APPENDIX C - Sillito Environmental · PDF [email protected] Tel: 082 925...

APPENDIX C

Public Participation Appendix, including:

1) Initial Stakeholder Notification Table

2) Registered Stakeholder Table

3) Comments and Responses Report

4) Summary Table of Public Participation Activities

5) Copies of Comments and Responses

a. Draft Scoping Phase

b. Final Scoping Phase

c. Draft EIA Phase

6) Proof of Public Participation Undertaken



c. Draft EIA Phase

1) Initial Stakeholder Notification Table

INITIAL NOTIFICATION TABLE DPW DRAKENSTIEN INCINERATOR INSTALLATION PROJECT

ADJACENT LANDOWNERS Name/Contact Details Erf/Address Means of Notice Date of Notification

1 SABLE D’ARGENT PTY ERF 1426/7 PO BOX 303 PAARL 7620

ERF 1426/7 PO BOX 303 PAARL 7620

Registered Post

2 GERHARDUS P.C LOUBSER Erf 1426/6 POSBUS 142 SIMONDIUM 7620

Erf 1426/6 POSBUS 142 SIMONDIUM 7620

Registered Post

3 PEAKSTAR 108 PTY LTD Erf 1426/5 PO BOX 1369 SANLAMHOF 7532

Erf 1426/5 PO BOX 1369 SANLAMHOF 7532

Registered Post

4 L’ARC D’ORLEANS ANNEX NED GER SENDING KERK – FRANSCHOEK Erf 889 L’AVENIR P/A L’ARC D’ORLEANS TRUST POSBUS 209 PAARL

Erf 889 L’AVENIR P/A L’ARC D’ORLEANS TRUST POSBUS 209 PAARL

Registered Post

5 RIVERSMEET ERFURT LANDGOED PTY LTD Erf 905 POSBUS 21 SIMONDIUM 7670

Erf 905 POSBUS 21 SIMONDIUM 7670

Registered Post

Name/Contact Details Erf/Address Means of Notice Date of Notification 6 Bien Donne

Landbounavorsingsraad Erf 904 Privaatsak x5013 Stellenbosch 7599

Erf 904 Privaatsak x5013 Stellenbosch 7599

Registered Post

7 Sybrand Mostert Salomons Vallei Erf 1426/11 Posbus 831 Huguenot 7645

Erf 1426/11 Posbus 831 Huguenot 7645

Registered Post

8 Republiek van Suid-Afrika Watervliet Erf 942/2 P O Box 9027 Cape Town 8000

Erf 942/2 P O Box 9027 Cape Town 8000

Registered Post

9 Leebar JNR (PTY) Ltd Langerust Erf 946/1 P O Box 116 Paarl 7620

Erf 946/1 P O Box 116 Paarl 7620

Registered Post

10 Elkana Trust Langerust Erf 946/2 Posbus 11 Simondium 7670

Erf 946/2 Posbus 11 Simondium 7670

Registered Post

Name/Contact Details Erf/Address Means of Notice Date of Notification 11 BR Datnow

Erf 1426/8 P.O. Box 19183 Linton Grange Port Elizabeth 6015

Erf 1426/8 P.O. Box 19183 Linton Grange Port Elizabeth 6015

Registered Post

12 Cape Fruit Processors (Pty) Ltd Erf 1426/9 Posbus 1368 Suider-Paarl 7624

Erf 1426/9 Posbus 1368 Suider-Paarl 7624

Registered Post

13 Cape Fruit Processors (Pty) Ltd ACB Erf 1426/10 Posbus 178 Simondium 7670

Erf 1426/10 Posbus 178 Simondium 7670

Registered Post

14 Pilgrims Minerals (Pty) Ltd Paarl Landelik Erf 1475/6 and Erf 1475/5 P O Box 130 Groot Drakenstein 7680

Erf 1475/6 and Erf 1475/5 P O Box 130 Groot Drakenstein 7680

Registered Post

15 NED GER Sendingkerk-Franschoek Paarl Landelik P/A MT Malan Erf 889/1 Posbus 209 Paarl 7620

Erf 889/1 Posbus 209 Paarl 7620

Registered Post

Name/Contact Details Erf/Address Means of Notice Date of Notification 16 Antoich Settlement Trust

Paarl Landelik C/O Mazars Moores Roland Erf 1655 4 Mill Street Paarl 7620

Erf 1655 4 Mill Street Paarl 7620

Registered Post

17 Republiek van Suid-Afrika Paarl Landelik Dept. Openbare Werke Erf 1006/2 Privaatsak X9027 Kaapstad 8000

Erf 1006/2 Privaatsak X9027 Kaapstad 8000

Registered Post

18 Republiek van Suid-Afrika Erf 888/1 P O Box 9027 Cape Town 8000

Erf 888/1 P O Box 9027 Cape Town 8000

Registered Post

19 HAND DELIVERY

Erf 894 Klipbank Victor Vester 9999

Erf 894 Klipbank Victor Vester 9999

HAND DELIVERY

20 HAND DELIVERY Lapris Estate Telkom SA LTD Erf 900/1

Erf 900/1

HAND DELIVERY

21 HAND DELIVERY Erf 1006/2 Meerlust

Erf 1006/2 Meerlust

HAND DELIVERY

22 HAND DELIVERY Deltameer Bergriver Land Trust Erf 1460/3

Erf 1460/3

HAND DELIVERY

23 HAND DELIVERY Hercules Pilaar Louw Philippus Albertus Briers Erf 475/6

Erf 475/6

HAND DELIVERY

GOVERNMENT DEPARTMENTS AND RATE PAYERS ASSOCIATIONS

Organization/Dept Means of Notice Date of Notification Reinhard van Niewenhuyzen Ward Councillor, Ward 28 of Drakenstein Municipality [email protected] Tel: 082 629 6239

