chapter 5 of the NEMA, 1998. GN No.s R. 543, R. 544, R.
545 and R. 546, National Environmental Management: Biodiversity Act 10 of 2004
(as amended).
National Heritage Resources Act, Act 25 of 1999 (as amended).
National Water Act, 1998 (Act No. 36 of 1998) as amended.
Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983) as amended.
Heritage Resources Act, 1999 (Act No. 25 of 1999) as amended.
Guideline Document, EIA Regulations, Implementation of Sections 21, 22 and 26 of
the Environment Conservation Act, April 1998.
DEAT Integrated Environmental Management Guideline Series, Guideline 3: General
Guide to the Environmental Impact Assessment Regulations, 2006, June 2006.
DEAT Integrated Environmental Management Guideline Series, Guideline 4: Public
Participation in support of the Environmental Impact Assessment Regulations, 2006,
May 2006.
DEAT Integrated Environmental Management Guideline Series, Guideline 5:
Assessment of Alternatives and Impacts in support of the Environmental Impact
Assessment Regulations, 2006, June 2006.
DEA&DP Guideline Document: Guideline on Public Participation, October 2011
DEA&DP Guideline Document: Guideline on the Interpretation of listed activities.
DEA&DP Guideline Document: Guideline on Alternatives, October 2011
DEA&DP Guideline for determining the scope of specialist involvement in the EIA
process, June 2005
DEA&DP Guideline for the review of specialist input in the EIA process, June 2005
DEA&DP Guideline for involving visual and aesthetic specialists in the EIA process,
June 2005
DEA&DP Guideline for involving biodiversity specialists in the EIA process, June 2005
The 12 National Lekgotla Outcomes (2010);
Gauteng Provincial Growth and Development Strategy (2005);
Gauteng Medium Term Strategic Framework (2009-2014);
Gauteng Employment, Growth and Development Strategy (2010);
Gauteng Integrated Energy Strategy (2010):
The City of Tshwane Integrated Development Plan (2011/2016).
Draft National Waste Management Strategy (2010);
Gauteng Hazardous Waste Management Policy (2008);

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INTRODUCTION

The proposed Clean Technology Waste to Energy Facility (CTWEF), concisely, will entail the
establishment of a sophisticated and self-contained Facility that will process waste tyres as
feedstock and evacuate electricity to the Eskom National Grid. The CTWEP will take up
approximately 4000m2 of warehouse space with associated activities taking place over the
23000m2 site allotment, which is located in a heavy industrial type environment.
The CTWEF is referred to as clean due to the fact that the product manufacturers have
noted that the sophisticated technology (most of which is protected by International
Intellectual Property rights) results in all of the emissions being either re-used in the process
or collected and sold as a value-added product.
The process involves whole tyres that are pre-processed (de-beaded) to remove the steel
beading and which are then further processed to produce shredded tyres, which is used as
the feedstock for the CTWEF. The feedstock (shredded tyres) is processed by the CTWEF
to consistently produce standard fuel products (diesel fuel oil4, carbon black and methane
gas5), which will be used to power Steam Turbines and Wrtsil Tri-Fuel generators sets,
which will then produce and evacuate up to 15 megawatts (million watts or MW) of
electricity to the Eskom National Grid through the adjacent substation and power line which
are located approximately 43m from the edge of the site.
The CTWEF will process up to a maximum of approximately 120 tonnes of shredded waste
tyres per day, which equates to up to approximately 200 400m3 of whole tyres per day,
which are effectively removed from landfill.
Please note:
1 tonne of whole tyre = approximately 1670m3, i.e. this is a whole tyre and includes
the air space within the tyre.
1 tonne of shredded tyre = approximately 1.6m3, i.e. this is a shredded tyre with tyre
chunks of approximately 20cm2 in size.
Based on the available information, 15MW can power approximately 10 000 homes. The
facility will create 72 permanent jobs. It has been estimated by the REDISA (Recycling and
Economic Development Initiative South Africa), plan which aims to remove waste tyres from
the South African environment, that up to 10 000 new jobs will be created by the plan 6. The
CTWEF will potentially process as much as 20% of the South African annual waste tyre
production, thereby establishing a link to approximately 2000 indirect jobs.

PLEASE NOTE: Diesel Fuel Oil (DFO) is also referred to in this Report as Pyro-Oil or Pyrolysis Oil and equates to the same substance
PLEASE NOTE: Methane gas is also referred to in this Report as Pyro-Gas, Pyrolysis Gas and Synthetic Gas (Syngas) and equates to the same substance
The basis for this is to subsidise the collection and recycling process by attaching a value to scrap tyres: Once they have a value, individuals and small entrepreneurs will seek out and
remove tyres from their community and deliver them to a collection point. A key element of the REDISA plan is that it will specifically and exclusively target the small and very small
businesses: the aim is to address the waste tyre problem whilst at the same time creating jobs in the area where they are needed most: in the informal and SMME(Small, Micro and
Medium Enterprises) sectors.
5
6

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It is important to highlight that the proposed CTWEF can also process the following general,
carbon based waste, which will all produce the same products and emissions from the
CTWEF, as waste tyres:
Municipal Solid Waste (MSW)
Plastics
Medical Waste (only carbon based waste, i.e. no radioactive waste etc.)
Coal or Coal dust
Agricultural Waste
Raw sewerage
Farm Manure
This CTWEF will however only be applying for Authorisation to process WASTE TYRES.
The Clean Technology Waste to Energy Facility will be located on an existing,
decommissioned, heavy industrial site (called an allotment) that is part of a much larger
heavy industrial site in the Pretoria West area of Gauteng, South Africa. The site on which
the CTWEF is proposed to be housed is located on part of Portion 124 of the Farm Pretoria
Town and Townlands 361 JR, commonly referred to as the Pretoria Industrial Estate or
Arcelor Mittal Steel South Africa, where existing heavy industries are located.
Pretoria is a city situated approximately 50km north of Johannesburg in the north-east of
South Africa, in a transitional belt between the plateau of the Highveld to the south and the
lower-lying Bushveld to the north at an altitude of about 1350m above sea level, in a warm,
sheltered, fertile valley, surrounded by the hills of the Magaliesberg range.
It is one of the country's three capital cities, serving as the executive (administrative) and de
facto national capital. The other two capital cities areas are Cape Town, the legislative
capital, and Bloemfontein, the judicial capital.
Pretoria itself is also referred to as
"Tshwane". Pretoria is contained within the City of Tshwane Metropolitan Municipality as
one of several constituent former administrations (among which also are Centurion and
Soshanguve).

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The Rationale
The rationale of the Applicant behind the Clean Technology Waste to Energy Facility is to:
iv) address the waste tyre problem through removing existing and future waste tyres
from the waste tyre cycle;
v) provide additional electricity generation capacity from a renewable resource to the
national Eskom grid; and
vi) create a sustainable business model with multiple local and international
partnerships

Waste Tyres in South Africa


Based on the available information there are between 60 million and 100 million waste
tyres currently located in South Africa with an additional 10 million waste tyres being added
annually to the above figure, which will contribute the above mentioned waste tyre stock.
Waste tyres often take the form on informal tyre landfills (i.e. stockpiles of waste tyres)
which have been shown to demonstrate the following issues:

Vector borne diseases from mosquitos that breed in the water logged areas of tyres
Tyre landfill fire hazards with the potential to produce noxious gaseous emissions
and air pollution

Various photographs illustrating the typical


environmental and health issues associated
with waste tyres stockpiles / informal
landfills.

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Renewable Energy Capacity in South Africa


The CTWEF is a policy target as depicted from the Department of Energys Integrated
Resource Plan or IRP (2010 to 2030). The current iteration of the Integrated Resource Plan
(IRP) for South Africa, initiated by the Department of Energy (DoE) after a first round of
public participation in June 2010, led to the Revised Balanced Scenario (RBS) that was
published in October 2010. The document outlines the proposed generation new build fleet
for South Africa for the period 2010 to 2030. This scenario was derived based on the costoptimal solution for new build options (considering the direct costs of new build power
plants), which was then balanced in accordance with qualitative measures such as local
job creation. In addition to all existing and committed power plants, the RBS included a
nuclear fleet of 9,6 GW; 6,3 GW of coal; 11,4 GW of renewables; and 11,0 GW of other
generation sources.
A second round of public participation was conducted in November/December 2010, which
led to several changes to the IRP model assumptions. The main changes were the
disaggregation of renewable energy technologies to explicitly display solar photovoltaic
(PV), concentrated solar power (CSP) and wind options; the inclusion of learning rates,
which mainly affected renewables; and the adjustment of investment costs for nuclear
units, which until then represented the costs of a traditional technology reactor and were
too low for a newer technology reactor (a possible increase of 40%).
Additional cost-optimal scenarios were generated based on the changes. The outcomes of
these scenarios, in conjunction with the following policy considerations, led to the PolicyAdjusted IRP:

The installation of renewables (solar PV, CSP and wind) were brought forward in order
to accelerate a local industry;
To account for the uncertainties associated with the costs of renewables and fuels, a
nuclear fleet of 9,6 GW was included in the IRP;
The emission constraint of the RBS (275 million tons of carbon dioxide per year after
2024) was maintained;
Energy efficiency demand-side management (EEDSM) measures were maintained at the
level of the RBS.

The Policy-Adjusted IRP includes the same amount of coal and nuclear new builds as the
RBS, while reflecting recent developments with respect to prices for renewables. In addition
to all existing and committed power plants (including 10 GW committed coal), the plan
includes 9,6 GW of nuclear; 6,3 GW of coal; 17,8 GW of renewables; and 8,9 GW of other
generation sources. The Policy-Adjusted IRP has therefore resulted in an increase in the
contribution from renewables from 11,4 GW to 17,8 GW.

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To contribute towards the above target and to stimulate the renewable industry in South
Africa, a market mechanism was identified in the form of Feed-In Tariffs (FIT). FITs are
simply put, guaranteed prices for electricity supply as opposed to the ever fluctuating
conventional consumer tariffs.
The fundamental economic principle supporting the FITs is the establishment of a tariff (i.e.
price) that covers the cost of generation plus a reasonable profit to encourage the
development of these projects as well as the associated financial investment to enable the
project. This type of facility (FIT) has been established in over 36 countries to promote
renewable energy production.
The establishment of the Renewable Energy Feed-In tariff (REFIT) in South Africa provides an
strong incentive and opportunity to increase the proportion of renewable energy generation
capacity in South Africa and to create a competitive environment for renewable energy
when measured against conventional energy generation facilities (such as coal for example).
The National Energy Regulator of South Africa (NERSA) has the legal mandate to determine
the prices and conditions under which any form of electricity generation can be supplied by
license.
The Clean Technology Waste to Energy Facility is a renewable energy generation facility
proposed in response to the above National Policy for the establishment of commercial
electricity generation. The proposed project will be developed in stages up to a maximum
output of 15 MW which will be evacuated into the national grid.

A Sustainable Business Model based on Partnerships


The Applicant has advised, that although they will be looking to participate in the IPP
Programme offered by the DoE, their business model does not depend on this.
Further, ECO2 SA Partnership (Pty) Ltd has created numerous partnerships with many local
and International Companies, with a view of establishing a world leading Energy from Waste
Company specialising in the delivery of renewable green energy.

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Please note that all technical information in this Report relating to the Eco 2 SA Partnership CTWEF
process description, including product and waste emissions, have been provided by a Professional
and experienced Energy Engineer (Professor Thomas Campbell) of the Eco2 SA Partnership Team,
who is Internationally recognised as a leading expert in this field and who is responsible for the
design and patenting of many of the technological innovations that form part of the Eco 2 SA
Partnership CTWEF, which is considered cutting edge in terms of the above. These technical
innovations contributed to the Eco2 SA Partnership CTWEF recently winning the COP17 Clean
Technology Award for Breakthrough Innovation (December 2011) as part of the COP17 proceedings
recently held in Durban, South Africa. The CTWEF was rigorously assessed by a panel of local and
International expert technical judges, as well as the Departments of Energy (DoE), Trade and
Industry (DTI) and Environmental Affairs (DEA).
It can therefore be reasonably suggested that any technical information provided is accurate, peer
reviewed and accountable.

Figure 7: Illustration of the COP17 Clean Tech SA 2011 Winner Award.

Following on from the above, the following Report Sections illustrate concisely, how the
process works, at a Scoping level type assessment, which is aimed at providing a good
understanding of the CTWEF for all stakeholders participating in the process.

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GENERAL DESCRIPTION OF PROPOSED ACTIVITY

7.1 Broad Overview of the Proposed CTWEF (Process Flow for all Components)

The proposed Clean Technology Waste to Energy Facility (CTWEF), concisely, will entail the
establishment of a sophisticated and self-contained Facility that will process waste tyres and
produce green electricity from this, as a result of the fact that all the emissions are either
re-used or collected and sold as a value-added product.
The CTWEF broadly consists of the following stages:
h) Receiving the tyres stock from suppliers and storing these on site in compressed
tyre bails
i) Processing the whole tyres into tyre feedstock through shredding the tyres
j) Conveying the feedstock to the pyrolysis and gasification facility
k) Pyrolysis / Gasification / Algal Bio-Reactor processes
l) Production of fuel products (syngas, carbon black, diesel fuel oil and biodiesel) from
Pyrolysis / Gasification / Algal Bio-Reactor
m) Electricity Production from a Steam Turbine and Wrtsil Tri-Fuel Generator Sets
running on the above-mentioned fuel
n) Evacuation of the electricity to the Eskom substation and National Grid
Product emissions (i.e. used in closed cycle system to generate electricity) include:
Pyro-Oil (also referred to in this Report as Diesel Fuel Oil or Pyrolysis Oil)
Pyro-Gas (also referred to in this Report as Methane Gas or Synthetic Gas)
Biodiesel
Carbon Black (also referred to in this Report as Carbon Char)
CO2 (Carbon Dioxide)
NOx (Oxides of Nitrogen)
SOx (Oxides of Suphur)
Waste emissions (i.e. collected and sold as value-add products) include:
Gypsum
Bottom Ash
Water Vapour
Steel
The processes above, as well as the emissions are described in more detail further in this
Scoping Report. In accordance with the NEMA EIA Regulations (2010), a detailed
assessment of the processes and emissions in terms of their potential environmental
considerations will only take place during the Environmental Impact Assessment (EIA) Phase
of this Environmental Application, which will be informed through the Scoping Process and
the Public Participation Process.

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Figure 8: Broad Overview of Operations for the CTWEP


2

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7.2 Receiving and Preparing the Feedstock (whole tyres to shredded tyres)
7.2.1 Receiving of Waste Tyres

Waste tyres form the principal feedstock for the CTWEF and must be sourced from
appropriate suppliers, which can include landfills, tyre vendors and other similar facilities.
These waste tyres can be delivered to site by a carrier (rail or road) which demonstrates an
appropriate waste transfer licence.
Tyres can be delivered to site via one of the following methodologies:
Rail line, which is existing and directly adjacent to the CTWEF
Small trucks (up to 60 tonne capacity which is approximately 6000 whole tyres) via
the existing entrance road (Staal Road) directly adjacent to the CTWEF.
Photo 1: Illustration of a cargo goods train, which in this
instance, will carry tyres (whole, bailed or shred) which will
be contained in the cargo bays of the train.

Photo 2: Illustration of a typical 60


tonne dump truck that will be used to
ship tyres onto site. Two trips with
one of these trucks per day would be
adequate to meet the 120 tonne per
day (TPD) requirement of the CTWEF.

Once the tyres are delivered, they are visually inspected for contamination by oil-based
products such as diesel or hydraulic oil. Any contaminated tyres will be rejected and
removed by the supplier. Once the tyres are checked, they are stacked in a demarcated
temporary storage area, prior to pre-processing stage (i.e. high pressure rinsing, bailing and
shredding of tyres). The temporary tyre store (whole tyres) will be located adjacent to a
tyre pre-processing (i.e. bailing and shredding) area and will be undercover to keep rain and
dust off the tyres. Because tyres are a potential fire risk (mainly due to arson), they will be
stored and stacked in a secure area with relatively small cells to limit this risk.

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Tyres are delivered in one and/or a combination of the following physical forms:
Whole tyres (i.e. a complete waste tyre)
Pre-Shredded tyres (i.e. these tyres have already been washed and shredded)
Compressed (bailed) tyres (i.e. these tyres have been bailed to facilitate efficient
transport and storage)
As discussed above, whole tyres are either compressed prior to delivery or compressed on
arrival, which assists in efficient on-site storage of tyres that are waiting to be processed (i.e.
shred). The compression of whole waste tyres is undertaken by a tyre baler, which uses a
hydraulic press which can achieve a size reduction ration of over 10:1 in terms of volume.
Each compression can accommodate up to 100 tyres and the volume of the bail is
approximately 1m x 1m x 1.5m (approximately 1.5m3 per bail). After compression the tyres
are secured by steel wire ties. A typical baler (and there are various models available to
scale the CTWEF) can process up to 3200 tyres per day (32 bales or 48m3 or 32 tonnes of
compressed tyres) and the unit is portable.
Photo 3: Typical baler with
compressed tyres (i.e. a tyre
bale) being tied with wire,
ready for transport to storage
facility for processing.

Pre-shredded tyre comprises chunks of tyre of approximately 25cm2 in size that have been
shred off-site and that have already been de-beaded (i.e. steel removed).
Photo 4: Typical illustration of pre-shredded
tyres showing approximate size of tyre chunks
(also called crumbs).