Email

Johan Rademeyer Drakenstein Municipality: Infrastructure and Planning [email protected] Tel: 082 925 8149

Email

Civil Engineering: Drakenstein Municipality Jimmy Knaggs [email protected] Cindy Prins [email protected] Tel: 021 807 4715 Fax: 02 870 1522 Municipal Offices, Corner of Market and Main Streets Paarl

Email and hand delivery of report

CapeNature Rhett Smart [email protected] Tel: 021 866 8000 Assegaaibosch Nature Reserve Jonkershoek


DEADP: Pollution Management Directorate Catherine Bill [email protected] Tel: 021 483 4349 Fax: 021 483 3254 1 Dorp Street Cape Town 8000


Organization/Dept Means of Notice Date of Notification Department of Water Affairs Derril Daniels [email protected] Tel: 021 941 6000 Fax: 021 941 6107 52 Voortrekker Road Spectrum Building Bellville


DEADP: Waste Directorate Mr. Eddie Hanekom [email protected] Tel: 021 483 2728 Fax: 021 483 4125 / 021 483 3200 Utilitas Building 1 Dorp Street Cape Town 8000


Department of Agriculture Cor van der Walt [email protected] Tel: 021 808 5093 Fax: 021 808 5092 Muldersvlei Road Elsenburg


Cape Winelands District Municipality Environmental Health Department Acting Air Quality Officer: Mr. Marius Engelbrecht [email protected] Tel: 021 888 5100 / 072 122 5680 Fax: 021 887 9365


2) Registered Stakeholder Table

REGISTERED STAKEHOLDER TABLE DRAKENSTEIN

Organization/Dept/Erf & Address Means of Notice Date of last Communication

Organs of State Competent authority: National DEA Waste Directorate Zinhle Mbili Environment House 473 Steve Biko Road Arcadia, Pretoria 0083 Tel: 012 399 9785 Fax:012 359 3625 Email: [email protected]

Department of Agriculture Cor van der Walt [email protected] Tel: 021 808 5093 Fax: 021 808 5092 Muldersvlei Road Elsenburg


Department of Water Affairs Derril Daniels [email protected] Tel: 021 941 6000 Fax: 021 941 6107 52 Voortrekker Road Spectrum Building Bellville


Organization/Dept/Erf & Address Means of Notice Date of last Communication DEADP: Land Management, Region 1; Pollution Management Directorate; Waste Directorate; and Air Quality Directorate c/o: DEA&DP DFU – André Oosthuizen Tel: 021 483 4282 Fax: 021 483 8311 Email: [email protected] 1 Dorp Street, 11th Floor Utilitas Building, Cape Town, 8001


CapeNature Rhett Smart [email protected] Tel: 021 866 8000 Fax: 086 529 4992 Assegaaibosch Nature Reserve Jonkershoek


Drakenstein Municipality WJ Knaggs Tel: 021 807 4500 Fax: 021 872 8054 Email: [email protected] P.O. Box 1 Main Street Paarl 7622

Cape Winelands District Muncipality Marius Engelbrecht Tel: 021 888 5811 Fax: 021 887 9365 Cell: 072 122 5680

Organization/Dept/Erf & Address Means of Notice Date of last Communication Email: [email protected]

Interested and Affected Parties

3) Comments and Responses Report

COMMENTS AND RESPONSES REPORT: WASTE LICENCE AND ATMOSPHERIC EMISSIONS LICENCE APPLICATION FOR

THE INSTALLATION OF A NEW INCINERATOR AT THE DRAKENSTEIN CORRECTIONAL FACILITY, PAARL, WESTERN CAPE

SEC REF: 0100812

DEA REF: 12/9/11/L1176/9 CWDM REFERENCE NUMBER: 7973879

TABLE CURRENT AS OF 27.01.2016

ISSUE/ CONCERN/ QUERY RAISED BY WHOM PROJECT TEAM RESPONSE Initial Notification and Draft Scoping Phase

Amendments have been made to Section 21 of the NEMA: Air Quality Act, GN 893 of 22 November 2013 which places the incinerator under a new sub-category, Subcategory 8.2: Crematoria and Veterinary Waste Incineration.

Cape Winelands District Contact: Marius Engelbracht Date: 23 January 2014

The reports will be amended where necessary; and a new application form will be submitted to the CWDM for their records.

Uncertainty within the report as the authors of the reports differ on the number and size of incinerator/s to be installed. The report refers to the possibility of dioxins and furans in the proposed incinerator emissions. Should dioxins and furans be present in the abattoir waste, the Scoping Report and AEL application should place this listed activity under Subcategory 8:1 Thermal Treatment of General and Hazardous Waste.

SEC stated that in the Final Scoping Report, clarity on the capacity of the single new incinerator, and specialist opinion on the issue of whether dioxins and furans need to be accounted for, will be outlined.

The AEL will be seen as a new application as the existing incinerators did not have registration certificates issued in terms of the Atmospheric Pollution Prevention Act, 1965 (Act 45 of 1965).

A new AEL application form will be submitted for the CWDM’s records.

1. All wetlands or sponge areas shall be considered “No-Go” areas. As such, no development will be allowed in these areas.

2. A botanist should be consulted to confirm that no natural vegetation is present on site within the proposed development footprint.

3. The final air quality impact assessment should investigate the inversion layer height and the frequency of these occurrences in the Drakenstein valley. The assessment should take seasonal variation into account.

4. The project engineer’s design must take all sensitive receptors into account and also data from the air quality impact

Drakenstein Municipality Contact: WJ Knaggs Date:24 January 2014

The municipality’s requirements with respect to avoidance of wet areas; botanical specialist opinion; air quality specialist input; and consideration of the re-use of waste ash will be adhered to going forward.

ISSUE/ CONCERN/ QUERY RAISED BY WHOM PROJECT TEAM RESPONSE Initial Notification and Draft Scoping Phase

assessment into account when calculating the correct stack height required.

5. The EIA report should consider options for the re-use of waste ash on the site.

It should be noted that this Department will be a commenting authority on the abovementioned application and requires an opportunity to comment on the reports compiled for the application when available for review by stakeholders.

Department of Environmental Affairs and Development Planning Land Management Contact: Ms. S. Adams Date: 7 March 2014

SEC has noted that the Department will be a commenting authority. The project is in the Final Scoping phase and the Department will be provided with an opportunity to comment on the Final Scoping Report.

ISSUE/ CONCERN/ QUERY RAISED BY WHOM PROJECT TEAM RESPONSE Final Scoping Phase

The Cape Winelands District Municipality, Municipal Health Services in terms of the National Environmental Management: Air Quality Act (Act 39 of 2004) (AQA) has no objection to the proposed installation of an abattoir waste incinerator at the Drakenstein Correctional Facility if all the legal requirements stipulated in relevant legislation are adhered.

Cape Winelands District Municipality Contact: Marius Engelbracht Date: 25 June 2015

Comment noted. The environmental impact assessment process has adhered to all procedures as outlined in the EIA Regulations contained in GN No. 982 of 2014.

Atmospheric Licensing Authority – Competent Authority Drakenstein Correctional Services existing incinerators did not have environmental authorization issued in terms of the Atmospheric Pollution Prevention Act, 1965 (Act 45 of 1965). The Drakenstein Correctional Services abattoir incinerator Atmospheric Emissions License (AEL) Application will be regarded as a new application for a listed activity in terms of the Section 21(1)(a) of the AQA. The status of this proposed incinerator will be for a new plant and the compliance emission monitoring for substances will be according to that of a new plant within the amended Section 21 listed activities legislation, GN 893 of 22 November 2013. With reference to the Cape Winelands District Municipality indicated as the Atmospheric Licensing Authority to issue the Atmospheric Emission License for the proposed installation of an abattoir waste incinerator at the Drakenstein Correctional Facility (Pages ii, 2, 6 of FSR refers). The National Environmental Management: Air Quality Amendment Act (Act 20 of 2014), Subsection 36(5) relates to circumstances where the Minister becomes the licensing authority. Subsection 36(5) of the Air Quality Amendment Act declares that, notwithstanding subsections (1) to (4), the Minister is the licensing authority and must perform the functions of the licensing authority if- (d) the listed activity relates to the activities listed in terms of Section 24(2) of the National Environmental Management Act, 1998, or in terms of Section 19(1) of the National Environmental Management: Waste Act, 2008, or the Minister has been identified as the competent authority (Page 7 of FSR refers).

The comment regarding clarity on the Competent Authority for the AEL application is noted. The project team has been in consultation with the national DEA for written confirmation of the abovementioned comment and will provide the confirmation as soon as it is received.


The Air Quality Amendment Act, made provision in Subsection 36(6) for an integrated environmental authorization which will include the Atmospheric Emission Licence under subsection (5)(d) of the Air Quality Amendment Act. Thus the Minister becomes the competent licensing authority and is empowered to issue an integrated environmental authorization for the listed activity. This integrated environmental authorization process was followed within this FSR (Appendix F of FSR refers). With the above mentioned as reference, the applicant or Environmental Assessment Practitioner must clarify who will be the Atmospheric Licensing Authority in terms of the AQA. The Cape Winelands District Municipality will require written confirmation from Department of Environmental Affairs who will be regarded as the Atmospheric Licensing Authority.

Preliminary Atmospheric Emission Licence Application The preliminary AEL application as received by the Cape Winelands District Municipality applies for an Atmospheric Emission Licence for two incinerators. The preliminary application, although only preliminary, contains limited or insufficient information. The information provided in the preliminary AEL has changed since the Draft Scoping Report in November 2013 with amendments to the AQA. The AEL application was made with the incinerators being classified as a listed activity under Category: Disposal of Hazardous and General Waste as a Section 21 AQA listed activity as contemplated in the Government Notice 248 of March 2010. The list of activities which result in atmospheric emissions which have or may have a significant detrimental effect on the environment was amended in the Government Notice No. 893 of November 2013. The amendment placed the incineration of abattoir waste as an activity listed in Category 8, Subcategory 8.2: Crematoria and Veterinary Waste Incineration.

It is noted that the information provided in the preliminary AEL has changed since the Draft Scoping Report in November 2013 with amendments to the AQA, as a result of the amendment of GN No. 248 of 2010 to GN No. 893 of 2013. Once confirmation of the competent authority for assessment of the AEL application is received, the information will be updated and submitted accordingly.


Should the Cape Winelands District Municipality remain the Atmospheric Licensing Authority for this listed activity at Drakenstein Correctional Services, this application will have to be resubmitted containing the correct information.

Dioxins and Furans Taking into account that the specialist report with the Scoping Air Quality Impact Assessment (Appendix D of FSR refers), this proposed incinerator assessment was carried out in line with the minimum emission standards for Section 21 listed activities as contemplated in the Government Notice 248 of March 2010. With the amendment to GN 248 of March 2010 with GN 893 of November 2013 coming into effect, certain pollutants to be monitored for were omitted amongst others Dioxins and Furans. Only abattoir waste should be incinerated within this proposed incinerator. Should any other waste, that could offset dioxins and furans, be incinerated, the listed activity will fall within Category 8, Subcategory 8.1: Thermal Treatment of General and Hazardous Waste of the listed activities in terms of the AQA. This category of Section 21 listed activity will require more pollutants to be monitored with more stringent values for some of the pollutants.