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Photo 5: This is another photo illustration of


shredded tyres that show the general
consistency of tyres chunks/crumbs. Note
how the shredded tyres show no evidence of
steel beading, which has in fact already been
removed from the tyre prior to shredding
(called de-beading the tyre).

Tyre and tyre shred are received at a weighbridge check-in facility and recorded into the
system. The tyre and tyre shred are offloaded utilizing a diesel and/or electric powered fork
lifter for tyre bales or tyre chips. Pre-shredded tyres will be moved immediately to the postprocessing area (the feedstock storage area).
Photo 6: Illustration of a typical electric/diesel type
forklift used for the tyre handling operations.

7.2.2 Preparing the Waste Tyres for Feedstock

Whole tyres (whole or bailed) received must still be prepared as feedstock and would
typically undergo the following process:

Whole tyres would be bailed with a bailing machine and then moved to storage cells
on site, ready for de-beading (steel removal) and shredding
Bailed tyres would then be de-beaded and fed into the shredding machine, to
become feedstock and join the pre-shredded material already in the feedstock
storage area

The proposed CTWEF will accommodate up to 120 tonnes of whole tyres per day. Each
compressed bail holds 100 tyres (approximately 1 tonne per bail as a waste tyre averages
10kg). A system of storage cells is proposed to house the compressed tyre bails, with each
cell measuring approximately 3.8m wide x 3.8m long and 1.6m high and which can house 12
bails which equates to 12 tonnes of compressed tyre (approximately 900 whole tyres).

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The CTWEF will receive waste tyres via rail and road every day throughout the week and will
require storage for Saturday and Sundays processing as well as spare capacity, therefore,
there will be approximately 30 storage cells included in the operational design and this is
detailed further below in Section 7.2.5, the Internal Tyre Reticulation section.
An area of approximately 320m2 which can house approximately 800m3 of bailed tyres has
therefore been set aside. The tyre stocking area will be located adjacent to the conveyor
system which will be load a tyre every 8 to 12 seconds for processing.

7.2.3 Tyre De- Beading (stripping of steel)

This process involves removing as much steel as possible from the waste tyre. A waste tyre
contains approximately 15% steel (beading) and once processed by the de-beader, the
waste tyre contains approximately 0.1% steel content.
Photo 7: Electric and/or
Diesel tyre de-beader,
which can also be
portable. Please note
that the model shown is
illustrative and the
model used in the CTWEF
will be scaled
appropriately.

7.2.4 Crumbing Process (tyre shredding)

This process involves the shredding of whole waste tyres, by a powerful machine, into tyre
shreds (also called tyres crumbs), which are approximately 25cm2 in size.
Photo 8: Typical shredding machine, which
can also be portable. Please note that the
model shown is illustrative and the model
used in the CTWEF will be scaled
appropriately and possibly integrated with
the internal tyre reticulation system.

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Briefly, the shredding plant does the following:


A super chopper roughly cuts up the tyres. This is a very heavy-duty machine with
large knives and a disc pusher to assist in feeding truck tyres.
The chopped tyres then pass via conveyor to the tumble back feeder, which controls
the rate of feed to the heavy rasper. The heavy rasper, which has 20 flying and 21
static knives and a screen, cuts the chopped tyres up further.
From the rasper the material moves under a magnet, which removes the steel from
the rubber granulate, and into a silo, which then feeds into a fine-granulator.
A fine-granulator is equipped with 18 flying knives and 6 static knives, and further
grinds the tyre particles down. The granules are then conveyed to the classifier,
which removes about half of the textile from the granules.
The granules are then passed, once again, under a magnet, which removes more of
the steel. This granulation and lint removal process is repeated through another set
of machines, and the granules are again passed under a magnet.
Now the granules pass through an aspirator, which removes the last of the textile
from the granulated rubber, and separates the rubber into three sizes, which then
get bagged.
Over-sized granules are sent back to the beginning of the fine granulation process.
This equipment and this configuration, according to the Applicant, is reportedly the most
appropriate, for the production of high quality, lint-free rubber granules, with low
maintenance costs and relatively smooth running. About 3.3 tonnes (i.e. approximately 330
tyres) of tyres can be processed per hour using the type of equipment discussed above.
Please note the model shown is illustrative only and the model used in the CTWEF will be
scaled appropriately and possibly integrated with the internal tyre reticulation system.
These machines produce a 99.9% steel and textile free rubber crumb, with a fine filter
system installed.
Photo 9: A view of the typical
mechanical parts associated with tyre
shredding machines, which resemble
gears and rasping knives moving past
one another. Note the tyre shreds
forming.

Photo 10: A typical shredded tyre stockpile, which is now


considered feedstock for the CTWEF. This feedstock will
be stored undercover to protect the feedstock from
external elements.
2

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7.2.5 Internal Whole Tyre Reticulation (in preparation for shredding)

This section only applies to whole tyres that have not yet been shredded and moved to the
feedstock storage area. Once the whole tyres have been received and the tyres have been
bailed they are moved to an area of storage cells that hold the bailed tyres. As discussed
above, each storage cell will hold approximately 12 bails (12 tonnes) of tyres and there will
be approximately 15 storage cells lined up on either side of the conveyor belt system. The
conveyor belt and sorting area is typically arranged in a layout that allows for efficient
delivery and manoeuvring of the whole and bailed tyres. The tyres are then fed onto an
open conveyor and dumped into a tyre shredder to be crumbed.
Photo 11: Typical internal whole tyre
reticulation and pre-processing area
with an integrated shredder highlighted
in red outline.

7.2.6 Internal Feedstock Reticulation (in preparation for gasification / pyrolysis)

This process involves transporting the crumbed (shredded) tyres which is now considered
feedstock. The system proposed comprises a pipe conveyor, which is an enclosed curvegoing transportation system for all kinds of bulk materials. At the loading and discharging
points, the conveyor system is identical with open troughed conveyors. The difference
starts after the loading point, where the belt is formed into its typical tubular shape by
special idler arrangements over a certain distance and finally is led through idler panels with
hexagonal cut outs and offset idler arrangement. At the discharging point, the belt opens
automatically after the final idler panel and transfers the material to its next destination.
Due to its tubular shape, the conveyor is able to manage horizontal and vertical curves as
well as high inclinations. The enclosed transportation system not only protects the conveyed
material against external influences such as climatic conditions, it also avoids material loss
and spillage.
Photo 12: Typical high speed internal
reticulation system which caters for
the CTWEF feedstock (shred tyres)
requirements.

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Figure 9: Illustration of the various stages of the tyre processing components of the CTWEP
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7.3

The Pyrolysis and Gasification System


7

7.3.1 An Overview of Waste to Energy Technology

The most typical form of Waste to Energy (WtE) Facility (i.e. not a Clean Technology
Facility) derives energy from the incineration of waste source. Most WtE processes produce
electricity directly through combustion or produce a combustible fuel product, such as
methane, methanol, ethanol or synthetic fuels. Modern incinerators reduce the volume of
the original waste by 95% to 96% depending upon composition and degree of recovery of
materials such as metals from the ash for recycling. Concerns regarding the operation of
incinerators include fine particulate, heavy metals, trace dioxin and acid gas emissions, even
though these emissions are relatively low from modern incinerators. Other concerns
include toxic fly ash and incinerator bottom ash (IBA) management.
Incinerators have electric efficiencies of the order of 14% to 28% with the rest of the energy
(if not recovered) lost as waste heat.
There are a number of new and emerging WtE technologies that are able to produce energy
without direct combustion. Many of these technologies have the potential to produce more
electric power from the same amount of fuel than would be possible by direct combustion.
This is mainly due to the separation of corrosive components (ash) from the converted fuel,
thereby allowing higher combustion temperatures. Some are able to efficiently convert the
energy into liquid or gaseous fuels. Some typical thermal and non-thermal new
technologies are listed below for ease of reference.
Thermal technologies:
Gasification (produces combustible gas, hydrogen, synthetic fuels)
Thermal depolymerization (produces synthetic crude oil)
Pyrolysis (produces combustible tar or bio-oil and chars)
Plasma arc gasification or plasma gasification process (produces rich syngas including
hydrogen and carbon monoxide)
Non-thermal technologies:
Anaerobic digestion (produces biogas rich in methane)
8
Fermentation production (produces biofuel for example)
The proposed Clean Technology Waste to Energy Plant will utilise the following general
technologies as part of the overall CTWEF:
Gasification
Pyrolysis
Fermentation (biofuel through algal farm technology)
Gasification and pyrolysis have electric efficiencies (i.e. thermal conversion efficiencies)
upwards of 75% and can be self-sustaining in terms of using the electricity generated to
continue driving the process.

Wikipedia - (http://www.wikipedia.org)
Waste to energy technology includes fermentation, which can take biomass and create ethanol, using waste cellulosic or organic material. In the fermentation process, the sugar in the
waste is changed to carbon dioxide and alcohol, in the same general process that is used to make wine. Normally fermentation occurs with no air present.
8

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7.3.2 A Broad Overview of the Proposed Clean Technology Waste to Energy Facility

The general gasification and pyrolysis technologies described above have been adapted,
improved and refined and protected through Intellectual Property (IP) mechanisms (i.e. laws
to protect intellectual property) to produce a Clean Technology Waste to Energy Facility that
is, according to the inventors, superior in design (i.e. efficiency and environmental benefits)
to any other WtE Plant currently in existence across the World.
As a result of these advances and innovations in process control technology (i.e. the
Intellectual Property designs discussed above), the Applicant considers the gasification
process to be safe to operate and environmentally sound.
The Applicant has also
confirmed that the CTWEF is designed to operate well within the internationally recognised
SEPA (UK)9 Permit and ISO10 standards and manufactured and installed to meet the most
rigorous design specifications for quality, optimized performance and efficiency.
This superior design has resulted in the same proposed CTWEF design winning the COP17
Clean Technology Awards for Breakthrough Innovation during 2011, which is a prestigious
awards ceremony dedicated to rewarding breakthrough technologies and innovative
sustainable solutions to some of the most critical environmental and economic issues of the
World.
The proposed Clean Technology Waste to Energy Facility will process the tyre shred
feedstock (at up to 120 tonnes per day) and consistently generate the same fuel products
through various patented processes.
The following fuel products will be produced through the above-mentioned process.
a) Methane Gas11 (also referred to as Pyro-Gas or Syngas in the Report)
b) Diesel Fuel Oil12 (also referred to as Pyro-Oil or DFO in the Report)
c) Carbon Black13 (also referred to as Carbon Char in the Report. This is an emission
from the pyrolysis / gasification process and is processed internally to become
pelletized and is then used in the Steam Boiler)
d) Biodiesel14
e) Algae biomass (this is an emission from the algal farm facility and is processed
internally to become pelletized and is then used in the Steam Boiler)
This fuel will in turn be used to power 2.5MW Wrtsil15 Generator Sets and Steam
Turbines, which in turn will power the CTWEF and evacuate up to 15MW of electricity to
the Eskom National grid.

The Scottish Environment Protection Agency (SEPA) is Scotlands environmental regulator.


ISO (International Organization for Standardization) is the world's largest developer and publisher of International Standards. ISO is a network of the national standards institutes of
164 countries, one member per country, with a Central Secretariat in Geneva, Switzerland, that coordinates the system.
11
Methane is a chemical compound with the chemical formula CH4. It is the main component of natural gas, and probably the most abundant organic compound on earth. The relative
abundance of methane makes it an attractive fuel.
12
Broadly speaking, fuel oil is any liquid petroleum product that is burned in a furnace or boiler for the generation of heat or used in an engine for the generation of power, except oils
having a flash point of approximately 40 C and oils burned in cotton or wool-wick burners. In this sense, diesel is a type of fuel oil. The term fuel oil is also used in a stricter sense to
refer only to the heaviest commercial fuel that can be obtained from crude oil, heavier than gasoline and naphtha.
13
Carbon black is a form of amorphous carbon that has a high surface-area-to-volume ratio, although its surface-area-to-volume ratio is low compared to that of activated carbon. It is
dissimilar to soot in its much higher surface-area-to-volume ratio and significantly lower (negligible and non-bioavailable) PAH (polycyclic aromatic hydrocarbon) content. Carbon black is
used as a pigment and reinforcement in rubber and plastic products.
14
Biodiesel is meant to be used in standard diesel engines and is thus distinct from the vegetable and waste oils used to fuel converted diesel engines. Biodiesel can be used alone, or
blended. Biodiesel can also be used as a low carbon alternative to heating oil.
15
Wrtsil is a Finnish corporation which manufactures and services power sources and other equipment in the marine and energy markets. The core products of Wrtsil include large
combustion engines. Wrtsil sees the growth in smart power market, oil and gas industry, lifecycle solutions and in environmental solutions. The company employed 17,913 workers in
more than 70 countries at the end of 2011, and its headquarter are located in Helsinki. In 2011, Wrtsils net sales totalled EUR 4.2 billion with approximately 18,000 employees. The
company has operations in nearly 170 locations in 70 countries around the world. Wrtsil is listed on the NASDAQ OMX in Helsinki, Finland.
10

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The proposed Clean Technology Waste to Energy Facility will also generate emissions, some
which are processed to fuel products to be re-used in the CTWEF and some which are
collected and sold as value-add products. These emissions are described briefly below and
are dealt with in more detail further in this report.
The following emissions will be produced through the above-mentioned process.
a) CO2 (from the Wrtsil Generator Sets and the main Pyrolysis / Gasification Unit)
b) SOx (from pyrolysis / gasification process)
c) NOx (from the Wrtsil Generator Sets)
d) Water Vapour (from the Steam Boiler)
e) Bottom Ash (from pyrolysis / gasification process)
f) Steel (from the tyre de-beading and almost insignificantly, the pyrolysis / gasification
process)
g) Carbon Black (from the pyrolysis /gasification process and referred to above as a preprocessed fuel product)
h) Algae biomass (from the algal farm process and referred to above as a pre-processed
fuel product)
The proposed Clean Technology Waste to Energy Facility will store the following volumes of
fuel products on site to ensure that the CTWEF can run continuously:

Methane Gas up to 80 tonnes (80m3) will be stored in 2 (two) above ground


storage tanks (AST) of 30m3 and 50m3 capacity each.
Diesel Fuel Oil up to 72 000 litres (72m3) will be stored in the form of two 36m3
ASTs

Photo 13: typical 50 000 litre aboveground fuel storage tank

The sections following will provide an overview of the above-mentioned process, as well as
specifically highlight both the product emissions and the waste emissions in more detail.

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7.3.3 A Detailed Overview of the Eco SA Clean Technology Waste to Energy Facility
7.3.3.1

The Eco SA Start Up Process

The CTWEF is designed to operate continuously (24 hours per day and 350 days per year).
Therefore the CTWEF will only be started once per year and the process described below
would only be applicable one per year or after an emergency shutdown, which the Applicant
advises would be an extremely rare occurrence.
The process starts with pre-purging of the Reaction Chamber, whereby the Reaction
Chamber is purged of air with steam and the oxygen levels are monitored to ensure safe
operating conditions. Once the pre-purge process is complete, the highly-efficient
pyrolysis/gasification burners (i.e. they emit low levels of NOx), located in the Reaction
Chamber, automatically turn on and the purge valve is closed. Vacuum pumps are
energized as soon as the pre-purge process is complete and a dampening system is utilized
to keep the furnace pressure at a predetermined negative pressure at all times during the
process.
It takes approximately 45 minutes to bring the system up to temperature once tyres are
loaded and the purging is complete. The fuel input to the burners is predetermined based
on reactor design and capacity. Gasification and condensation normally starts within 10 to
15 minutes once the system has obtained operating temperature. Syngas (i.e. methane) is
used to supply the necessary gas which supplies the heat energy for approximately 10-15
minutes on start-up, where after, the system is self-sufficient.
Please note: times indicated are only at the start and finish of a period of continuous
operation which, according to the Applicant is 350 continuous days in a calendar year, in
other words, the start-up process will only happen once per year.
7.3.3.2

The Eco2 SA Pyrolysis and Gasification Process (the Reaction Chamber)

This component of the CTWEF, in essence, provides for the thermal decomposition of
organic or carbon-based feedstock in the absence of oxygen. The pyrolysis / gasification
process takes place in the Reaction Chambers described above, which are completely
sealed and contain radiant tubes16 heated by patented low NOx burners that are operated
to maintain a minimum temperature of 340C and up to a maximum temperature of 510C.
The reaction chamber will be under a constant negative pressure (of between 50mm to
125mm of water column)17 in the absence of air. The Reaction Chamber is also equipped
with automatic relief valves that will be automatically activated if required, and release any
excess gas or unacceptable pressure build-up to a thermal oxidizer, which ensures that
these gases remain in the CTWEF and are not released to the atmosphere. An automated
oxygen monitor controls this process. Please note: The system is designed such that no
raw gas can be released to the atmosphere. The Reaction Chamber forms the core
process in the CTWEF and the products that emanate from the Reaction Chamber are
Pyrolysis Vapours (distilled to Pyro-Gas) and Carbon Char (pelletized to carbon pellets).
16

The objective of the radiant tube burner is to transfer heat from combustion gases to the radiant tube and then radiate the energy to the load. Radiant tube burners are used in
specific heating processes where combustion products cannot come in contact with the load or material. Radiant tube burners are an indirect heating burner meaning the heat is
transferred without any direct flame or combustion exhaust. Radiant tube burner systems are designed to reduce nitrous oxide in the burner process. Radiant tube burners include a
flue gas recirculating assembly designed to reduce NOx emissions.
17
A vacuum gauge is used to measure the pressure in a vacuum. Because pressure was once commonly measured by its ability to displace a column of liquid in a manometer, pressures
are often expressed as a depth of a particular fluid (e.g. inches of water). The most common choices are mercury (Hg) and water; water is nontoxic and readily available, while mercury's
density allows for a shorter column (and so a smaller manometer) to measure a given pressure. Note: 50mm of water column = 0.049 Bar and 125mm of water column = 0.122 Bar. 1
Bar is about equal to the atmospheric pressure on Earth at sea level.

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7.3.3.3

The Rationale behind Continuous Operations for the CTWEF

The CTWEF is designed to operate continuously for 24 hours per day and for 350 days per
year. The rationale behind this process has to do with the fact that the application of heat
and throughput of material within the Reaction Chamber is uninterrupted.
This continuous process will allow the core Reaction Chamber temperature to remain
constant and ensure that the gas produced remains separated from the outside air (i.e. the
atmosphere). Any residual gas (i.e. Pyro-Gas) is channelled to the Pyro-Gas storage Tank
and utilised by the Wrtsil Engines to create electricity. The continuous process is also
important in order for the process to remain commercially viable. The feedstock (i.e. the
tyre shred) is introduced to the air lock in batches from a number of receptacles and these
merely top up the existing supply of shred within the machine, hence, maintaining the
uninterrupted supply and the continuity of the process.
7.3.3.4

The Core Process in the Reaction Chamber

Within Reaction Chamber, the high temperature and oxygen deprived atmosphere drive off
a mixture of gaseous hydrocarbons 18. All gases leaving the Reaction Chamber go through a
condenser, at which point the gases liquefy and are delivered to a Pyro-Gas Unit (i.e. the
Pyro-Gas storage tanks). Non-condensing gases travel through yet another heat exchanger
for the final separation of liquids and gases. The burners shut down when the process
temperature reaches 510C. The gasification process continues for approximately another
hour. Dampers automatically adjust when the process gas flow increases or decreases.
The process described above is a continuous process of reductive distillation19; thereby
allowing each product in the cycle to be extracted at the appropriate temperature. There is
no need to stop the process to extract products. Batch processing is completely different in
that the process undergoes heating and cooling in each cycle, which is a very time
consuming process and considered highly inefficient and hence continuous distillation is
preferred.
The next step in the process is the post-purge process of the reaction chamber. Steam
supplied from a small steam boiler is injected from the bottom of the
reactor and air is purged from the system to atmosphere.
A
hydrocarbon monitoring system monitors gases in the Reaction
Chamber until a safe level is reached. At this point in the process
automatic activated doors release the Carbon Char through a purged
corridor chute (to be processed to Carbon Pellets) and this works
through an Archimedes Screw20 type system (pictured to the right) to maintain integrity of
main Reaction Chamber environmental conditions.

18

In organic chemistry, a hydrocarbon is an organic compound consisting entirely of hydrogen and carbon. Hydrocarbons are one of the Earth's most important energy resources. The
predominant use of hydrocarbons is as a combustible fuel source. Extracted hydrocarbons in a liquid form are referred to as petroleum (literally "rock oil") or mineral oil, whereas
hydrocarbons in a gaseous form are referred to as natural gas.
19
Distillation is a method of separating mixtures based on differences in volatilities of components in a boiling liquid mixture. Distillation is a unit operation, or a physical separation
process, and not a chemical reaction. Commercially, distillation has a number of applications. It is used to separate crude oil into more fractions for specific uses such as transport,
power generation and heating. Water is distilled to remove impurities, such as salt from seawater. Air is distilled to separate its componentsnotably oxygen, nitrogen, and argon for
industrial use. Distillation of fermented solutions has been used since ancient times to produce distilled beverages with a higher alcohol content. The premises where distillation is
carried out, especially distillation of alcohol are known as a distillery.
20
The Archimedes' screw consists of a screw (a helical surface surrounding a central cylindrical shaft) inside a hollow pipe. As the shaft turns, the bottom end scoops up a volume of
liquid or solid or both. This matter then slides up in the spiral tube, until it finally pours out from the top of the tube and feeds into a designated containment area.

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Figure 10: Illustration of the various stages of the Pyrolysis and Gasification Process
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The table below illustrates, concisely, the various continuous processed that make up the
CTWEF and that are discussed in this Report.
Unit Process

Function of Unit Process

Batch or
Continuous
Process

Diesel Power Generator


(Wrtsil Tri-Fuel
Engines)

Provide power to entire facility operations

Continuous

Fuel Storage Unit


(Tanks)

To feed fuel into Diesel Generator

Continuous

Pyro Gas Storage Unit

To feed pressurized Pyro Gas (methane) into Diesel Generator and


Pyrolysis Unit

Continuous

Pre-Processing Unit
(shredding of tyres)

Physical breakdown of all feedstock (both organic and synthetic


carbon based materials)

Continuous

Pyrolysis Unit

Processing of tyre feedstock under oxygen free conditions

Continuous

Steam Turbine Boiler


Unit

Provide energy to the Power Generator

Continuous

Power
Generator/Electricity
Consolidation

Produce electricity that can be utilized by the facility and excess is


provided to the local grid

Continuous

Carbon Capture Unit

The photosynthesis process, using algae bioreactors capture the


CO2 and NOx from the Wrtsil engines and the pyrolysis unit.
These reactors produce algal crude (oil) and biomass, roughly in
the proportion of 70/30. Algal crude (oil) is used to feed the
gensets, and the algal biomass is pelletized with char to feed the
steam boilers.

Continuous

Bio fuel extraction from


Carbon Capture unit

Algal is removed from the bioreactors on a continuous basis, dried


and then pressed to produce biofuel and biomass.

Continuous

Table 1: A summary of the various continuous processes in the CTWEF

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7.4 Product Emissions from the CTWEF

Product Emissions described in this section refer to solid, liquid or gas emissions generated
by the CTWEF that are utilised in the closed cycle system, in other words, these emissions
are recycled into the process or utilised to run the system in a self-sufficient manner. These
emissions do not leave the CTWEF.
7.4.1 Liquid Emissions

The proposed CTWEF will generate the following liquid Product Emissions:
Pyro-Oil (also referred to as Diesel Fuel Oil or DFO in this Report) a type of crude
diesel
Pyro-Gas (also referred to as Methane Gas or Syngas in this Report) - in a liquid form
(i.e. LPG or Low Pressure Gas like that which burns in a domestic gas plate burner)
Biodiesel from the algal farm (used to capture and process NOx and CO 2 gas
emissions)
Water vapour21 this will be released from the Steam Boiler (running on pelletized
carbon black and algae biomass) and fed into solution with the algal bioreactor
7.4.2 Gaseous Emissions

The proposed CTWEF will generate the following gaseous Product Emissions:
Carbon Dioxide22 this will be produced from residual emissions from the Wrtsil
Generator sets (running on methane and DFO) producing electricity as well as the
residual emissions from the Pyrolysis / Gasification Unit.
These CO2 emissions (above) will be fed into a micro algae bioreactor which will
produce biofuel which in turn will be fed back into the Wrtsil Generator sets
NOx23 residual emissions will be produced from the Wrtsil Generator sets
(running on syngas and DFO) producing electricity and this will be fed into a micro
algae bioreactor which will produce biofuel which will in turn be fed back into the
Wrtsil Generator sets
7.4.3 Solid Emissions

The proposed CTWEF will generate the following solid Product Emissions:
Carbon Black carbon char will be produced through the pyrolysis / gasification
process and is further processed (pelletized in a closed, vacuum system) and utilised
as feedstock in the Steam Boilers, producing electricity. The carbon conversion
process results in high quality fine carbon feeding the steam turbine boiler.
Algal solid waste this will be produced from the algal facility (CCU) and is pelletized
as feedstock for the Steam Boiler.
Photo 14: from left to
right: diesel (fuel oil or
biofuel), methane gas and
carbon black

21

Water vapour is the gas phase of water. It is one state of water within the hydrosphere. Water vapour can be produced from the evaporation or boiling of liquid water or from the
sublimation of ice. Under typical atmospheric conditions, water vapor is continuously generated by evaporation and removed by condensation.
22
Carbon dioxide (CO2) is a naturally occurring chemical compound. It is a gas at standard temperature and pressure and exists in Earth's atmosphere in this state.
23
NOx is a generic term for mono-nitrogen oxides NO and NO2 (nitric oxide and nitrogen dioxide). They are produced from the reaction of nitrogen and oxygen gases in the air during
combustion, especially at high temperatures. In areas of high motor vehicle traffic, such as in large cities, the amount of nitrogen oxides emitted into the atmosphere as air pollution can
be significant. NOx gases are formed everywhere where there is combustion like in an engine.

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7.5 Waste Emissions from the CTWEF

Waste Emissions described in this section refer to solid, liquid or gas emissions generated by
the CTWEF that are not utilised in the closed cycle system, in other words, these emissions
are not recycled or utilised to run the system and are instead safely collected for shipping
off site to a vendor that will utilise the emissions. These emissions do leave the CTWEF.
7.5.1 Liquid Emissions

The proposed CTWEF will generate the following liquid Waste Emissions:
There will be no liquid waste emissions from the CTWEF
7.5.2 Gaseous Emissions

The proposed CTWEF will generate the following gaseous Waste Emissions (please observe
the note):
Water vapour24 this is harmless
Air as in atmospheric composition air
NOx within the NEM: AQA permitted levels
CO within the NEM: AQA permitted levels
PLEASE NOTE: THESE GASES ARE ONLY EMITTED TO ATMOSPHERE IF A CARBON CAPTURE UNIT
(CCU) IS NOT FITTED TO THE CTWEF THE EMISSION LEVELS ARE STILL WELL WITHIN THE NEM:
AQA PERMITTED LEVELS. PLEASE REFER TO DETAILED DISCUSSION ON FOLLOWING PAGE.
7.5.3 Solid Emissions

The proposed CTWEF will generate the following solid Waste Emissions:
Steel (pre-processing) - the majority of the steel will be recovered during the preprocessing phase prior to the shredded tyre rubber entering the pyrolysis chamber.
This is high quality steel that is sold to industry.
Steel (post processing) - a further amount of less than 1% of steel will also be
recovered during the pyrolysis process.
SOx25 and its compounds will be recovered (through a specialized process) from the
Wrtsil engines in the form of Gypsum, which is a standard modern board product
for the building industry. The product will be sold to the building/construction
industry.
Residual bottom ash - is at a consistency suitable for the brick-making industry and
will be donated to the brick-making project on an adjacent site
Photo 15: from left to right:
Gypsum, Bottom Ash and
bailed steel

24

Water vapour is the gas phase of water. It is one state of water within the hydrosphere. Water vapour can be produced from the evaporation or boiling of liquid water or from the
sublimation of ice. Under typical atmospheric conditions, water vapor is continuously generated by evaporation and removed by condensation.
25
SOx refers to many types of sulfur and oxygen containing compounds such as SO, SO 2, SO3, S7O2, S6O2, S2O2, etc.

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The tables below provide an indication of the approximate solid and gaseous emissions from
the CTWEF.
Feedstock

of

Steel

shredded

recovered

during

pyrolysis and before

Pyro-Gas

Pyro-Oil

Carbon

Bottom

produced

produced

Char

Ash

waste tyres

26

Electricity
yield

produced

120 tonnes per

6 tonnes per day

day

28.5

48

tonnes

tonnes

per day

per day

37.5

420 kg

126 000 000

tonnes

per day

kwh per

per day

annum

Table 2: Approximate indication of solid product emissions from the CTWEF


Feedstock
shredded

of
waste

Water

Vapour

Air produced

SOx produced

produced

NOx

CO2

produced

produced

tyres
120 tonnes per day

23 tonnes per

231 tonnes per

0.327 tonnes

6.59 tonnes

0.002 tonnes

day

day

per day to

per day to

per day to

Gypsum

CCU

CCU

Table 3: Approximate indication of gaseous emissions from the CTWEF

IMPORTANT NOTE: The Applicant has advised that the CTWEF can only accommodate a Carbon Capture Unit (CCU)
once the Facility is scaled to 60 Tonnes per Day (TPD) due to the fact that the CCU is an expensive facility that only
becomes viable at a certain TPD of processing.
The Applicant has also advised that even though NOx and CO2 will be emitted to the atmosphere up until a CCU is
fitted, that these emission levels are well within the NEM: AQA permit levels stipulated.

26

Total Bottom Ash mass per 120 tonnes per day of ELT: 420 kg. The bottom ash contains trace elements of heavy metals below detection limits on equipment less than 1 part per
million. No heavy metals are oxidized in the pyrolysis process

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7.6 Hours of Operation

The CTWEF will operate 24 hours per day and 350 days per year in a continuous process, as
discussed earlier in this document. The table below provides an overview of the various
components of the CTWEF in terms of their operational activities.

Unit Process / Plant

Operating Hours

No. Days Operation per


Year

Diesel Power Generator (Wrtsil Tri-Fuel


Engines)

00h00-24h00

350

Fuel Storage Unit (Tanks)

00h00-24h00

350

Pyro Gas Storage Unit

00h00-24h00

350

Pre-processing Unit (tyre shredding)

00h00-24h00

350

Pyrolysis Unit

00h00-24h00

350

Steam Turbine Boiler Unit

00h00-24h00

350

Power Generator

00h00-24h00

350

Carbon Capture Unit

00h00-24h00

350

Bio fuel extraction from Carbon Capture


unit

00h00-24h00

350

Table 4: Operating hours of the proposed CTWEF.

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7.7 Electricity Generation (Steam Turbines and Wartsila Tri-Fuel Engines)


7.7.1 Steam Boiler and Turbine

The solid residue remaining from the pyrolysis and gasification process discussed earlier in
the document consists of carbon char and residual steel. The residual steel will be separated
magnetically and bailed as a value add product. Trace elements of heavy metals fall below
detection limits on equipment to level of less than 1 part per million and so are not
quantified here and considered insignificant by the Project Engineer. The Carbon Char is
conveyed to a fluid bed furnace and is further processed (i.e. pelletized) and utilised on site
as a feedstock in a steam turbine cycle, producing electricity. A bag filter will be utilised for
the capture of all particulate matter and solids (i.e. dust from carbon char).

Water vapour is the only emission


from the steam cycle.
Photo 16: Typical steam boiler facility

The Carbon Char conversion process results in high quality fine carbon with limited
impurities feeding the steam turbine boiler. The process will also be supplemented by the
introduction of biomass (algae) resulting in a renewable energy feedstock. This unique
process, which is protected by IP, results in the ability of the steam boiler to handle very fine
particulate matter and co-firing (i.e. burns on either char or biomass).
It is important to note that this is not a standard steam boiler as the carbon is pre-converted
into a pure form of carbon and therefore contamination (i.e. impurities in the carbon) is at a
very low level. The biomass from algae and carbon char (that has been pelletized) is also a
pure fuel.
The residual bottom ash produced by the steam boiler system is at a consistency suitable for
the brick-making industry and will form part of the value-added products generated by the
CTWEF emissions.

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7.7.2 Tri-Fuel (Wrtsil) Engines

The syngas (methane/pyro-gas) and diesel fuel oil (DFO) produced through the pyrolysis and
gasification process will be fed into Wrtsil tri-fuel engines for electricity generation. The
generator sets can be fed up to three different formulations of fuel which can run on 3
common rails.
The fuel for the Wrtsil tri-fuel engines will be pre-processed using a unique and patented
technology which involves water injection into the feed-line of the engine. The result of this
patented technology reduces engine emissions significantly (up to 20%); raises the efficiency
of the diesel engine (up to 5%)and increases engine longevity and reliability resulting in
lower running costs and better environmental performance.
Gas fractions and inert gases (i.e. residual gases from the Pyro-Tanks) are collected and
temporarily stored in a dedicated volatile organic compound (VOC) tank (approximately 5
litres in size) and are used as a supplemental fuel for the Wrtsil engines . This fuel is a
pure and highly potent energy source.
Photo 17: Illustration of a typical Wrtsil 2.5MW
tri-fuel generator set.

7.7.3 Carbon Capture Unit (CCU)

This process uses micro algae bioreactor technology (much like a fish tank) to capture
residual carbon emissions (CO2) and NOx from the Wrtsil tri-fuel engines. The NOx and
CO2 and particulate matter (from combustion which normally include PM10, PM4 and submicron particles)27 form feedstock for the algal bioreactors (please refer to illustration
below of an Algae Biofactory. Algae28 are the most common and fastest growing plants in
the world. Algae require raw materials that are abundant and inexpensive, such as sunlight,
salt water or industrial process water, carbon dioxide and nutrients (Phosphate and
Nitrogen). Algae can also have a lipid content of up to
70% giving high oil yields. The CO2 enhances growth
times of algae and functions as a high yield feedstock
for bio-fuel extraction.
There are no residue gases from the
CCU and this will be demonstrated
by the Applicant in the EIA Phase of
the Environmental Application.
27

Particulates also known as particulate matter (PM), suspended particulate matter (SPM), respirable suspended particle (RSP; particles with diameter of 10 micrometres or less) fine
particles, and soot are tiny subdivisions of solid matter suspended in a gas or liquid. In contrast, aerosol refers to particles and/or liquid droplets and the gas together. Sources of
particulate matter can be man-made or natural. Air pollution and water pollution can take the form of solid particulate matter, or be dissolved
28
Algae (Latin for "seaweed") are a very large and diverse group of simple, typically autotrophic organisms, ranging from unicellular to multicellular forms, such as the giant kelps that
grow to 65 meters in length. They are photosynthetic like plants and simple because their tissues are not organized into the many distinct organs found in land plants. The largest and
most complex marine forms are called seaweeds.