The comment is noted and has been incorporated into Section 9.4.3 of the draft EIA Report, September 2015.

Dust Mitigation and Noise Control The decommissioning of the existing two incinerators as well as the construction of the proposed incinerator can have associated impacts such as dust and noise. Ash residue from the proposed incineration process could in addition create a dust nuisance. In respect of the indication made to dust in the Report, the applicant is required to submit a dust management plan as detailed below in order to comply with the National Dust Control Regulations (Regulation 827 of 1 November 2013):-

a) Identify all possible sources of dust within the affected site;

b) Detail the best practicable measures to be undertaken to mitigate dust emissions;

c) Detail an implementation schedule; d) Identify the line management responsible for

The comment is noted and has been incorporated into Section 2.4.2 of the Draft EMPr for the proposed activity.


implementation; and e) Establish a register for recording all complaints received

by the person regarding dust fall and for recording follow up actions and responses to the complainants.

The proposed project must comply with all the Western Cape Noise Control Regulations Provincial Notice 200 of 20 June 2013 during decommissioning of the old incinerators and the construction of the proposed new incinerator.

Emergency Preparedness and Abnormal Operating Conditions Plan An internal emergency preparedness plan must be formulated for acute pollution to be included in the Drakenstein Correctional Services emergency preparedness plan. All risks identified in the plan must be systematically managed using one of the following approaches:

1. Environmental Management procedures; and/or 2. A contingency plan to minimize the impact of the incident

through an efficient and effective emergency response. This should include as a minimum a description of responsible personnel, their expertise, contact numbers, response procedures, staff training programs and personal protective equipment used in the event of acute pollution for containment, clean-up, response or prevention must be available for inspection. The Contingency plan should include media specific response, i.e. storm water and groundwater, discharges to sewer, waste, air pollution, etc. The project must make provision with reference to control of incidents in terms of Section 30 of NEMA, as amended where such an incident are defined within Section 30 of NEMA as an unexpected, sudden and uncontrolled release of hazardous substances, including from a major emission, fire or explosion that causes, has caused or may cause significant harm to the environment, human life or property.

The requirement for an emergency/ contingency plan has been included in Section 2.4.1 of the draft EMPr for the proposed activity.


Environmental Health Perspective – National Health Act, Act 61 of 2003 The comments above do not include the comments from the Cape Winelands District Municipality Municipal Health Services in terms of the National Health Act, Act 61 of 2003. Environmental Health inputs in terms of the mentioned legislation will be given by the Environmental Health Practitioner designated to ensure the environmental health risks are managed at the Drakenstein Correctional Services.

Noted.

Dust and Noise Regulations Dust and noise may be generated during construction phase of the project. Please note that the operation should comply with the recently promulgated National Dust Control Regulations, Notice 827 of 2013 and Department of Environmental Affairs and Development Planning Environment Conservation Act, 1989 Western Cape Noise Control Regulations P.N. 200/2013.

Department of Environmental Affairs and Development Planning: Air Quality Management Contact: Peter Harmse Date: 10 July 2015

Mitigation measures for dust and noise impacts have been incorporated into Section 2.4.2 and Section 2.4.3 of the Draft EMPr for the proposed activity.

Air Emission Listed Activity The proposed activity triggers the following Section 21 Listed Activity in terms of the National Environmental Management: Air Quality Act, 2004 (Act no. 39 of 2004) as amended:

1. Category 8 Subcategory 8.2 (Crematoria and Veterinary Waste Incineration) which is described as “Cremation of human remains, companion animals (pets) and the incineration of veterinary waste”.

2. The information supplied in sections 5 and 6 of the Preliminary Atmospheric Emissions Licence application is incomplete.

It is noted that the information provided in the preliminary AEL has changed since the Draft Scoping Report in November 2013 with amendments to the AQA, as a result of the amendment of GN No. 248 of 2010 to GN No. 893 of 2013. Once confirmation of the competent authority for assessment of the AEL application is received, the information will be updated and submitted accordingly.


Air Emissions Impact Management The following recommendations made by the Airshed Planning Professionals in the Air Quality Impact Assessment Report dated August 2012, must be implemented:

1. The supplier of the incinerator must be able to demonstrate that Category 8.2 Emission Limits will not be exceeded. This may require the installation of gas cleaning (abatement) equipment.

2. Implementation of regular stack monitoring to ensure that emissions are within the minimum Emission Limits as contained in the Category 8.2 Listed Activity. Frequency of this monitoring must be agreed with the appropriate licensing authority (Cape Winelands District Municipality).

3. Best practice measures must be employed to minimize or avoid offensive odours emanating from the incinerator feed material.

It has been recommended by the EAP that compliance to and implementation of all mitigation measures as proposed by the specialists and the EMPr become a condition of the environmental authorization.

The Department would like to draw your attention to Section 28 of the National Environmental Management Act (NEMA), i.e. Duty of Care which states that; “Every person who causes, has caused or may cause significant pollution or degradation of the environment must take reasonable measures to prevent such pollution or degradation from occurring, continuing or recurring, or, in so far as such harm to the environment is authorized by law or cannot reasonably be avoided or stopped, to minimize and rectify such pollution or degradation of the environment.

Noted. Appendix E contains the EMPr for the proposed activity that is aimed at adhering to the requirements of Section 28 of NEMA.

Roads 1. Drakenstein is not the road authority in the proposed

development area. 2. Any alterations to the existing road network will be the

responsibility of the developer, including design, approval and construction of any extra traffic control and or traffic calming.

Drakenstein Municipality Contact: WJ Knaggs Date: 17 August 2015

It is not anticipated that any additional or alteration to the existing road network will be required.