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7.7.4 Feeding the Electricity into the Grid

The proposed Clean Technology Waste to Energy Facility will feed electricity directly into the
substation via trenched cables. The exact technical design and specification of these cables
will be determined at the EIA Phase of the Project.

Photo 18: The Eskom substation with several electrical power lines running above the substation are
outlined in red. The proposed Clean Technology Waste to Energy Facility will feed electricity into the
substation via trenched cables. The CTWEF location is directly to the left of the tar road and just out
of view in the photograph.

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7.7.5 Emergency Flaring and Shut-Down Process

The CTWEF will, according to the Applicant, rarely undergo a shutdown process and/or
emergency flaring.
The reason for emergency flaring is normally related to the over-pressurization of the
Reaction Chamber (i.e. where the pyrolysis and gasification take place). Once flaring has
taken place, the system returns to normal operation.
The reason for emergency shutdown is normally related to abnormal operation such as
equipment failure or operator error.
Should a shutdown occur, the CTWEF is designed in such a manner so as to ensure that
there are no emissions released to the atmosphere as the engine (Wrtsil) shuts down
within 5 revolutions of the crankshaft, which is typically around 1 second.

7.8 Bulk Services Required to Operate the CTWEF


7.8.1 Roads

Access roads are already in place and are located directly adjacent to the proposed CTWEF.
These roads cater for an existing heavy industrial area and so the traffic generated by the
proposed CTWEF (2 x 60 tonne trucks per day) is not anticipated to be out of keeping with
existing operations on the broader site.
7.8.2 Water

Water services are already in place and are located on site. The CTWEF will utilise potable
water in a closed loop system that comprises approximately 5m3 of water. This water will
be topped up due to evaporation and together with other water used on site (which will
include washing of whole tyres before bailing and shredding and potable water use for
general cleaning and maintenance activities), a total of approximately 0.5m3 (i.e.
approximately 500 litres) per day of potable water will be utilised.
7.8.3 Electricity

Municipal supplied electricity is on site and available for use. The proposed CTWEF will
however generate all of its own electricity and is effectively self-sustaining.
7.8.4 Sewage

Municipal supplied sewage services are already installed on site and are, according to the
applicant, in good working order.

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GENERAL PURPOSE AND REQUIREMENT OF THE ACTIVITY AS PROPOSED BY


THE APPLICANT

This section briefly outlines the requirements, intentions and rationale that the applicant
has for proposing and supporting the specific activity.

The proposed Clean Technology Facility represents cutting edge and world class
technology.
The proposed Clean Technology Facility is practically emissions free and carbon
neutral
The proposed Clean Technology Facility addresses the waste tyre problem in South
Africa, in a sustainable, environmentally friendly manner
The proposed Clean Technology Facility produces green electricity through the fact
that waste goes into the CTWEF and electricity comes out the other side, all gaseous
emissions are captured and re-used in the self-sustaining process
The proposed Clean Technology Facility has recently won the COP 17 Clean
Technology Awards (December 2011), in the category, Breakthrough Innovation,
which was rigorously assessed by local and international experts and was supported
by the National Departments of Trade and Industry, Energy and Environment,
respectively, which demonstrates a sound technological and sustainable business
proposal
The proposed Clean Technology Facility will support up to 72 direct and 2000 indirect
and sustainable employment opportunities
The proposed Clean Technology Facility will result in the effective reduction of
approximately 438 000 tonnes (120 TPD plant) of waste tyres are currently in landfills
The proposed Clean Technology Facility will result in the production of approximately
1.26 million MWh (120 TPD Plant) of green electricity over a 10 year period
The proposed Clean Technology Facility will result in the effective net carbon
reduction of approximately 1 600 000 tonnes (120 TPD plant) of CO2e (i.e. the
representative greenhouse gases that are commonly referred to as a carbon
footprint)

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NEED AND DESIRABILITY OF THE ACTIVITY

This section outlines the purpose of considering the activity need and desirability in
accordance with the National Environmental Management Principles in terms of NEMA
which serve as a guide for the interpretation, administration and implementation of NEMA
and the NEMA EIA regulations (2010).
9.1 Legislative Framework

The National Environmental Management Principles specifically inter alia require the
following:

Environmental Management must place people and their needs at the forefront of
its concern and equitably serve their interests;
Environmental Management must be integrated, acknowledging that all elements
of the environment are linked and interrelated, and it must take into account the
effects of decisions on all aspects of the environment and all people in the
environment by pursuing the selection of the best practicable environmental option;
Environmental justice must be pursued so that adverse environmental impacts shall
not be distributed in such a manner as to unfairly discriminate against any person;
and
Decisions must take into account the interests, needs and values of all interested
and affected parties;
The Environment is held in public trust for the people, the beneficial use of
environmental resources must serve the public interest and the environment must be
protected as the people's common heritage.

Need and desirability must thus be considered in the context of sustainable development
which speaks to social, economic and environmental considerations and takes a long-term
strategic view to environmental management.

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9.2 Sustainable Development

Sustainable development is best summarised by an extract from the United Nations World
Commission on Environment and Development and reads as follows:
"Sustainable development is development that meets the needs of the present without
compromising the ability of future generations to meet their own needs As such it requires
the promotion of values that encourage consumption standards that are within the bounds
of the ecologically possible and to which all could reasonably aspire."
(Our Common Future, WCED, 1987) 29.

Ecosystem Services

Social Systems

Economic
Systems
Systems

The widely accepted interdependence


model
of
sustainability recognises that
social and economic systems
have never been and can never
be independent of the natural
system.
This model further supports the
belief that interactions between
and within component systems
will
result
in
feedback
throughout the system
Endorsed by the National DEA

(Mebratu, 1998)

(Good) Governance

It is thus important that the Environmental Impact Assessment Phase carefully


consider and assess the broad principles of sustainable development in order to
clearly demonstrate the need and desirability of the proposed activity in the context
of NEMA.

29

United Nations. 1987."Report of the World Commission on Environment and Development." General Assembly Resolution 42/187, 11
December 1987
2

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10 STRATEGIC POLICY CONSIDERATIONS APPLICABLE TO THE PROPOSED


CTWEF

This section provides an overview of the policy documents of relevance to the proposed
development. These include a number of National, Provincial and Local Authority level
documents and the details are gleaned from the Social Scoping Report (Barbour, May 2012)
and Town Planning Scoping report (Groenewald, May 2012).
National, Provincial and Local Authority Policy
The 12 National Lekgotla Outcomes (2010);
Gauteng Provincial Growth and Development Strategy (2005);
Gauteng Medium Term Strategic Framework (2009-2014);
Gauteng Employment, Growth and Development Strategy (2010);
Gauteng Integrated Energy Strategy (2010):
The City of Tshwane Integrated Development Plan (2011/2016).
National and Provincial Level Waste Policy
Draft National Waste Management Strategy (2010);
Gauteng Hazardous Waste Management Policy (2008);
10.1 The 12 National Lekgotla Outcomes

During the National Lekgotla held in January 2010, Cabinet identified 12 National Outcomes
for the current Administration. All relevant Cabinet Ministers signed performance
agreements linked to the relevant Outcomes. The 12 National Outcomes essentially define
national public-service delivery priorities and associated (incremental) targets until 2014.
More detailed delivery agreements have since been developed in order to extend targets
and responsibilities to national and provincial departments, agencies and municipalities.
Performance and evaluation systems have also been implemented to track performances.
The 12 National Outcomes thus essentially define the key thrust of national socio-economic
developmental policy until 2014, and hence also underpin all current provincial and local
level strategic (developmental) planning (although specific implementation and emphasis
would differ from province to province and local authority to local authority, in line with
prevailing local development conditions and priorities).
Outcomes 2, 4, 5, 6 and 10 are broadly applicable to aspects of the Eco2 Clean Technology
Waste to Energy Facility proposal:

(2) A long and healthy life for all South Africans;


(4) Decent employment through inclusive economic growth;
(5) A skilled and capable workforce to support an inclusive growth path;
(6) An efficient, competent and responsive economic infrastructure network;
(10) Environmental assets and natural resources that is well-protected and continually
enhanced.

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10.2 Gauteng Growth and Development Strategy (2005)

The Gauteng Provincial Growth and Development Strategy (PGDS) of 2005 is founded upon
the inclusive vision to ultimately create a better life for all of Gautengs citizens. The
purpose of the PGDS is therefore to provide a strategic framework to guide inclusive socioeconomic growth and development in the province over the medium term. In this regard,
the PGDS outlines six key strategic objectives with regard to provincial growth and
development:

(1) Provision of social and economic infrastructure and services that will build
sustainable communities and contribute to halving poverty;
(2) Accelerated, labour absorbing economic growth that increases per annum and that
will create long-term sustainable jobs and contribute to halving unemployment;
(3) Sustainable socio-economic development;
(4) Enhanced government efficiency and cooperative governance;
(5) Deepening participatory democracy, provincial and national unity and citizenship;
(6) Contributing to the successful achievement of New Partnership for Africas
Development (NEPAD) goal and objectives.

10.3 Gauteng Medium Term Strategic Framework (2009)

The 2009-2014 Gauteng Medium Term Strategic Framework (MTSF) is aligned with its
national counterpart MTSF. The Gauteng MTSF outlines seven development priorities for
the province over the relevant five year period, namely:

(1) To stimulate redistributive economic development to create decent work,


sustainable livelihoods and reduce income inequality;
(2) To develop well-educated and skilled people to build a productive, socially cohesive
and well-governed Gauteng;
(3) To develop healthy people to build a productive Gauteng;
(4) To develop a food secure Gauteng that is a sustainable region which promotes
equitable rural development;
(5) To build a safe, secure and corrupt-free Gauteng with high moral standards and
integrity;
(6) To build cohesive, caring and sustainable communities with decent families, public
services and access to economic opportunities;
(7) To build a developmental state which has the capacity to effect socio-economic
transformation through effective administration and improved public services.

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10.4 Gauteng Employment, Growth and Development Strategy (2010)

The Gauteng Employment, Growth and Development Strategy (GEGDS) was approved by
the Gauteng Executive Council in May 2010. The GEGDS is closely aligned with national
governments strategic pursuit of a new economic growth path in order to address past
shortcomings, and specifically with regard to creating more inclusive growth. The GEGDS is a
medium to long term planning tool, and seems likely to become a key provincial policy
document. The GEGDS is aligned with the 2009-2014 GMTSF.
The GEGDSs vision essentially reflects that of the 2005 PGDS, namely "an inclusive and
sustainable Gauteng economy that promotes a developmental and equitable society". The
GEGDS acknowledges that despite achievements since 1994, enormous structural
weaknesses persist in the provincial economy. The purpose of the GEGDS is therefore to
build upon the 2005 PGDS, and outline a new economic growth path aimed at addressing
weaknesses, while still striving towards building a stable, inclusive economy and society. Of
specific relevance to the CEO2 application is the central place given to building a provincial
green economy.
The strategic objectives outlined in GEGDS are aligned with those of the 2009-2014 GMTSF,
as well as the key national commitment to a new economic growth path, and are the
following:

Long-term strategic objective: to create decent work and build a growing inclusive
economy (aligned with Strategic Priority 1 of the GMTSF);
Outcome statement (as per GMTSF) is to stimulate redistributive economic
development, to create decent employment, sustainable livelihoods and to reduce
income inequality;
Long-term Growth Path Choices or Decisions identified in the GEGDS are the following:
An innovating economy (including one which ensures that existing resources are
used more productively/ less wastefully);
An inclusive economy (one which focuses on providing the same basic level of socioeconomic and bulk infrastructure development throughout the province);
A green economy (i.e. one which uses existing resources in a more efficient,
environmentally-friendly and sustainable manner) (GPG; 2010a).

The discussion below is largely derived from Siraaj Mohammeds (Witwatersrand University
School of Economics and Business Science) summary and analysis on the Engineering News
website30 and it extracted from the Social Assessment Scoping Report (Barbour, January
2012):
The GEGDS aims to drive the provincial economy onto a new economic growth path by
focusing on three areas: innovation, green growth and inclusivity. The innovation will not
only be building on the high technology sectors of the economy, but will also focus on using
existing resources, skills and institutions more effectively. The provincial government will
work with business and other partners to ensure that existing businesses and budding
entrepreneurs are supported in a way that promotes innovation. The goal is to work with
current resources and capabilities to build a knowledge-based economy
30

www.engineeringnews.co.za/article/reflections-on-gautengs-employment-growth-and-development-strategy-2010-06-04
2

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The GEGDS notes that building a green economy and environmental sustainability is central
to the strategy, which, usefully, draws on national economic policies and programmes, such
as the Department of Trade and Industry's new Industrial Policy Action Plan, and
complements these plans. The document states: "Gauteng needs an economy based on
green technologies, green jobs, green energy and green production processes that reduce
the ever higher input costs stemming from unsustainable resource use." In addition, the
GEGDS recognizes that past economic activity in the province had used non-renewable
resources in a wasteful and inefficient manner, with detrimental implications for the
environment in Gauteng and globally
The strategy also recognises that building a green economy will not only benefit future
generations, but will also have short-term economic gains for the Gauteng economy.
Promoting more-efficient use of resources through greater environment friendliness will not
only improve productivity and save money, but will also make our products more desirable
and competitive in global markets. Environmental sustainability has become a global
concern, and countries and products that are seen to be harmful to the planet will be
increasingly shunned (Mohammed in Engineering News, 2010)
In addition, the GEGDS proposes that the province should re-align the manufacturing sector
away from traditional heavy industry input markets and low value-added production
towards sophisticated, high value-added production such as information technology,
telecommunications equipment, research and development and bio-medical industries; and
the development of the finance and business service sector with specific emphasis on
financial services and technology, auxiliary business services and technology, corporate
head office location and business tourism (CTMM; 2011).

10.5 Gauteng Integrated Energy Strategy (2010)

The Gauteng Integrated Energy Strategy (GIES) was finalized in 2010. The Strategy is a
strategic response to structural weaknesses and gaps in the provinces energy sector, as
demonstrated by the extreme vulnerability of its massively urbanized economy and
population to the large-scale electricity outages and rapid fuel-price increases, as were
experienced in 2008, The GIES further recognizes that the national energy sector is
responsible for most of SAs greenhouse gases being emitted, and that and Gauteng, as the
economic hub of South Africa, is a key contributor to national emissions levels. The GIES
therefore explicitly includes a focus on the environment in its vision statement, namely a
province that promotes and implements sound energy decisions based on the principles of
equity, a healthy environment, investment promotion and prosperity for all (GPG; 2010b).
The main purpose of the GIES and implementation plan is to direct the way that energy is
supplied and used within the Gauteng province during the next 4 years (2014); 15 years
(2025); 45 years (2055) and beyond, in an integrated and comprehensive manner. The
strategy aims to improve Gautengs environment, reduce Gautengs contribution to climate
change, and tackle energy poverty, whilst at the same time promoting economic
development in the province. The GIES is intended a strategy that will require working with
existing initiatives, not in duplicating them, but taking them further (GPG; 2010b).

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The GIES states that, taking cognizance of the need to integrate the needs of energy security
and arresting and reversing climate change, Provincial Government is committed to:

moving the province to a low-carbon economy;


ensuring that the provinces carbon emissions peak, and start declining by 2030;
ensuring that there is an improvement in energy efficiency;
ensuring the scaling up of renewable energy options; and
Ensuring that energy access for the poor is a priority.

The GIES notes that existing national energy targets were set in a very different context, one
of low electricity prices, a fledgling carbon market and poor regulatory framework for
renewable energy. National government has since then put in place a process to create a
much more conducive environment for energy efficiency and for renewable energy. The
current situation therefore, demands even more stringent targets.

10.6 Tshwane Metro (Renewable) Energy Policy

The GIES also provides a useful overview of the energy/ climate change-related policies of
constituent Metros. Focus here is on the CTMM. In this regard, the GIES notes that the
CTMM has an official, Council-approved State of Energy Report, as well as an Energy and
Climate Change Strategy and Implementation Plan. The CTMM Strategy is based on four key
pillars, namely:

Sustainability: To enhance energy sustainability, accessibility and affordability to


residents and the municipality;
Cleaner, more efficient and diverse energy use and supply: To encourage and promote a
shift to cleaner (emitting less pollutants and greenhouse gases ), more efficient and
diverse energy use and supply;
Economic growth and development: To support economic growth and development in
CTMM, especially in the north, through smarter energy use; and
Innovation: To encourage the development and use of innovative tools, products and
solutions for energy use.

A number of targets are set in the CTMM Strategy, including:


10 CDM/carbon offset projects (to be identified by 2006 and implemented by 2010);
10% of CTMM electricity demand being met by local renewable sources by 2010
50% of eligible landfills producing electricity cost-effectively from methane by 2010
50% gas reticulation of middle-income areas by 201031.

31

As may be seen, most of the targets refer to 2010. It is unclear to which extent the relevant
targets have been met.
2

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Sustainable energy and climate change activities in CTMM are led and coordinated by the
Energy and Electricity department. The city has embarked on numerous demand side
management programmes. Plans for the extraction of energy from landfill sites are
ongoing. Plans are also afoot for the mass implementation of solar water heaters and
smart metering systems, and preparations are in progress for the citys Bus Rapid Transport
system (GPG; 2010b).

10.7 Draft National Waste Management Strategy (2010)

Section 6 (1) of the National Environmental Management: Waste Act (2008) requires the
development of a National Waste Management Strategy (NWMS). The purpose of the
NWMS is to give effect to the key objectives of the Act, including the provision of measures
to ensure that waste disposal activities are not harmful to people or the environment (as
per Section 24 of the Constitution).
Key goals and objectives of the NWMS include broad responsible disposal, especially the
recovery of recyclable / reusable resources and by the same token, diversion from landfill.
The NWMS is based on the waste hierarchy concept, as first outlined in the 1999 White
Paper on Integrated Pollution and Waste Management, which identifies waste avoidance
and reduction as the basal strategy, and disposal by landfilling as last resort (i.e. top of the
hierarchy pyramid). After avoidance, recovery, re-use and recycling comprise the second
level of the waste management hierarchy / strategy.
Five key goals are identified for the NWMS. Thermal treatment and energy recovery is
identified as one of the objectives in meeting Goal 3 (reducing, recycling and re-using waste)
and Goal 4 (treating and safely disposing of waste as a last resort).
Waste tyres
The NWMS identifies the tyre waste stream as particularly problematic, mainly as old tyres
are not compactable or degradable, and that some landfill sites have historically refused to
accept them, with others charging higher fees for allowing their disposal. As a result, illegal
dumping is a huge problem. In addition informal steel recovery is responsible for
uncontrolled toxic air emissions and unsightly tyre stockpiles which prevent other land uses.
In terms of implementing the waste hierarchy, the strategic focus is on diverting tyres from
landfill through recycling and the promotion of treatment and processing technologies. The
NWMS notes that while around 12 plants countrywide are currently producing recycled tyre
products, the supply of waste tyres exceeds the demand. The Strategy notes that energy
recovery holds potential (e.g. as feedstock in cement kilns).
The waste tyre regulations which came into effect on 30 June 2009 require all producers
and importers of tyres to submit an Industry Waste Management Plan (IndWMP), which
must indicate how the tyres are to be managed and how management will be financed once
the tyres become waste (NWMS; 2010: 94).

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Hazardous Medical
The NWMS notes that, in terms of the treatment and disposal of hazardous waste and
Health Care Risk Waste there is an urgent need for additional treatment capacity to be
developed by the private sector, especially bearing in mind the long term goal of phasing
out onsite disposal of this waste. Currently, the lack of capacity has led to an untenable
reliance on obsolete and unreliable facilities and is hampering efforts to divert waste from
landfill and support the recovery of energy (DEA; 2010: 39).
Energy Recovery and Pyrolysis
In terms of waste treatment and processing, the Department of Environmental Affairs (DEA)
supports the development of alternatives to landfill including incineration, gasification, and
pyrolysis in so far as they generate energy. Thermal treatment of waste must conform to air
emissions standards to mitigate the impact on health and the environment. While there are
cost implications of conformant incineration as a waste processing technology, this needs to
be considered in relation to the rising costs of disposal to landfill as full cost accounting is
implemented. It is anticipated that appropriate incineration, gasification and pyrolysis
facilities will increase over time and ultimately replace landfills as the primary disposal
mechanism for waste (NWMS; 2010: 40).
The NWMS envisages that national recovery targets and recycling norm and standards will
be developed progressively over the next 5 years. Public waste education is identified as a
key strategic objective in implementing the NWMS.

10.8 Gauteng Hazardous Waste Management Plan (2008)

Between 2007 and 2008 the Gauteng Department of Agriculture, Conservation and
Environment (GDACE) embarked on a project to develop an integrated hazardous waste
management plan for the province. The total production of hazardous waste in the province
was estimated at ~446 200 tons per annum (t/a), with treatment accounting for ~48 000 t/a
and disposal ~385 000 t/a. Key challenges and/or deficiencies with regard to waste
management in the province include the following:
The storage of hazardous waste and a need for the cleanup of contaminated land;
Insufficient capacity for hazardous waste treatment, especially thermal treatment
facilities, as an alternative to landfill;
A lack of alternative sites for hazardous waste disposal;
The need to explore alternative delivery mechanisms for hazardous waste facilities such
as public private partnerships
Nine targeted action plans were developed, and a list of Priority Waste Streams drawn up.
With regard to waste treatment and thermal treatment, the Plan does not mention
pyrolysis, but does indicate that the increased use of tyres and waste rubber in cement kilns
should be supported and brought into alignment with national policy (GPG; 2008).

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11 DESCRIPTION OF PROPERTY ON WHICH THE PROPOSED ACTIVITY IS TO BE


UNDERTAKEN

Building 3 Works Building

Buildings 1 and 2 Shed and Office Facility

Figure 11: Aerial photograph of the property comprising the site. Building 1 was historically related
to metallurgical processes and will house the CTWEF. Building 2 was historically used as general
stores and Offices and is planned to be converted into Office facilities for the CTWEF. Building 3
comprises some workshops and historically housed metallurgical processes. This building lies over
Portion 48 of the Farm Pretoria Town and Townlands 351 JR. The yellow line shows the boundary of
Portion 124 of the Farm Pretoria Town and Townlands 351 JR, which falls to the right of the yellow
line and includes Buildings 2 and 3 and the broader site.
11.1 Location and Size of Property

The subject property is located in the City of Pretoria, which is a city contained within the
City of Tshwane Metropolitan Municipality as one of several constituent former
administrations (among which also are Centurion and Soshanguve) and is situated
approximately 50 km north of Johannesburg in the north-east of South Africa, in a
transitional belt between the plateau of the Highveld to the south and the lower-lying
Bushveld to the north at an altitude of about 1350 m above sea level, in a warm, sheltered,
fertile valley, surrounded by the hills of the Magaliesberg range. It is one of the country's
three capital cities, serving as the executive (administrative) and de facto national capital.

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The subject site is an allotment of approximately 2.3 Hectares that forms part of Portion 124
of the Farm Pretoria Town and Townlands 351 JR, which is an approximately 500 hectare
heavy industrial site owned by Arcelor Mittal South Africa 32, previously known as Iscor33
(Iron and Steel Corporation of South Africa).

Figure 12: Cadastral illustration showing the cadastral boundary (in green) of Portion 124 of the
Farm Pretoria Town and Townlands 351 JR. The site or allotment as referred to above is
represented by a white circle with a red dot in the middle. . Illustration courtesy of Urban Dynamic
Gauteng.

GPS Location:
Southings: 25 46 11
Eastings: 28 07 40
Approximate Size of property:
The broader Arcelor Mittal Heavy Industrial Steel Mill site (Portion 124 of Farm
Pretoria Town and Townlands 351 JR) comprises approximately 500 Hectares of
land, all of which is completely transformed for heavy industrial purposes.
The specific allotment falls within Portion 124 mentioned above and comprises a
total area of approximately 23 694m2 or 2.3ha in total area.
The above property (allotment) will hereinafter be referred to as the Site.

11.2 Location of Activity on Proposed Property

The activity will be constrained to the site and will use the entire area on site, which will
include the broader allotment area and Buildings 1 and 2 identified above. The detailed
layout design will only be made available during the EIA Phase of the Environmental
Application process as this is subject to the findings of the Scoping Phase of the
Environmental Application process.

32

ArcelorMittal South Africa Limited is the largest steel producer on the African continent, with a production capacity of 7.8 million tonnes of liquid steel per annum.
Iscor, with its first works in Pretoria, was established as a state company in terms of the Iron and Steel Industry Act, No. 11 of 1928. The objectives of establishing the company were
to produce iron and a range of steel products, and to create employment opportunities. Production at the Pretoria plant started in 1934. And on 4 April 1934 the first steel was tapped
from the open-hearth furnace at the Pretoria Works.
33

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11.3 Site Access

Preliminary indications are that the site will be accessed from Staal road, which is located in
the existing and secure entrance to the Acelor Mittal Industrial Park, which is accessed off
Quagga Road (R55). The northern extension of Staal Rd, Transoranje Road (R55) provides a
direct link to the M4 Magaliesberg Freeway north of the site. A number of east-west roads
link Staal road to the M7 (Roger Dayson Road), and ultimately the M14.
The site is therefore strategically located in terms of both major rail and road access.
Please refer to Appendix A for a visual indication of the above description.

11.4 Current Land Use and Zoning


11.4.1 Current Land Use

The site is a decommissioned heavy industrial site which was historically used as part of the
Iscor operations and accommodated infrastructure relating to metallurgical processes. The
structure/site was rehabilitated and is currently vacant
11.4.2 Zoning

The following information relates to the issued Zoning Certificate of the City of Tshwane
Metropolitan Municipality; City Planning Department and is based on the provisions of the
Tshwane Town Planning Scheme (TTPS), 2008, as provided by the Professional Town Planner
for this Project (Urban Dynamics, May 2012).

Site: An allotment of Portion 124 of 351JR


Zoning: Industrial 1 (Use Zone 10)

Purposes for which buildings may be erected and used


Generally, in terms of Table B (Column 3) of the TTPS, erven/property zoned for Industrial 1
may be used for Industrial purposes, including light industrial, and for a cafeteria, car wash,
commercial use, Parking Garage and Parking site, but excluding noxious industrial processes
(see Consent section below).
Definition: Industry
Means land and buildings where a product or part of a product is manufactured, mounted,
processed, repaired, rebuilt or packed, including a power station and incinerator plant and
may include a cafeteria and a caretakers flat and any other activities connected to or
incidental to the activities mentioned herein, excluding noxious industries, light industries
and retail industries.
Definition: Noxious Industry
Means land and buildings used for any use included in the list in Schedule 8 of the TTPS
together with any living accommodation required for a caretaker and includes any other use
on the same site, which is necessary in connection with the primary use.

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Purposes for which buildings may be erected and used only with consent of Council
Generally, in terms of Table B (Column 4) of the TTPS, erven/property zoned for Industrial 1
may be used for Noxious Industrial purposes (see definition below), in terms of the
provisions of Clause 14 (6)(d)(ii) or for uses not listed above. The latter mentioned clause
states that the erection and use of buildings for noxious industries in Use Zone 10,
Industrial 1, may be allowed if , upon the production of a certificate issued by the
Municipalitys Health Officer in consultation with the Inspector of Factories, declaring that
the process it is proposed to employ in the conduct of any of the industries listed in Schedule
8 will eliminate nuisance or danger to health on neighbouring properties arising from waste
matter, effluvia, vapour, smoke or smell, on condition that if land treatment of such matters
is proposed, the nature, slope and area of the land relative to dwellings, streams or water
courses shall be satisfactory.
Temporary Uses
Temporary Uses may be permitted in terms of Clause 14(8) of the of the TTPS, stating that,
notwithstanding any contrary stipulation contained in this Scheme, the Municipality may
grant permission for the temporary use of any building or land within any use zone for any
of the erection and use of temporary buildings or the use of existing buildings or sites for
site offices, storage rooms, workshops or such other uses that are in the opinion of the
Municipality necessary for the erection of any permanent building or structure on the land
or the installation of engineering services shall be to the satisfaction of the Municipality:
Provided that such permission shall lapse, ipso facto, on completion of the permanent
building or structure or the completion of the engineering contract.
Height
A building height of 18m, measured vertically from the natural ground level to the highest
point of the building, applies within the Industrial 1 land use zone. In an "Industrial 2" zone
the Municipality may grant permission to an increase in height in respect of any building,
which requires additional height for a manufacturing process or storage purposes, but
should the Subject buildings exceed such height restriction, consent must be requested. The
height of the buildings and any modifications on the subject site should be confirmed, and if
exceeding 18m in height the local authority must confirm whether consent will be granted
to increase the height parameters within the Industrial 1 zoning.
Floor Area Ratio (FAR)34
A FAR of 3 applies to the property. The land owner will need to confirm the current
coverage.
Coverage
Buildings (footprint) may cover the property are up to 75%. The land owner will need to
confirm the current coverage.

34

Floor area ratio (FAR), floor space ratio (FSR), floor space index (FSI), site ratio and plot ratio are all terms for the ratio of a building's total floor area to the size of the parcel of land
upon which it is built. The terms can also refer to limits imposed on such a ratio. As a formula: Floor area ratio = (Total covered area on all floors of all buildings on a certain plot)/(Area
of the plot). Thus, an FSI of 2.0 would indicate that the total floor area of a building is two times the gross area of the plot on which it is constructed, as would be found in a multiplestory building. Floor area ratios are used as a measure of the intensity of the site being developed. The ratio is generated by dividing the building area by the parcel area, being sure to
use the same units.

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Building Lines
The property is subject to a 4.5m building restriction area along any street boundary. The
subject site is not adjoining any public road/street. Clause 12 of the TTPS and Schedule 1
(p58 of the TTPS) also applies.
Consent Uses
The CTMM Zoning Certificate confirms that no consent to use the property for uses other
than specified above has been granted. Nonetheless they state that: Please note that the
validity of the Consent Use cannot be verified as the rights may have elapsed in terms of the
conditions of the Consent use approval. The validity will have to be proven by the owner of
the property.
General Conditions
An extract of the Tshwane Town Planning Scheme, 2008, is included as Annexure I of the
Town Planning Report, which relates to conditions applicable to all erven. The above zoning
information must be read in conjunction with the relevant Annexure T (of the TTPS), if any,
and the rest of the Clauses of the Tshwane Town-Planning Scheme, 2008. The CTMM
confirmed (pers comm. Lynette Groenewald of Urban Dynamic, May 2012) that no
Annexure is linked to the property.

11.5 Strategic Planning Context


11.5.1 Guiding Principles of the Development Facilitation Act

The guiding principles of the Development Facilitation Act (Act 67 of 1995), being the most
significant Act defining principles to guide planning and development, include the following
strategic land development objectives:

Promote the integration of social, economic, institutional and physical


aspects of land development;

Promote the availability of residential and employment opportunities in close


proximity to/or integrated with each other;

Optimise the use of existing resources relating to agriculture, land, minerals,


bulk infrastructure, roads, transportation and social facilities;

Promote a diverse combination of land uses, also at the level of individual


Erven or subdivisions of land;

Discourage the phenomenon of urban sprawl in urban areas and contribute


to the development of more compact towns and cities;

Encourage environmentally sustainable land development practices and


processes.

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On a local level, the guiding principles may be interpreted to support the more optimal use of the
subject property, not only from a land and services efficiency perspective, but also to support the
provision of economic/work opportunities close to high density residential use, albeit in an
environmentally responsible manner. Such infill/re-development will counteract urban
degeneration and decentralization.

Based on the Professional Town Planning Report (Urban Dynamic Gauteng, May 2012), the
following is noted:
The provincial and land use policy support the use of the properties for industrial purposes.
The City of Tshwane Metropolitan Municipality regards the re-development of the ISCOR
industrial area and the utilization of unused industrial space as a priority as per their
strategic policy documentation. Council also wishes to attract private investment. The
proposed utilization of existing industrial infrastructure also addresses city
revitalization/regeneration and job-creation objectives.
The zoning of Portion 124 of 351JR, which accommodates Buildings 1 and 2, has been
established as Industrial 1 (light industry). The previous use was for heavy/noxious
industry, albeit state run. The requirement to submit a consent application will be
determined by the interpretation of the nature (noxious or nor) of the processes to be
incorporated in the proposed use.
With respect to Portion 48 of 351JR, which accommodates Building 3, clarity must be
obtained from the local authority re the exact zoning and a rectification on their system
should be investigated. Should the ZAR/Rail zoning remain and the client still wish to utilize
the building for offices, a consent application will be submitted.
In summary, the proposed principle use, industrial, is allowed on the majority of the project
site (buildings 1&2) via the existing zoning and offices can be included as a use on Portion 48
via a consent application. The proposed use does not differ, in principle from previous use
(heavy industry and office) and is compatible with adjacent use/zoning.
Information received indicates that the traffic impact and engineering services requirement
of the proposed use will be less than the previous site demand.
Based on initial information, the proposed use should be supported, but regularation
(consent) application may apply given the position of the buildings on the properties and the
possible noxious nature of processes used

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11.5.2 The Integrated Development Plan (IDP)

The IDP is seen as the single, inclusive and strategic document that outlines and
incorporates all organisational and developmental needs and activities in in a Municipality.
It serves as the overarching planning and policy instrument that guides and informs all
decisions regarding planning, management and development within the Municipality and
pertains to all activities performed by the various role players. It binds a municipality in the
execution of its executive authority, but simultaneously provides communities with a sense
of coordinated and cooperative goals, objectives and targets.
The Tshwane IDP was approved by Council in 2011, and covers the period 2011-2016. The
section below focuses on aspects of relevance to the Project Proposal.
In this regard the 2011-2016 is explicitly aligned with key national and Gauteng policy
documents, including:

National: the New Development Plan (2011), the (Lekgotla) Outcomes Approach (2010),
the national MTSF 2009-2014, National Key Performance Indicators (KPAs), the 2005
National Growth and Development Perspective (NGDP) and AsgiSA (Accelerated Growth
and Development in South Africa);
Provincial: the Gauteng MTSF 2009-2014, the GEGDS (2010) and the Gauteng Spatial
Development Framework (2010).

The outline below provides a brief overview of the key strategic objectives identified for the
CTMM for the 2011-2016 period, and specifically those three (out of 7) which may be of
relevance to the CEO2 proposal.
These include:

(2) Economic Growth and Development and Employment Creation (see discussion of
GEGDS above);
(3) Sustainable Communities with clean, healthy and safe environments and integrated
social services (see discussion of GEGDS and GIES above).