Storm water 1. Any existing internal or external storm water system that

may require upgrading i.e. replacement of undersized pipes shall be the responsibility of the developer.

2. There is no municipal storm water reticulation in the proposed development area.

3. Suitable pollution control must be implemented at the outfalls.

4. The disposal of any contaminated run-off (washing water, storm water, etc.) must be disposed of in such a manner so as not to cause any pollution to surface, ground water or create a nuisance.

Noted. Appendix E contains the EMPr that is aimed at addressing the issues of pollution control.

Water 1. Bulk water services will not be negatively affected.

Noted.

Waste 1. The burial of any animal waste on site will not be allowed. 2. The incinerator area should be connected to the septic

tanks. All waste and wash water from this area should be discharged into the septic tanks. The washing of plastic bins should only be done in this area.

3. Septic tanks should be monitored on a regular basis to prevent overflow.

4. Section 4.3 Waste Management in the Project Engineer’s Preliminary Design Report should be adhered to.

5. Once construction is completed all waste materials and rubble is to be removed and disposed of at a licensed waste disposal facility.

Section 2.4.1 of the draft EMPr contains the mitigation measures for appropriate waste management for the proposed activity.

Sewage 1. Bulk sewage service will not be negatively affected.

Noted.


General 1. All of the works, including but not limited to; roads, storm

water, sewers, landscaping, irrigation, etc. shall be designed by a suitably registered (ECSA registration for the civil works and SACLAP registration for the landscaping) person and any such works shall be constructed under supervision of such registered person. All such design plans shall be submitted to the Civil Engineering Services Department for approval prior to the commencement of construction.

2. All works where applicable shall be constructed to at least the minimum standards as set out in, Engineering Services: Municipal Standards.

Noted.

The Department perused the application and wishes to inform the applicant that the previous comments dated July 2014 still applies. The Department will provide further comments once a copy of the EIA Report is received.

Department of Water and Sanitation: Western Cape Contact: Melissa Lintnaar-Strauss Date: 17 August 2015

Noted.

Your site inspection dated 17 June 2015 and correspondence dated 22 July 2015 have reference. The Department has reviewed the information submitted and can confirm that water use authorization in terms of the National Water Act, 1998 (Act No. 36 of 1998) will not be required for the proposed development. The new incinerator will be constructed within the footprint of the existing facility and will not impact on any water course. The Department therefore has no objections to the proposed development provided that all mitigation measures proposed are adhered to.

Department of Water and Sanitation: Western Cape Contact: Warren Dreyer Date: 28 August 2015

The clarification regarding the issue of the requirement for a water use authorization is noted.

The Department has evaluated the submitted Final Scoping Report (FSR) and is satisfied that the document comply with the minimum requirement of the Environmental Impact Assessment (EIA) Regulations, 2010. The report is hereby accepted by the Department in terms of GN No. R.543 of 18 June 2010 and you may proceed with the Environmental Impact Assessment Process.

Department of Environmental Affairs Contact: Zinhle Mbili Date: 15 July 2015

Noted.

ISSUE/ CONCERN/ QUERY RAISED BY WHOM PROJECT TEAM RESPONSE Draft EIA Phase

The following is the Department of Environmental Affairs and Development Planning: Air Quality Management comments on the Draft EIA report: Dust and Control Regulations Propose operation to comply with the recently promulgated national Dust Control Regulations, Notice 827 of 2013 and Department of Environmental Affairs and Development Planning Environment Conservation Act, 1989 Western Cape Noise Control Regulations P.N. 200/2013.

Department of Environmental Affairs and Development Planning: Air Quality Management Contact: Peter Harmse Date: 24 November 2015

Dust and noise control measures for the operational phase of the proposed development have been laid out in the EMPr in Sections 2.4.2 and 2.4.3 respectively and will be adhered to accordingly.

Air Emission Listed Activity DEA&DP: Air Quality Management confirmed that the proposed activity triggers Section 21 Listed Activity in terms of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) as amended: Category 8 Subcategory 8.2 (Crematoria and Veterinary Waste Incineration) which is described as “Cremation of human remains, companion animals (pets) and the incineration of veterinary waste”.

Noted.

Air Emissions Impact Management All recommendations made by Airshed Planning Professionals in the Air Quality Impact Assessment Report dated August 2012, must be implemented. Incinerator supplier to demonstrate that Category 8.2 Emission

Limits will not be exceeded. Possible installation of gas cleaning equipment.

Regular stack monitoring to be implemented. Frequency of monitoring to be agreed by the appropriate licencing authority.

Best practice measures to be implanted to minimize or avoid odours emitted from incinerator feed material.

Section 2.4.2 of the EMPr contains all recommendations made by the Air Quality specialist for the operational phase of the proposed development.

Attention must be given to Section 28 of NEMA – Duty of Care. Noted. The following is the Drakenstein Municipality’s comments on the Draft EIA report: Materials and waste stored onsite prior to removal must be covered appropriately and liquid waste containers to be stored

Drakenstein Municipality Contact: WJ Knaggs Date: 9 December 2015

Building materials during the construction phase will be covered and stored appropriately. Waste stored onsite will be covered and stored appropriately in accordance


within the bunded area. with the Norms and Standards for the Storage of Waste.

Top soil to be removed where soil disturbances are bound to occur and adequately stored and covered in a demarcated area.

Location of the top soil stockpile will be determined prior to the commencement of site activities.

No fires or burning of waste to take place during the construction phase.

No fires or burning of waste will take place onsite during the construction phase.

If the Contractor decides to feed waste water into the sedimentation pond during the construction phase prior to disposal, the location of the sedimentation pond should be provided.