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The City of Tshwane IDP 2011 to 2016 describes Region 3 as follows:


General Information
Extent: 376km
Estimated Population size: 514 195
Wards:
1, 3, 7, 42, 51, 52, 53, 54, 55, 56, 58, 59, 60, 62, 63, 68,
71, 72, 80, 81, 82, 84, 92
Settlements:
Eastlynne, Weavind Park, Kilner Park, Lindo Park,
Waverley, Moregloed, Rietfontein, Wonderboom South,
Gezina, Villeria, Hatfield, Colbyn, Riviera, Rietondale,
Arcadia,
Sunnyside,
Muckleneuk,
Groenkloof,
Waterkloof, Monument park, Menlo Park, Ashleigh
Gardens, Waterkloof Heights, Mayville, Mountain View,
Hermanstad, Pretoria Gardens, Capital Park, Salvokop,
Danville, Atteridgeville, Saulsville, Pretoria Industrial,
Kwaggasrand, Elandspoort, West park, Lotus Gardens
Features:
Groenkloof Nature reserve, Retail and shopping
facilities such as Brooklyn mall, Government offices,
Union Buildings, Diplomatic corps (embassies etc., Fort
West village, SABS, University of Pretoria, UNISA,
Tshwane university of Technology

Figure 13: City of Tshwane IDP Region 3


Illustration.

Source IDP 2011-2016 and Urban Dynamics


Town Planning Scoping Report (May 2012)

In the situational analysis of the CoT IDP it is stated that the CoT space economy has been
for a long time propelled by the heavy industrial development in the areas of manufacturing.
However, the Gauteng Employment, Growth and Development Strategy (GEGDS) indicated
that the province should re-align the manufacturing sector away from traditional heavy
industry input markets and low value-added production towards sophisticated, high valueadded production such as information technology, telecommunications equipment, research
and development and bio-medical industries; and the development of the finance and
business service sector with specific emphasis on financial services and technology, auxiliary
business services and technology, corporate head office location and business tourism.

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The following table (IDP extract) indicate the outcome issues, which are a summary of the
new growth path, governments program of action, outcomes approach and turnaround
strategy:
Table 49: Summary of outcome issues for
CoT Outcome issues

Impact areas

CoT Implications

Speeding up growth and transforming the


economy to create decent work and
sustainable livelihoods.
Massive programme to build economic
and social infrastructure.
Decent employment through inclusive
economic growth.
An efficient, competitive and responsive
economic infrastructure network.
Implementation of the Community Work
Programme
Substantial
public
investment
in
infrastructure both to create employment
directly, in construction, operation and
maintenance as well as the production of
inputs, and indirectly by improving
efficiency across the economy.
Targeting
more
labour-absorbing
activities across the main economic
sectors the agricultural and mining
value chains, manufacturing and services.
Taking advantage of new opportunities in
the knowledge and green economies.

Economic activity areas, Regional


corridors
including
Capital
Core,
Metropolitan level nodes and industrial
areas

The City cannot function without adequate


infrastructure and services that is well
planned and maintained.
CoT must succeed in increasing the level
of economic activity in its regions and
thereby create sustainable growth and
job creation opportunities resulting in a
more prosperous community that can
participate in a more equitable sharing
economy.
Integral in this process will be the
development of holistic aggressive
programmes aimed at sustainable job
creation to achieve the national target of
halving poverty levels by 2014 and
community empowerment strategies.
Bulk infrastructure projects should be
evaluated in terms of their contribution to
the development and growth of the
various development typologies in the city
e.g. economic areas as discussed,
residential areas etc.
All major economic activity areas should
be serviced by a regular and reliable public
transport mode.

This includes areas where business,


industrial, and commercial and retail
activities are present. The function at both
a regional and local level, in the context of
differentiated locations and at different
stages
of
development.
The
developmental
requirements
(infrastructure, maintenance etc.) will
therefore differ - resulting in different
interventions that are needed.
The development of the provincially
indicated (GSDF) development corridors
should be investigated further.

Table 5: Illustration of the IDP CoT outcomes

The IDP incorporates existing economic activity areas, including industrial areas, as a focus
area for a spatial capital investment strategy, to develop economic networks and
infrastructure that can provide inclusive growth and job creation. To address this strategic
objective (economic growth and development and job creation), the CTMM conducted an
Industrial Land Audit. The audit revealed that most of the industrial sites/estate in all the
regions of CoT was not fully developed due to infrastructure capacities. The City Planning
Department will launch the second phase of the project in 2011/12 to unlock the
investment potential of these estates. This will then be translated into the Capital items
required for further public investment.
In this regard the proposed development should be assessed in terms of its economic
viability, not only for the site, but for the broader community, in addition to assessing
environmental and social viability in terms of the above. The above should all be factored in
planning and decision-making in order to promote the notion of sustainable development.
In this regard, it is required that the proposed development is assessed against the
requirements of the Municipal Integrated Development Plan (IDP) and the Municipal Spatial
Development Framework (SDF).
The above will be further assessed in the EIA Phase.
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11.5.3 The Spatial Development Framework (SDF)

The SDF, broadly, lays down bioregional planning principals for the spatial development of
the region, which the municipalities and other relevant role players as well as local
developers have to adhere to. Local Municipalities are expected to refine the spatial
delimitation of the core areas, buffer zones, agricultural and urban areas and develop placespecific design guidelines for areas under their jurisdiction. In terms of the Municipal
Systems Act, the specific purpose of the SDF is to facilitate efficient land use management
and sustainable development of the applicable area.
A Spatial Development Framework (SDF) is a sectorial plan, which has to be formulated as a
core component of the IDP and it must:

Give effect to the Chapter 1 Principles of the Development Facilitation Act


(Act 67 of 1995);
Set out objectives that reflect the desired spatial form of the city;
Contain strategies and policies regarding the manner in which the above
objective especially with regard to desirable land-use patterns, spatial
reconstruction of the city and the location and nature of development within
the municipality) will be achieved;
Set out the Capital Investment Framework for the municipalitys
development programs;
Contain a strategic assessment of the environmental impact of the SDF;
Identify programmes and projects for the development of land;
Provide visual representation of the desired spatial form of the city,
indicating the following:

Where public and private development and infrastructure investment should take
place;
Desired or undesired utilisation of space in particular areas;
Urban edge;
Areas where strategic intervention is required;
Areas where priority spending is required ; and
Alignment with the spatial development frameworks of neighbouring municipalities.
The following levels of SDFs guide development in the Tshwane Central Western Region
(Region 3), of which the subject property forms part:
Draft Municipal Spatial Development Framework, 2012
The MSDF aims to address the following towards the achievement of the City vision:
Addressing social need;
Restructuring of a spatially inefficient City;
Promotion of sustainable use of land resources;
Strategic direction around infrastructure provision;
Creating opportunities for both rural and urban areas;
Guiding developers and investors as to appropriate investment localities...

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Region 3 is described as . the largest job opportunity zone in the CoT. The region is
generally well provided for in terms of service infrastructure.. Nonetheless, future
development may be subjected to future bulk infrastructure limitations. The large tracts of
land owned by government, especially the Defense Forces, have also had a significant
influence on the development patterns of the city, mostly by acting as buffers and restricting
spatial integration. Much of this land is under-utilized and is located strategically for infill
development or economic opportunities and can contribute significantly to the spatial
restructuring of the city if released for development.
Tshwane as a whole forms part of the Tshwane - Johannesburg - Ekurhuleni conurbation
and lies north of Johannesburg and Ekurhuleni. This conurbation is growing into one of the
major urban regions in the world. This vast conurbation forms the economic powerhouse of
South Africa and indeed of Africa. In terms of the Gauteng Spatial Development Framework
(GSDF) the Provincial Economic Core is anchored by Rosslyn to the north (Tshwane) and is
linked to the Johannesburg International Airport to the east (Ekurhuleni) via the N1/R21 and
the Central Business District of Johannesburg to the south via the N1/M1 highway. This
emerging Gauteng Urban Region and its strategic prominence is a very strong force that will
shape Tshwanes future not only spatially, but also economically and institutionally over the
next decade.
The subject area thus forms part of the metropolitan focus area for infill development,
better utilization of infrastructure and economic development and on a regional basis, the
site is part of the Tshwane node, which is the starting point of a Primary development axis
(including industrial use) which links to the east rand area and Johannesburg.
From a regional/metropolitan policy perspective, the continued industrial/commercial use
of the area, as part of the Tshwane node is acknowledged.
The Vision of the City of Tshwane is to become The African Capital City of Excellence. Seven
strategic objectives have been identified in order to respond to the vision, including
Economic Growth and Development and Job Creation and supporting sustainable
communities with clean healthy and safe environment. Over the next 5 years, the Citys
performance in these areas, amongst others, must improve and will be reflected in the input
and outcome indicators of the 2011-2016 IDP.
The MSDF responds primarily to:
Strategic Objective 2 (Economic growth and development):
Provide strategic direction around infrastructure provision
Guide developers and investors as to appropriate investment
localities

Strategic Objective 3 (sustainable communities with clean healthy and safe


environment and integrated social services). :
Restructure the spatially inefficient City through compaction,
densification and TOD
Promote sustainable use of land resources
Growth management

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The more effective utilization of the area, already identified for industrial purposes, speaks
to the abovementioned objectives. The City of Tshwane has also embarked on Industrial
Land Audits in order to regularize use and support more effective and responsible use of
industrial land.
The Region 3 (Central Western Regional) Spatial Development Framework 2012
The Region 3 RSDF is the most direct, applicable policy document, relating to the land use of
the subject properties. The situational analysis of the Region 3 RSDF points to the good
industrial infrastructure including ISCOR, Pretoria Industrial and the restricted industrial
node along Mitchell/Soutter Streets as one of the strengths of the area. Hence the
following Opportunity was identified as a Key Issue in the SWOT analysis of the area:
The re-generation of ISCOR or utilisation of the infrastructure is a development opportunity
for the area.
The intended re-development project will address one of the weaknesses noted in the
Region 3 analysis, being the closing of ISCOR which has led to a general decline in the
western areas and There is a lack of private sector investment in the west.
The RSDF further reiterates that the main economic opportunities of the region are
located in Pretoria Industrial, Carl Street, Mitchell Street and Soutter Street presently
accommodating 46 000 job opportunities. Despite this number of jobs, there is large scale
poverty and unemployment. A concerted effort should be launched to attract investment to
the western part of the region especially the re- generation of ISCOR to stimulate the
creation of job opportunities
The RSDF also highlights the following, in support of development on the subject properties:
Both Quagga Road and Roger Dyason/Eeufees (M7) Road are earmarked as Mobility
Spines, which serves the purpose of inter-regional and metropolitan movement.
These roads link to the N14 and N4;
The Region C Open Space and Environmental sensitivity plan show minor
points/aspects of environmental sensitivity affecting the site, although a
green/protected area is indicated south of the properties (not adjacent to the
subject site. The Environmental Impact of the proposed use (specific processes) on
the existing environment will be gauged through an impact study;
The properties form part of the urban core and are well within the urban edge;
The properties are well served with public transport, with taxi routes, rail passenger
lines and a modal transfer station within walking distance. The second Phase BRT
rout also passes by the area.
The Professional Town Planner has concluded by stating that there is no doubt that
Industrial development on the subject properties is supported by the existing land use
policies of the Tshwane Metropolitan Municipality. The support of the administration to
include specific processes will be determined by the classification of such processes/uses and
the results of the EIA.
The above will be further assessed in the EIA Phase.
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12 DESCRIPTION OF THE RECEIVING ENVIRONMENT THAT MAY BE IMPACTED BY


THE PROPOSED ACTIVITY

Figure 14: Regional map showing the approximate site boundary (in yellow highlight and red outline). This
illustration highlights key landuse features surrounding the site.

12.1 Land Use Character of the Area Surrounding the Site


12.1.1 The Site

North:
To the north of the site lies the remainder of the Arcelor Mittal Industrial Site, beyond which
lies a railroad servicing the Industrial Site, beyond which lies Staal Road, beyond which lies
more industrial type facilities, beyond which lies Bessemer Road, beyond which lies
additional industrial type activities, beyond which lies the M22 (Quagga Road), beyond
which lies the residential suburb of West Park and Quaggasrand, which is approximately
1km in distance from the proposed CTWEF.

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East:
To the east of the site lies an adjacent heavy industrial landuse, beyond which lies the edge
of the Arcelor Mittal Industrial Site, beyond which lies the M7 (Roger Dyason), beyond
which lies a commercial suburb which lies approximately 1.8km to the east of the proposed
CTWEF.
South:
To the south of the site lies a reinforced concrete embankment, which cuts into a slope,
beyond which lies the rail line which services the Arcelor Mittal Industrial Park, beyond
which lies a Eskom substation, beyond which lies a tarmac road used for internal reticulation
within the Industrial Park, beyond which lies a gas works, beyond which lies a hillside that is,
according to the landowner, an old dumpsite that has been capped and rehabilitated,
beyond which lies Hendrik Potgieter road, beyond which lies Pierre van Ryneveld road,
which lies approximately 1.6km from the proposed CTWEF.
West:
To the east lies Staal Road, which forms part of the broader Heavy Industrial Site, beyond
which lie more heavy industrial type facilities, beyond which lies the R55 (Quagga Road),
beyond which lies the residential suburbs of Kalfong and Atteridgeville, which lies
approximately 4.8km and 4km respectively from the proposed CTWEF.
Please refer to Appendix A for a detailed overview of the surrounding areas.

12.2 Surface Slope and Elevations of the Site

Information relating to surface slope and elevation is based on the findings of the site visit
and reference to elevation information readily available from Google Earth.
The site, broadly, consists of a levelled area with a very gentle inclination (slope) rising
across the site from the extent of the north western boundary through to the south eastern
extent of the site, which forms a boundary wall/reinforced embankment cutting into the
slope angle, above which runs a tarmac road and railroad.
Elevations on site range from a high point of approximately 1365 metres above mean sea
level (mamsl) near the north west boundary of the site (existing warehouse) to
approximately 1400 mams near the south eastern reinforced embankment. The slope
stretches over approximately 100m in distance (from north west to south east) and a 5m
elevation difference over this area.

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Photo 19: Illustration of


slope of site, looking across
the site from the north
west corner up towards
the south east corner,
showing the concrete
reinforced embankment,
beyond which lies the
Eskom
substation,
overhead (132kv) power
lines and various heavy
industrial facilities (note
gas flaring in background).

Please
refer
to
Appendix
A
for
detailed illustrations.

12.3 Geology

According to Pretoria State of the Environment Report (SoE) 35, the most dominant
geological formations of the Pretoria area are Pretoria Group Andesite and Bushveld
Gabbro-Norite, Pretoria Group Shale and Pretoria Group Quartzite. Most of the valuable
east-west quartzite ridges (including the Magalies Mountain Range, which is a Protected
Natural Environment) of the Tshwane Metropolitan Municipality occur within the Pretoria
area.
The site visit revealed extensive hardened and gravelled areas with prominent subterranean
concrete reinforced foundation structures, which according to historical aerial photography
interrogation, suggests that the structures may have formed part of a historical warehouse
that was located on the southern portion of the property. The existing warehouse
12.4 Sensitive Natural Features

There were no sensitive natural features noted on site or around the site. It is important to
highlight that the site and adjacent areas formed part of a heavy industrial zone that has
been in operation for almost 10 decades (almost 100 years) and so it is considered highly
unlikely that any natural sensitive features would be present.

12.4.1 Groundcover

The site has been extensively transformed and utilised for heavy industrial operations over a
period of many years as part of the broader Arcelor Mittal Heavy Industrial Site (previously
Iscor Steel Mill). As such, there is no natural groundcover to speak of and the site is
effectively underlain by hardened gravel and reinforced concrete foundations used to
support heavy duty operations on the site.

35

The City state of the Environment on Internet project (CsoEI) is part of South Africa's Local Agenda 21 Program. A sustainabl e local environmental policy requires knowledge and easily
accessible environmental information for administrators, decision makers and citizens. The CsoEI project will facilitate the electronic dissemination of information on the current state of
the environment in South Africa's cities, human induced environmental impacts and management responses geared towards achievi ng greater sustainability. The South African pilot
cities involved in the City state of Environment Program are Johannesburg, Pretoria, Durban and Cape Town

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12.4.2 Hydrology (i.e. surface water and natural drainage features)

There were no natural drainage channels noted on site and all stormwater as well as
rainwater captured via gutters on the extensive roofed area of the existing warehouse
appears to be channelled into industrial scale stormwater facilities into the larger
stormwater reticulation network of the Arcelor Mittal Heavy Industrial Site.

12.4.3 Sensitive Man-Made Features in the Immediately Adjacent Landscape

The immediately adjacent landscape, up to a distance of approximately 750m in a westerly


and northerly direction, 1.4km in an easterly direction and 500m in a southerly direction,
comprises heavy industry type activities, which form part of the broader heavy industrial
site. There are therefore no sensitive man-made features located within these zones.
The closest man-made feature to the site that would be considered sensitive are the water
reservoirs located atop the nearby hillside which is located above the southern portion of
the industrial park, which is located approximately 550m to the south east of the proposed
CTWEF.