The sedimentation pond will be located within the cordoned off construction area, only if one is required. If a sedimentation pond is needed during construction then the exact location of the sedimentation pond will be determined prior to commencement of any site activities. The pond will be established on an impermeable surface and not within 50m of a freshwater system. This is to ensure that there will be no soil or surface water contamination.

If any oil/fuel chemical spills occur they are to be contained and the incident to be treated as a section 30 incident in terms of NEMA until proven otherwise. A spillage must be reported immediately to the Environmental Management Department.

Spillage Incident procedures are set out in the EMPr.

The septic tanks should be emptied on a regular basis by a suitable waste contractor.

The septic tanks will be emptied every 3 months.

The following is the Air Quality Officer’s provisional comments on the Draft EIA report: The Cape Winelands district Municipality, Municipal Health Services in terms of the National Environmental management: Air Quality Act (Act 39 of 2004) (AQA) has no objection to the proposed installation of an abattoir waste incinerator at the

Cape Winelands District Municipality Contact: Marius Engelbracht Date: 10 December 2015

Noted.


Drakenstein Correctional Facility if all the legal requirements stipulated in relevant legislation are adhered to. Atmospheric Licensing Authority – Competent Authority Clarification on the competent Atmospheric Licensing Authority is required.

DEA confirmed that they are the competent authority in terms of the Atmospheric Emission Licensing.

Preliminary Atmospheric Emission Licence Application The preliminary AEL application incompleteness will be addressed and will be resubmitted containing the correct information once confirmation on the competent Atmospheric Licensing Authority has been received.

The form submitted was a provisional form and it was submitted only to receive a reference number. The application form is currently being compiled and on completion will be submitted online via SAAELIP.

Dioxins and Furans The EIA Report and the EMPr must address the possible mitigation measures if waste other than abattoir waste is incinerated within the proposed incinerator.

No other waste will be incinerated at this facility other than abattoir waste. Measures for prevention of incineration of other waste types have been included in the EMPr Section 2.4

Disposal of Incinerator Ash The proposed mixture of ash with manure and used as fertilizer as indicated in the Draft EIA report should only be approved if an application for delisting of the ash as hazardous waste has been successful.

The EMPr Section 2.4.1 and 2.4.2 states - ash from the incinerator must be appropriately disposed of at a licensed waste management facility. The incinerator ash will not be mixed with manure and used as fertilizer.


Directorate: Waste Management Contact: Marius Venter It is recommended that the separation of infectious and non-infectious animal parts take place at the abattoir to prevent cross contamination. Infectious animal parts are regarded as hazardous waste while non-infectious parts are regarded as general waste. The Draft EIR states that the proposed incinerator will be used mainly for the thermal treatment of diseased animal carcasses and treatment of animal parts not suitable for the human consumption. It further states that any animal parts that will not be incinerated will be removed by a private contractor for re-use in other industries. 1. Please indicate whether the incinerator will treat both infectious

and non-infectious animal carcasses (and not only “diseased animal carcasses”).

2. GN No. R. 636 (National Norms and Standards for the Disposal of Waste to Landfill) dated 23 August 2013, promulgated in terms of Section 7(1)(c) of the NEM:WA, 2008 (Act No. 59 of 2008). Regulation 4(2) states that non-infectious animal carcasses may only be disposed of at a class B waste disposal facility or at one designed in accordance with the requirements for a GLB+ waste disposal facility as specified by DWAF – Minimum Requirements for Waste Disposal by Landfill (2nd Edition, 1998). If non-infectious animal carcasses are not incinerated may not be disposed of on-site and must be disposed of at a waste disposal facility suitable to accept such waste.

3. Regulation 5(1) of GN No. R636 identify wastes that are prohibited or restricted in terms of disposal. This regulation prohibits the disposal of infectious animal carcasses and animal waste to land. Infectious animal carcasses must be treated before they can be disposed of at a class B waste disposal facility.

Department of Environmental Affairs and Development Planning Directorate: Development Facilitation Contact: Adri La Meyer Date: 14 December 2015 The following is a compilation of comments received from different directorates within the DEA&DP on the Draft EIA report

The incinerator will treat both infectious and non-infectious carcasses. They will not be separated prior to incineration as this will not be practical.

The proposal to incinerate infectious animal carcasses and animal waste is supported by this Directorate.

Directorate: Waste Management Contact: Marius Venter

Noted.


GN No. 921 promulgated in terms of Section 19(2) of the NEM:WA identifies waste management activities likely to have a detrimental effect on the environment. This Directorate anticipates that a very small percentage of the total volume of abattoir waste will be infectious (i.e. hazardous). The applicant has applied for the authorization of the listed activity identified in Category B 4(4) of GN No. 921, being “The treatment of hazardous waste in excess of 1 ton per day calculated as a monthly average; using any form of treatment excluding the treatment of effluent, wastewater or sewage”. If infectious animal carcasses are separated from non-infectious carcasses and incinerated separately, then the activity identified in Category B 4(4) of GN No. 921 would not be applicable. It is more likely that the activity listed in Category A 3(7) of GN No. 921 “The treatment of hazardous waste using any form of treatment at a facility that has the capacity to process in excess of 500 kg but less than 1 ton per day, excluding the treatment of effluent, wastewater or sewage” would be more applicable if infectious and non-infectious animal carcasses are incinerated separately.

Incineration of both infectious and non-infectious animal carcasses will take place on site. No abattoir waste will be disposed of to landfill. The infectious and non-infectious abattoir waste will not be separated prior to incineration. Thus, the correct activity has been applied for.

Category C 5(2) (storage of hazardous waste) does not require a waste management licence, but the applicant only needs to comply with the requirements of GN No. 926 of 29 November 2013 (Norms and Standards for Storage of Waste).

The applicant will comply with the Norms and Standards for the Storage of Waste and adhere to Section 2.4.1 of the EMPr stating the operational procedure on handling of waste. All waste management activities, such as handling of waste, will be conducted on impermeable surfaces.

GN No. 926 of 29 November 2013 further governs the storage of general waste at a facility that has the capacity to store in excess of 100m3 of general waste. Should the applicant meet the threshold requirements of this Norm and Standard, then compliance with the GN. 926 is required, including registration with the relevant authority.

Noted.

All abattoir waste is to be stored in leak proof containers with closable lids prior to disposal.

Directorate: Waste Management Contact: Marius Venter

All abattoir waste will be stored in appropriate cold rooms at the abattoir adjacent to the incinerator. It is then transported manually from the cold


rooms in plastic bins directly to the incinerator, where it is fed (again manually) into the incinerator. The plastic bins will be leak proof and have closable lids.

Confirmation on the treatment of blood, fat and feather. Will it be incinerated?

The applicant has confirmed the following: The blood and feathers will not be incinerated at the proposed facility. Only fat will be incinerated with the abattoir waste. Blood (minimal) from the abattoir process will be discharged to the septic tanks. Maximum 1 to 2 drums per day. It has been proposed that the feathers will be mixed with manure and used as fertilizer on the land within the Drakenstein Correctional Facility.

Clarity on disposal of waste water. The waste (wash) water from the incinerator area will be discharge to concrete septic tanks situated adjacent to the abattoirs.

General waste that cannot be recovered must be disposed of at a licensed waste disposal facility. Covered skips/bins should be available on site for the temporary storage of this waste.

Covered skips/bins will be available on site for the temporary storage of general waste.

Draft Lifecycle EMPr to include impact of spillage/leakage of product to the environment. EMPr to identify mitigation measures to address potential spills, including staff training, reporting of spillages to authority (Pollution & Chemical).

Operational Management impacts are located in Section 2.4 of the EMPr.


Waste, chemicals and fuels must be stored in secure areas with impermeable surfaces. All chemicals and fuel must be stored in a bunded area and be able to accommodate 110% of the volume.

All waste, chemicals and fuels will be securely store onsite on an impermeable surface. Chemicals and fuels will be stored in a bunded area.

All waste management activities, including waste handling at the incinerator area, must be conducted on impermeable surfaces.

The handling of abattoir waste will only take place on an impermeable surface within the incinerator area.

The incineration of domestic waste on the site is not allowed. No other waste (i.e. domestic waste) will be incinerated at this facility other than abattoir waste. This has been stated in the Final EIAR in Section 7.3. and in the EMPr Section 2.4

Directorate: Air Quality Management Contact: Peter Harmse The National Dust Control and Provincial Noise Control Regulations are to be adhered to.

Directorate: Air Quality Management Contact: Peter Harmse

All recommendations with regards to Air Quality are contained in the EMPr. They will be implemented accordingly and adhered to by the contractor and the applicant.

Application form for provisional registration of listed activities in respect of NEM:AQA, submitted to Cape Winelands District Municipality, is incomplete. Provide clarity on the licensing authority for the AEL application.

The form submitted was a provisional form and it was submitted only to receive a reference number. The application form is currently being compiled and on completion will be submitted online via SAAELIP.

All recommendations made by Airshed Planning Professionals in the Air Quality Impact Assessment Report dated August 2012, must be implemented. Incinerator supplier to demonstrate that Category 8.2 Emission

Limits will not be exceeded. Possible installation of gas cleaning equipment.

Regular stack monitoring to be implemented. Frequency of monitoring to be agreed by the appropriate licencing authority.

Best practice measures to be implanted to minimize or avoid odours emitted from incinerator feed material.

All recommendations with regards to Air Quality are contained in the EMPr will be implemented accordingly and adhered to by the contractors and the applicant.


Directorate: Development Management Contact: Lorretta Osborne Final EIR should also include reference to activities listed in terms of the 2010 EIA Regulations.

Directorate: Development Management Contact: Lorretta Osborne

The Final EIR has been amended accordingly.

Draft EIR refers to a Section 24G rectification process to be followed. Please be advised that the application does not include a Section 24G application.

Final EIR amended accordingly.

There is a discrepancy between the operational hours in different sections of the DEIR. What are the operational hours for the proposed incinerator?

As per the comments: Section 6.1 indicates that the recommended operating hours to be 10 hours per day. Section 9.4.2 states the assumptions and limitations applied to the air quality impact assessment undertaken by Airshed in 2012 and updated in 2015, where it was assumed that the current operations were to be twenty-four hours over a 365 day year in order to model a “continuous” process as well as preserve the most conservative modelling approach. The operational hours of the proposed incinerator will be from 09h00 to 14h00 from Monday to Friday and 09h00 to 12h00 on Saturdays.

What will the noise impact be during the operational phase? Operational phase noise impacts and mitigation measures can be found in Section 2.4.3 of the EMPr.

Recommendations and mitigation measures contained in the specialist studies must be included in the Revised EMPr.

Noted.

Directorate: Pollution and Chemicals Management Contact: Xenthia Smith The Soil and Groundwater Contamination assessment report dated February 2013 does not indicate what the potential source

Directorate: Pollution and Chemicals Management Contact: Xenthia Smith

The water quality for the area is generally poor and not suitable for irrigation purposes due to various parameters exceeding the guideline levels for irrigation (high natural


of poor groundwater quality is. Once identified this must be addressed in the Final EIAR.

mineral contact etc), as stated in the Groundwater Contamination Assessment Report.

Piezometers must be installed up-gradient and down-gradient of the septic tanks in order to monitor for any leakages. Monitoring must be conducted twice a year. Monitoring results are to be reported to Pollution and Chemicals Management as well as DWS.