12.4.4 Residential areas

It is important to contextually highlight that the following general Residential areas have
been identified as surrounding the Arcelor Mittal Heavy Industrial Park and which include:
1) Proclamation Hill (North east) approximately 1.4km.
2) Danville (North North West) approximately 2.5km.
3) Elandspoort (North west) approximately 2.7km.
4) West Park (North) approximately 1km.
5) Kwaggasrand (North West) approximately 1.1km.
6) Pretoria West (North East) approximately 2.5km.
7) Laudium (South West) approximately 1.8km.
8) Pretoria Central (East North East) approximately 5km.
9) Thaba Tshwane (South East) approximately 2.8 km.
10) Valhalla (South East) approximately 3.5km.
11) Lotus Gardens (West North West) approximately 4km.
12) Kalafong (West South West) approximately 4.85km.
13) Atteridgeville (West) approximately 4km

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The following extract from the Social Scoping Assessment Report (Barbour, January 2012) is
noted:
In the context of the sites location within a broader, (heavy, noxious) industrial area,
significant direct impacts on immediately adjacent land (all sides) are unlikely. In this regard,
it should be noted that the Iscor (Arcelor/ Mittal) parent site has been in operation since
Iscors Pretoria plant first started operations in 1934 36. The blue collar communities towards
the north and north-east have traditionally benefited from employment opportunities
associated with the Industrial area. However, as noted in the 2010 Local Integrated Spatial
Development Framework for Attridgeville, Lotus Park and Surrounds, the area west of
Pretoria CBD towards Attridgeville and beyond is under immense development pressure,
mainly residential (CTMM; 2010 37).
Cumulative impacts on near-adjacent and proximate communities are potentially a source of
concern. In this regard, Wespark, Kwaggasrand and Proclamation Hill are all located 1-1.5
km from the site. High density residential land use in Laudium is located ~1.7 km south-west
of the site. The suburbs of Kwaggasrand, Wespark and Laudium were specifically identified
as key potential receptors during a recent meeting held between the CoTMM and the
proponent with regard to the proposed development

13 SOCIO-ECONOMIC CONTEXT

This section provides a scoping overview of the socio-economic findings and context of the
receiving environment as well as the anticipated socio-economic considerations of the
proposed activity. The following information has been extracted and adapted from the
Social Scoping Assessment Report (Barbour, January 2012) for this Project.
13.1 Socio-Economic Baseline Findings

Legislation and policies reflect societal norms and values. The legislative and policy context
therefore plays an important role in identifying and assessing the potential social impacts
associated with a proposed development. In this regard a key component of the SIA process
is to assess the proposed development in terms of its fit with key planning and policy
documents. Should the findings of the study therefore indicate that the proposed
development in its current format does not conform to the spatial principles and guidelines
contained in the relevant legislation and planning documents, and there are no significant or
unique opportunities created by the development, the development cannot be supported.

The broad findings of the Baseline Report indicate:


The identification of key social issues that need to be assessed during the EIA includes:
The policy and planning related issues;
National and regional issues
Local, site-specific issues.

36
37

This was Iscors premier plant until the Vanderbijlpark Works were commissioned in 1952 in the Vaal Triangle area.
Final Draft document was published in 2008, and approved by Council in 2010.

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Policy and planning issues


The findings of the review indicate that the disposal of old tyres has been identified as a key
issue. In terms of implementing the waste hierarchy, the strategic focus is on diverting tyres
from landfill through recycling and the promotion of treatment and processing technologies.
The proposed project is therefore supported by and supports the National Waste
Management Strategy (NWMS).
At a local, site-specific level the findings of the review indicate that the site is located in an
existing industrial area that is zoned Industrial 1. The proposed development is therefore
compatible with the current zoning for the site.
National and regional issues
South Africa produces approximately 10 million waste tyres per annum and there are in the
region of 60 to 100 million waste tyres in circulation that need to be disposed of. Finding an
environmentally suitable option for disposing of waste tyres therefore represents a key
social concern.
The proposed project will therefore provide an environmentally suitable approach for
recycling tyres and for disposing for other waste streams. The proposed development and
the associated technology will therefore have a social benefit at both a national and regional
level. This benefit is likely to be significant given the number of old tyres generated in South
Africa per annum (10 million) and the scale of the backlog (60 to 100 million).
Site specific issues
Construction phase
Based on the information provided, the potential negative social impacts associated with
the construction phase are likely to be negligible. The potential positive impacts include:

Creation of opportunities for local employment during the construction phase;


Creation of opportunities for local and regional Small Medium and Micro Enterprises
(SMMEs) and other businesses during the construction phase;
Creation of the opportunities for skills development and training.

Operational Phase
Based on the information provided, the potential negative social impacts associated with
the operational phase are likely to be negligible. In addition, the proposed site is located in
an existing industrial area that is zoned Industrial 1. The potential positive impacts are
largely linked to the broader social benefits associated with providing an environmentally
suitable solution for recycling old tyres and the associated by-products (clean, renewable
energy and biofuel).
In addition the operational phase will:
Create opportunities for local employment;
Create opportunities for training and skills development;
Create opportunities to local business and the local economy;
Create opportunities for further research and development.

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At this stage in the process there has been no interaction by the SIA consultants with
communities and other affected parties that live in the area. Detailed consultation will be
undertaken during the assessment stage of the SIA.

13.2 Socio-Economic Context

The CoTMM is located in the north-western quadrant of the Gauteng Province, which is
approximately 50 km north of Johannesburg and forms part of the Gauteng metropolitan
area (Tshwane / Johannesburg / Ekurhuleni), which has grown into South Africas largest
urban area. The area represents the economic powerhouse of South Africa and indeed of
Africa. As the administrative capital of the Republic of South Africa, the city is dominated by
government services and the diplomatic corps of foreign representatives in South Africa.
Gautengs population was estimated at approximately 10.5 million (2007 StatsSA
Community Survey), up from approximately 8.8million in 2001 (Census 2001), and
accounted for nearly 22% of the national population (on approximately 1.4% of the national
territory). Gauteng is the most urbanized (97%) and also the fastest growing province in
South Africa. Gauteng experienced a population growth of over 20% between 1996 and
2001, and by 2007 was the most populous province (KwaZulu Natal ranking a close second,
at approximately 10.2 million) (www.en.wikipedia.org/wiki/Gauteng).
According to the 2011/ 2016 CoTMM IDP, the current population is ~ 2.5 million. The
CoTMM is characterised by a rapidly growing population (projected annual growth of 4.1%),
a situation which is exacerbated by immigration, which, by 2011, had resulted
approximately 26.8% of all CoTMM households residing in informal housing. The highest
density of people in the CoTMM live in the previously disadvantaged areas, such as
Atteridgeville, Mamelodi, Olievenhoutbosch, Soshanguve, and Garankuwa (CoTMM; 2011).
According to the 2007 StatsSA Household Survey an estimated 73% of the population was
Black African, followed by White (~23 %). Statistically, the Black African component has in all
likelihood increased significantly with the amalgamation of the 3 LMs.
Information contained in the IDP indicates a total estimated population of ~514 000 for the
Central/ Western Planning Region of the CoTMM (CoTMM; 2011). The findings of the 2008
CoTMM Household Survey indicated that the Regions population had decreased slightly, by
-4.7% in the period 2001-2008. The CWPRs population was largely comprised of Black
Africans (approximately 75%) and Whites (approximately 23.5%). The Ward 3 population
was estimated at ~28 778, that of Laudium (Ward 51) ~19 141, and Attridgeville (Ward 62)
21 754 people (CoTMM; 2008).

Information contained in the2010 Local Integrated Spatial Development Framework for


Attridgeville, Lotus Park and Surrounds, indicates an estimated 2005 population of
approximately 43 000 for the Attridgeville formal community and an additional
approximately 63 000 for the Attridgeville informal community. The SDF further indicated
2005 population estimates of approximately 10 000 for Kwaggasrand/ Wespark (unclear
whether Proclamation Hill counted in), and ~15 000 for Danville/ Elandspoort (CTMM;
2010).
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Employment levels
Out of an estimated approximately 1.7 million people aged between 15-64 years, ~980 000
were considered as economically active in 2008. Unemployment in Tshwane was estimated
at 19.8%. Unemployment levels are spread unevenly across the CoTMM, with the North
Western and North Eastern regions having unemployment rates of approximately 43.5%
and approximately 31.4% respectively, whilst the Eastern and Southern regions have very
low unemployment rates. The CWPRs estimated unemployment level was ~13.4%,
somewhat lower than the Tshwane Metro average (19.8%) (CoTMM; 2008).
According to the Household Survey, across all Tshwane Regions, the majority of employed
individuals are paid employees, followed by self-employed persons. The number of selfemployed individuals is just below 10% in all regions with the exception of the Southern
region accounting for 11.9% self-employed persons. The remaining categories of paid family
worker, employer and unpaid family worker accounted for 3% of employees (CoTMM;
2008).
According to Census 2001, an estimated 48% of the Attridgeville economically active
population was unemployed, and approximately 14% of that of the Kwaggasrand area. Only
about 50% of the population of economically active age in the Attridgeville-Pretoria West
area was economically active. Unemployment in the general area is identified as
exceptionally high in the 2010 Local Integrated Attridgeville and Surrounds SDF (CTMM;
2010).
Income levels
According to the 2008 Household Survey, half (50%) of adults in the CoTMM had no formal
source of income. The CWPR total was slightly less (49.3%). At least some (perhaps 20%)
may however be students. Of the earning fraction of the CoTMM population, approximately
17% earned R1100 or less per month. For the CWPR, the corresponding income clustering
was in the R2 100-R12 8000 bracket (approximately 18%) (CoTMM; 2008). Within the
CoTMM spatial economy, the Southern and Eastern Regions have the highest income levels.
The lowest income levels are mainly associated with the newly amalgamated LM areas
which are located in the north-west and north-east of the CoTMM.
Information contained in the 2010 Local Integrated Spatial Development Framework for
Attridgeville, Lotus Park and Surrounds indicates average annual incomes of ~R18 000 for
Attridgeville Informal; approximately R43 000 for Attridgeville, and approximately R119 000
for Wespark/ Kwaggasrand. In comparison, the Tshwane MM average was approximately
R92 000 (CTMM; 2010).

The description following is largely derived from the 2011-2016 Tshwane Metro IDP and a
regional
(Gauteng)
profile
on
Brand
South
Africas
website
www.southafrica.info/about/geography/gauteng.htm.

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Gauteng
The Gauteng (Sesotho for "place of gold") economy is traditionally heavily reliant on the
mining sector. Gold was discovered on the Witwatersrand in 1886 (40% of the world's
current reserves, mostly located as deep-level ore). The Witwatersrand region essentially
coincides with what today is Johannesburg, the provincial capital, located to the south of
Tshwane (the distance between the Pretoria and Johannesburg CBSs is approximately 50
km). Since its inception, Johannesburg has been the regional economic powerhouse while
Pretoria has been the administrative centre.
While mining remains important, the Gauteng economy has since diversified, with more
sophisticated sectors, such as finance and manufacturing, playing an ever increasing role.
Manufacturing includes basic iron and steel, fabricated and metal products, food,
machinery, electrical machinery, appliances and electrical supplies, vehicle parts and
accessories, and chemical products (Gauteng Profile on Brand South Africa website). The
provinces core economic area is identified in the Gauteng SDP as the triangle roughly
stretching between the Johannesburg CBD, O.R. Tambo International Airport and the
Tshwane CBD (i.e. just to the east of the study area).
The province has the most important educational and health centres in the country. Pretoria
boasts the largest residential university in South Africa, the University of Pretoria, and what
is believed to be the largest correspondence university in the world, the University of South
Africa, or Unisa. More than 60% of South Africa's research and development takes place in
Gauteng, which has 41% of the country's core biotechnology companies. It's also home to
leading research institutions such as the Council for Scientific and Industrial Research (CSIR),
the Agricultural Research Council (ARC) and the Onderstepoort Veterinary Institute.
The most important economic sectors are financial and business services, logistics and
communications, and mining. More than 70 foreign banks have their head offices in the
province. Guateng is also home to the head offices of all of South Africas major banks,
stockbrokers and insurance giants. The Johannesburg Stock Exchange (JSE) is among the top
20 stock exchanges in the world by market capitalisation.
The province's economy is moving away from traditional heavy industry markets and low
value-added production towards sophisticated high value-added production, particularly in
information technology, telecoms and other high-tech industries. In an international survey
in 2000, Gauteng was identified as one of 46 global hubs for technological innovation. The
burgeoning high-tech corridor in Midrand, halfway between Pretoria and Johannesburg, is
the fastest-developing area in the country.
The province also has the best telecommunications and technology on the continent, with
correspondents from all of the world's major media based in the Province as well as South
Africa's five television stations. It also has the highest concentration of radio, internet and
print media in Africa.

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Tshwane Metro
The CoTMM Metro economy plays an important role in the economy of Gauteng, featuring
a strong manufacturing sector, particularly the automotive industry, metal production etc.
The CoTMM continues to register strong economic performance as highlighted by its GVA of
R157 billion and GVA growth rate of 5,9% in 2007. The GVA did not change significantly
since 2008, despite the global economic recession it remained at 6% in the 2009/10 financial
year. Notwithstanding the importance of the automotive industry (and in line with the
provisions of the GPSDP), the CoTMM has started to transform its economy away from a
traditional reliance on industry and heavy manufacturing towards the financial and service
sectors (CoTMM; 2011).
In 2009 the CoTMM accounted for 38,1% (R10 350,4 million) of the total of building plans
passed in the province (R27 185,2 million). The largest contributions for residential building
plans passed were recorded for dwelling-houses (25,8% or R7014,7 million) and flats and
townhouses (8,3% or R2 252,5 million) (CoTMM; 2011).

14 HERITAGE CONTEXT

The site is completely transformed (including subterranean environments through concrete


reinforced foundations) for heavy industrial use and has in fact been decommissioned. The
proposed Clean Technology Waste to Energy Facility will not result in a physical change in
landuse (i.e. heavy industrial type activities) and will also not trigger any of the relevant
activities contained in Section 38 of the Heritage Resources Act. Accordingly, this aspect
will not be assessed further.
Relevant triggers in terms of the HRA are illustrated below for ease of reference:

S38(1)(a) Construction of a road, wall, powerline, pipeline, canal or other similar


form of linear development or barrier over 300m in length.
S38(1)(b) Construction of a bridge or similar structure exceeding 50m in length.
S38(1)(c) Any development or activity that will change the character of a site exceeding 5 000m2 in extent;
involving three or more existing erven or subdivisions thereof;
involving three or more erven or divisions thereof which have been
consolidated within the past five years.
S38(1)(d) Rezoning of a site exceeding 10 000m 2 in extent.

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15 AIR QUALITY CONTEXT

Airshed Planning Professionals (Pty) Ltd has been instructed to compile an Air Quality
Baseline Assessment for the proposed pyrolysis plant and extracts from the Scoping Report
have been provided below and which have been used to guide the air quality considerations
on the Project.
The process would have to apply for an Atmospheric Emission License (AEL), as defined in
the NEM: AQA Listed Activities. These listed activities are contained in the Government
Notice (GN) 33064 of March 2010. It has been anticipated that the proposed plant would
need to apply as a Category 8 Listed Activity. This was discussed at a Joint Authorities
meeting, where it was also discussed whether or not the plant apply for an AEL under
Category 1.1, Solid Fuel combustion installation, but it has been found that the proposed
plant will not have a design capacity equal to or greater than 50MW heat input per unit, in
fact, it will be far less than this.
Therefore, for the sake of conservancy, the plant will apply for an AEL as a Category 8 listed
activity.
It is expected that the main sources of pollution emanating from the proposed plant would
be the power generators. The combustion gases associated with these generators mainly
include Carbon Dioxide (CO2), Oxides of Nitrogen(NOx), Sulphur Dioxide (SO 2), Carbon
Monoxide (CO) and Particulate Matter (PM). The power generators running on syngas and
liquid fuels would not produce significant PM; however, the power generator using carbon
black as fuel would be producing fly-ash and therefore the potential for PM in the emissions.
There is therefore also the possibility that trace metals may be present in the PM emissions
from this power generator. Such metals would typically only be those which are relatively
volatile. Trace amounts of Volatile Organic Compounds (VOCs) may also be present in the
combustion gases
The initial findings above will be investigated in more detail in the EIA Phase of the
Environmental Application Process.
16 MAJOR HAZARD INSTALLATION CONTEXT

A Major Hazard Installation Baseline Study (Nature and Business Alliance Africa, March
2012) was undertaken for the CTWEF. As a result of the Facility layout not yet being in
place, and which will be influenced by the findings of the Scoping Report, the MHI Baseline
Study only highlighted the necessary legal and policy considerations with respect to the
establishment of such a Facility.
The major hazard installation risk assessment will focus only on the requirements of the
Major Hazard Installation Regulations R.692 of 30 July 2001 issued in terms of the
Occupational Health and Safety Act (Act No 85 of 1993). This will be investigated in detail,
in the EIA Phase of the Environmental Application Process.

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17 TOWN PLANNING CONTEXT

The Town Planning Baseline Assessment was conducted by Urban Dynamics (Gauteng) and
concluded the following:
The provincial and land use policy supports the use of the properties for industrial purposes.
The City of Tshwane Metropolitan Municipality regards the re-development of the Iscor
industrial area and the utilization of unused industrial space as a priority as per their
strategic policy documentation. Council also wishes to attract private investment. The
proposed utilization of existing industrial infrastructure also addresses city
revitalization/regeneration and job-creation objectives.
The zoning of Portion 124 of 351JR, which accommodates Buildings 1 and 2 (please refer to
the Town Planning Report appended to this Scoping Report), has been established as
Industrial 1 (light industry). The previous use was for heavy/noxious industry, albeit run
by the State (i.e. Republic of South Africa).
The requirement to submit a consent
application will be determined by the interpretation of the nature (noxious or not) of the
processes to be incorporated in the proposed use.
In summary, the proposed principle use, industrial, is allowed on the project site (buildings 1
and 2) via the existing zoning and offices can be included via a consent application.
The proposed use does not differ, in principle from previous use (heavy industry and office)
and is compatible with adjacent use/zoning. Information received indicates that the traffic
impacts and engineering services requirement of the proposed use will be less than the
previous site demand.
Based on initial information, the proposed use should be supported, but regularisation
(consent) application may apply given the position of the buildings on the properties and
the possible noxious nature of processes used.

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18 POTENTIAL ENVIRONMENTAL IMPACTS IDENTIFIED

The intention of this chapter is to raise awareness with regard to potential impacts that may
become evident through the establishment of the CTWTEP and associated infrastructure.
The potential impacts listed have been anticipated based on available information and
through specialist opinions, where available. Please note that the descriptions below do
not represent an impact assessment but the anticipated scope of impacts and will be
further evaluated and assessed in the EIA Phase.

Potential environmental impacts and issues that may be associated with the construction,
operational and decommissioning phases of the proposed project and a summary of these
have been identified and are listed below. The applicability and degree and extent of these
impacts are anticipated to vary depending of the lifecycle stage of the development. This
will be assessed, by specialists where appropriate and mitigation measures for these
impacts will be considered during the EIA phase.
As part of the EIA phase an Environmental Management Programme (EMPr) will be
compiled for the various project life cycle stages to ensure that these impacts are minimised
and/or eliminated where feasible. These are summarised below.
18.1 Potential Physical Impacts:
18.1.1 Dust

It is anticipated that dust will be produced but that no hazardous dust will be generated.
This will be detailed during the EIA phase of this application.
18.1.2 Noise

It is anticipated that the general noise levels for the site will increase due to the increased
activity. This will be detailed during the EIA phase of this application.
18.1.3 Vibration

It is anticipated that the general vibration levels for the site will increase due to the
increased activity. This will be detailed during the EIA phase of this application.
18.1.4 Light

It is anticipated that the general light level for the site will increase due to the increased
activity on site. This will be detailed during the EIA phase of this application.

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18.2 Potential Biophysical Impacts:


18.2.1 Air Quality

Emissions (product and waste) for the CTWEF have been identified in the Scoping Phase and
these will be detailed and assessed during the EIA phase of this application.
18.2.2 Waste Impacts

It is anticipated that solid and liquid waste generation for the site will increase. This will be
detailed during the EIA phase of this application.

18.3 Potential Socio-Economic Impacts


18.3.1 Strategic and Town Planning

Preliminary indications show that the CTWEF may be supported from a Strategic and Town
Planning perspective, through a permitting process. This will be detailed and assessed
during the EIA phase of this application.
18.3.2 Major Hazard Installation

It has been identified in the Scoping Phase that a MHI Assessment in terms of the relevant
legislation will be required and this will be detailed and assessed during the EIA phase of this
application.
18.3.3 Socio-Economic

Preliminary specialist opinion indicates that the CTWEF may be supported from a Strategic
and Socio-Economic perspective. This will be detailed and assessed during the EIA phase of
this application.
18.3.4 Climate Change

It is becoming increasingly important to reduce natural resource use, carbon footprints and
create sustainable and green developments. The business as usual approach is no
longer acceptable in the face of climate change and the rapidly declining natural capital
available. In this regard, activity (i.e. alternative treatment of the waste tyre stream) and
technological (i.e. incorporating a CCU at a certain TPD threshold, or not for example)
alternatives will be investigated through the EIA Phase.
18.3.5 Traffic

It is anticipated that there will be traffic consideration related to the proposed


development. This will be detailed and assessed during the EIA phase of this application.
18.3.6 Bulk Services (e.g. sewage, water, electricity and solid waste)

It is anticipated that there will be bulk services impacts related to services provision from
service providers. This will be detailed and assessed during the EIA phase of this application.

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19 METHODOLOGY TO BE ADOPTED IN THE ASSESSMENT OF POTENTIAL


IMPACTS DURING THE ENVIRONMENTAL IMPACT PHASE

The assessment of the potential impacts will be based on extensive experience related to
environmental impact assessment as well as specialist assessment and input, where
applicable. Impact assessment will also be coupled with input and comment from
stakeholders. The potential impacts will be assessed after review by the professional team,
including specialists, and on the basis of professional judgement.
In the EIA Report, it is proposed that the types of potential impact (direct, indirect, and
cumulative) be considered along with the nature and magnitude (severe, moderate, and
low), extent and location of the potential impacts.
An informed prediction will be made of the timing (construction, operation or
decommissioning phase) and duration (short, long term, intermittent or continuous) of the
potential impact. An informed prediction will also be made of the likelihood or probability
of impacts occurring and an estimation of the significance of the potential impact (local,
regional or global scale).
Mitigation measures will be identified that could be implemented to lessen the potential
impacts and an evaluation of the predicted significance of residual impacts after mitigation
is put into place, will be made. The assessment of the potential impacts will be carried out
in a methodology that has been adapted from best practice guidelines disseminated from
the Competent Authority.
More details regarding the methodology to be adopted in the assessment of potential
impacts during the EIA phase are contained in the Draft Plan of Study for EIR (Appendix E).
20 ALTERNATIVES
20.1 Legislative Requirements

The NEMA EIA Regulations (2010) require that a description of any feasible and reasonable
alternatives identified must be provided and define alternatives as the following:
In terms of the NEMA EIA Regulations all Basic Assessment Reports 38, Scoping Reports 39 and
Environmental Impact Reports 40 must contain a description of any feasible and reasonable
alternatives that have been identified, including a description and comparative assessment
of the advantages and disadvantages that the proposed activity and alternatives will have
on the environment and on the community that may be affected by the activity.
Every EIA process must therefore identify and investigate alternatives, with feasible and
reasonable alternatives to be comparatively assessed.

38
39
40

Regulation 22(2)(h) of No. R. 543 of 18 June 2010 refers.


Regulation 28(1)(c) and (j) of No. R. 543 of 18 June 2010 refers.
Regulation 31(2)(g) and (i) of No. R. 543 of 18 June 2010 refers.

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Alternatives are defined in the NEMA EIA Regulations as different means of meeting the
general purpose and requirements of the activity.
The feasibility and reasonability of and the need for alternatives must be determined by
considering, inter alia, (a) the general purpose and requirements of the activity, (b) need
and desirability, (c) opportunity costs, (d) the need to avoid negative impact altogether, (e)
the need to minimise unavoidable negative impacts, (f) the need to maximise benefits, and
(g) the need for equitable distributional consequences.
Alternatives in the context of an activity may include alternatives to:
b)
c)
d)
e)
f)

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


The type of activity to be undertaken;
The design or layout of the activity;
The technology be used in the activity; and
The operational aspects of the activity.

The No-Go alternative must also be assessed.


An illustrative table is provided below, describing alternatives that are typically referred to
during an EIA process, which are strongly influenced by the development opportunities and
constraints identified during the process.

Table 6: Illustration of some typical alternatives assessed during an Environmental Application


process.

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The EAP, in conjunction with reference to various specialist opinions for the site has
considered the following alternatives, which will, at the EIA Phase, be determined for
further comparative assessment, only once they have passed the feasible and reasonable
test as detailed in the NEMA EIA Regulations (2010):
1. Layout considerations (to address potential hazards associated with the fuel
storage tanks and site logistics);
2. Technology Alternatives (to address carbon emissions, i.e. using a CCU vs.
not using one, once a certain TPD threshold is reachedfor example)
3. Activity considerations (to address the treatment of the waste stream, i.e.
tyres to landfill, incineration or the Eco2 SA CTWEF); and
4. The No-Go consideration (this is a mandatory option)
Based on the contextual information presented above, and considered by the EAP, there is
no evidence to suggest that other alternatives should be investigated for the proposed
activity.
20.2 The No Go Option (Mandatory Option)

The no-go option would result in the proposed development not being implemented and
potential impacts associated with this will be detailed in the EIA Phase, once the layout of
the plant has been designed and the potential impacts associated with the technological
and activity alternatives have been investigated in detail.
20.3 Layout Alternatives

Preliminary specialist opinions have indicated that layout alternatives may have to be
investigated and will be influenced by the design informants of the EIA Phase. These relate
mainly to the on-site fuel tanks and fuel storage as well as the storage of whole tyres and
tyre feedstock on site.
20.4 Activity Alternatives

Based on the available information, there are a number of options (i.e. landfill, incineration,
shredding for value-added products etc.) available to the waste industry in dealing with
waste tyre stock and these will be investigated and assessed in detail in the EIA Phase of this
Project.

20.5 Sustainable Technology Alternatives

The NEMA Principles states that sustainable development requires the consideration of all
relevant factors including the following:

That the disturbance of ecosystems and loss of biological diversity are avoided,
or, where they cannot be altogether avoided, are minimised and remedied;
that pollution and degradation of the environment are avoided, or, where they
cannot be altogether avoided, are minimised and remedied;
that the disturbance of landscapes and sites that constitute the nation's
cultural heritage is avoided, or where it cannot be altogether avoided, is
minimised and remedied;

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that waste is avoided, or where it cannot be altogether avoided, minimised and


re-used or recycled where possible and otherwise disposed of in a responsible
manner;
that the use and exploitation of non-renewable natural resources is responsible
and
equitable, and takes into account the consequences of the depletion of the
resource;
that the development, use and exploitation of renewable resources and the
ecosystems of which they are part do not exceed the level beyond which their
integrity is jeopardised;
that a risk-averse and cautious approach is applied, which takes into account
the limits of current knowledge about the consequences of decisions and
actions; and
that negative impacts on the environment and on people's environmental
rights be anticipated and prevented, and where they cannot be altogether
prevented, are minimised and remedied.

In this regard, sustainable technology alternatives, in the context of this application, can be
described as technologies that are technologically and environmentally superior to
standard technologies and that will assist in promoting the above NEMA Principles.
These may include, for example:
Technologies that ensure a more efficient pyrolysis / gasification process
Technologies that ensure acceptable or even no emissions
Technologies that ensure that carbon sequestration is considered as part of the
Project, for example

21 PUBLIC PARTICIPATION PROCESS


21.1 Steps Taken to Notify Potentially Interested and Affected Parties

Identification of Stakeholders
After obtaining the relevant site information, the Landowner, Competent and Commenting
Authorities were contacted to obtain owner/occupant details for directly adjacent erven as
well as key stakeholders in the waste industry, related to this type of activity. In terms of
the NEMA EIA Regulations (2010), notification of directly adjacent landowners and occupiers
is required. The EAP is satisfied that the public participation process will be consistent with
the requirements of Regulations.

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Communication with Stakeholders


In terms of the NEMA EIA Regulations, potential Interested and Affected Parties
(I&APs) must be given 30 calendar days within which to register as an I&AP
(initial notification).
Further, registered I&APs must be given an opportunity to comment on reports
that will be submitted to the relevant authority.
As such, and in accordance with the Public Participation Guidelines produced by
the relevant authority, the initial notification (30 days) and the commenting
period for the Draft Scoping Report (40 days) have been combined to allow for
stakeholders to be fully informed upfront and all parties have therefore been
given 40 calendar days in which to register as an I&AP and lodge with the EAP
their comments/issues/suggestions pertaining to the proposed activity, based
on the available information.
One local newspaper advert was published in the Rekord on 01 June 2012
One regional newspaper advert was published in the Pretoria News on 01 June
2012
One national newspaper advert was published in the Sunday Times on 03 June
2012
Please refer to Appendix E for copies of the contents of these documents;
Three site notices were placed at highly visible locations (please refer to
Appendix A which shows the locations of these notices) at the subject site;
This draft Scoping Report has been released to registered I&APs and
commenting authorities for a period of 40 calendar days in which to lodge with
the EAP their comments/issues/suggestions pertaining to the proposed
development.
Please refer to Appendix E for a full account of Stakeholders notified as part of
this Initial Public Participation Period.
21.2 Authority Consultation

The following Authorities have already been consulted with on the Project as part of a due
diligence exercise on the Project:

National Department of Environmental Affairs (DEA)


Tshwane Metropolitan Municipality
Gauteng Department of Agriculture and Rural Development (GDARD)

The same Authorities have been engaged with as part of this Public Participation Process as
mandatory stakeholders. A summary of the submissions/contacts is made in bullet point
below.
Application form and supporting documents (NEMA EIA and NEM: WA) submitted to
DEA on 06 December 2011;
Acknowledgement of receipt of the application form (NEMA EIA and NEM: WA) and
supporting documents submitted to the EAP on 09 January 2012;
Application form and supporting documents (NEM: AQA) submitted to Tshwane
District Municipality on 20 March 2012;
Acknowledgement of receipt of the application form (NEM: AQA) and supporting
documents submitted to the EAP on 16 April 2012
2

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21.3 Summary of Application and Public Participation Process

A summary of the Public Participation Process is presented in the table below.


Item
Submission of Application Form
supporting documents to DEA.
Receipt of DEA approval to proceed

and

Submission of Application Form and


supporting documents to Tshwane District
Municipality.
Receipt of Tshwane District Municipality
approval to proceed
Initial Specialist Studies (i.e. opinions) to
inform Scoping Report
Collation of the draft Scoping Report (DSR)
Identification of interested and affected
parties
Identification of Ratepayers Associations
and NGOs
Posting
of
registered
letters
to
owners/occupants adjacent to the site; the
ward councillor and identified NGOs and
Civic Associations.
Newspaper advert published in the Rekord
Newspaper advert published in the Pretoria
Newspaper
Newspaper advert published in the Sunday
Times
Review of draft Scoping Report and Plan of
Study for EIR by registered stakeholders
40-day response period allowed for
40-day stakeholder response period ends
Collation of the Final Scoping Report (FSR)
Review of Final Scoping Report and Plan of
Study for EIR by registered stakeholders
21-day response period allowed for
21-day stakeholder response period ends
Submission of final Scoping Report and Plan
of Study (POS) for EIR to DEA
Approval of Scoping Report and POS for EIR

Date
06/12/11

Comment

09/01/12

DEA Reference Numbers issued:


NEAS Reference: DEA/EIA/0000879/2011
DEA Reference: 12/12/20/2673

20/03/12

16/04/12
December 2011
to May 2012
March 2012 to
May 2012
December 2011
to May 2012
May 2012
30/05/12

Tshwane District Municipality reference


number 9/16/1/2/13 R was issued
Town Planning, Socio-Economic, MHI, Air
Quality

Erf ownership details obtained


from landlord and local authority
Details obtained from the Ward
Councillor
Please refer to Appendix E for an
indication of Registered Letters Issued to
Stakeholders

01 June 2012
01 June 2012

Local newspaper
Regional newspaper

03 June 2012

National newspaper

04 June 2012 to
16 July 2012
16 July 2012
July 2012
August 2012
TBA
TBA
TBA
TBA

TBA
to

TBA

TBA

To be confirmed once DEA has reviewed


the PoS for EIR.

Collation of the draft Environmental Impact


Report (EIR) and EMPr

TBA

Review of draft EIR Report by registered


stakeholders

TBA

To be completed once approval (from


DEA) has been received to proceed with
the EIA.
Draft EIR Report to be submitted to
registered stakeholders once it has been
prepared and collated. A 40-day comment
period will be allocated to registered
I&APs.

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40-day response period allowed for


40-day stakeholder response period ends
Collation of the Final EIR Report
Review of Final EIR Report and EMPr by
registered stakeholders
21-day response period allowed for
21-day stakeholder response period ends
Submission of final EIA Report to DEA&DP

Notification of registered stakeholders of


the environmental authorisation decision

TBA
TBA
TBA
TBA
TBA
TBA

TBA

TBA

TBA
EIA Report to be submitted once (1) the
public consultation phase has been
finalised, (2) the EIR has been updated to
include and address comments and
concerns from the EIA phase public
comment period,
To be conducted once a decision has been
made by DEA&DP.

Table 7: Summary of the Application and Public Participation Process

21.4 Proof of Notification

A copy of the contents of the site notices, adverts and notification letters is contained in
Appendix E.
21.5 List of Registered Interested and Affected Parties (I&APs)

A list containing contact details of all persons initially notified is contained in Appendix E
(Public Participation).
A Comments and Responses Report contains the details of all registered I&APs and will be
provided with the Final Scoping Report as this Draft Report forms part of the Initial Public
Participation Process.

21.6

Summary of Considerations Raised by Interested and Affected Parties

There have been no considerations raised as yet as the initial Public Participation Process
has not yet taken place. This information will be recorded and included with the Final
Scoping report.
Comments raised by I&APs during the Scoping Stage will be addressed through the
Comments and Responses Report and are submitted to the relevant authority with the final
Scoping Report.

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22 CONCLUSIONS

A number of potential environmental and social considerations have been identified during
the Scoping stage of this project, which need to be considered and assessed in more detail
during the EIA stage.
These include:
Bulk Infrastructure considerations (e.g. roads, sewage, electricity and solid waste);
Noise, dust, light and vibration considerations;
Social and economic considerations;
Strategic Policy and Planning considerations;
Major Hazard Installation (MHI) considerations;
Climate Change considerations;
Air Quality considerations; and
Waste considerations
Specialist studies recommended by the EAP for the EIA stage should include:
Social Assessment;
MHI Assessment;
Town Planning Assessment;
Air Quality Assessment
In addition to the above recommended studies, a legislatively required draft Environmental
Management Programme (EMPr) will be compiled to form part of the EIR Report. A plan of
study for EIA is included as Appendix F, which needs to be reviewed and approved by DEA
prior to the EIR phase commencing.
Should you require any further information, please do not hesitate to contact the
undersigned.
We look forward to your valued participation.
Yours faithfully,

FABIO VENTURI
Certified Environmental Scientist (SAIEES)
Environmental Assessment Practitioners Association of South Africa (Founding Member)
Green Star SA Accredited Professional (GCBSA)
Certified Carbon Footprint Analyst (CPSA)

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