Monitoring wells will be installed up-gradient and drown-gradient of the septic tanks and monitoring will be carried out twice a year. The report will be submitted to Pollution and Chemical Management and DWS.

Indicate where the final effluent from the existing waste water treatment plant will be released to and whether any monitoring is being conducted prior to the release.

The final effluent is discharged into the Berg River and monitoring of the effluent is conducted every day prior to its release.

Directorate: Development Facilitation Contact: Adri La Meyer The correct AEL application number reference to be confirmed.

Directorate: Development Facilitation Contact: Adri La Meyer

The correct AEL reference number is the CWDM AEL Application reference number (7973879).

Impact statement in executive summary incorrect. Must amend to reflect that the two historic incinerators are no longer operational and that the applicant intends to construct a new incinerator.

Final EIR amended accordingly.

Waste Management hierarchy must be referenced correctly. Final EIR amended accordingly.

Final EIAR must state that no water use authorization is required, as per the freshwater specialist recommendations.

The FEIAR has been amended accordingly.

It is noted that the freshwater specialist recommends a 50m buffer area around freshwater ecosystems during the construction phase of the proposed incinerator.

A 50m buffer area will be maintained throughout the construction phase of the proposed development. This recommendation from the freshwater specialist has been inserted into the EMPr and will be adhered to by the contractor.


Freshwater specialist recommendation - No manure and ash residue mixture should be applied to land within 100m of any freshwater ecosystem to reduce the risk of organic matter washing or leaching into river or wetland ecosystem.

The EMPr Section 2.4.1 and 2.4.2 states - ash from the incinerator must be appropriately disposed of at a licensed waste management facility. The incinerator ash will not be mixed with manure and used as fertilizer.

EMPr (Statutory obligations) must be amended to include NEM:AQA as a relevant legislation.

The EMPr has been amended accordingly.

EMPr (Waste Management) states that chemical toilet facilities must be located away from the sensitive freshwater ecosystems, ideally at least 20m from the Riviersonderend River and 10m away from the remaining freshwater ecosystems. It is assumed that the river system is the Berg (and not Riviersonderend River). A buffer area of 50m from the freshwater ecosystems must be maintained.

The river system is the Berg River. A 50m buffer area from the freshwater ecosystems will be enforced.

The following is the Department of Environmental Affairs (Chemicals and Waste Management) comments on the Draft EIA report:

1. Waste Classification and Management Regulations and associated Norms and Standards must be considered.

2. All comments and correspondence raised by I&APs to be incorporated into the Final EIAR.

3. Final EIAR to contain all information set out in Appendix 3 of the GN 982 of 4 December 2014.

4. The activity may not commence prior to a waste management licence being granted by the Department.

Department of Environmental Affairs – Chemicals and Waste Management Contact: Mpho Rabambi Date: 14 January 2016

All comments have been noted.

4) Summary Table of Public Participation Activities

Drakenstein New Incinerator Installation Summary of the Public Participation Process to Date

Initial Notification Phase and Review of Draft Scoping Report Item Date Comment

Submission of Application Form to DEA for Integrated EIA and Waste Licence Application

28/12/2012 14 day period allowed for

Written approval from DEA to proceed with Scoping and EIA

19/02/2013

Submission of preliminary Application Form for AEL to Cape Winelands District Municipality (CWDM)

April 2013

Receipt of file reference number form CWDM

08/04/2013

Identification of interested and affected parties (i.e. adjacent landowners; NGO’s and ratepayers’ associations; relevant Organs of State)

2013

Posting of registered letters of notification to identified I&AP’s

25/11/2013

Newspaper adverts published the Bolander and Paarl Post local newspapers

28/11/2013

Site notices erected at site entrance and hand delivery of notification to adjacent parties where postal address is unknown.

27/11/2013

Draft Scoping Report posted on the SEC website and delivered to the Paarl public library

27/11/2013

40 day period for initial stakeholder notification and review of Draft Scoping Report

27/11/2013 – 03/02/2014

Posting of registered letters of notification of FSR availability to identified I&AP’s

08/06/2015

Final Scoping Report posted on the SEC website and delivered to the Paarl public library

08/06/2015

21 day period for public review of Final Scoping Report

12/06/2015 – 03/07/2015

Final Scoping Report Accepted and to proceed with EIA

15/07/2015

Draft EIA posted on the SEC website 09/11/2015 30 day period for public review of Draft EIR

12/11/2015 – 11/12/2015

5) Copies of Comments and Responses

1

global

From: Marius Engelbrecht <[email protected]>

Sent: 23 January 2014 01:37 PM

To: Colleen McCreadie

Cc: [email protected]; Hans Linde ([email protected])

Subject: RE: Upgrade of incinerator at Drakenstein Correctional Facility

Follow Up Flag: Follow up

Flag Status: Flagged

Categories: Red Category

Good Day Colleen

With reference to the Draft Scoping Report and preliminary Atmospheric Emission License (AEL) Application for the

upgrade of incinerators at Drakenstein Correctional Facility.

There are uncertainty within this report as the authors of the reports differ on the number and size of

incinerator/incinerators to be installed. The report refer to one large incinerator to replace the two current

incinerators. Reference are also made within the report to two replacement incinerators namely a red meat

incinerator that can burn at a maximum rate of 233 Kg/hour and a white meat incinerator to burn at maximum rate

of 353 kg/hour.

It must be noted that the amendments to Section 21 of the NEMA: Air Quality Act, GN 893 of 22 November 2014

places the incinerator for burning of veterinary waste under a new sub-category, Subcategory 8.2: Crematoria and

Veterinary Waste Incineration. The report and preliminary AEL application still refer to the incinerator for veterinary

waste under GN 248 of 31 March 2010 as Category 8 activities: Disposal of Hazardous Waste and General Waste.

The GN 248 of 31 March 2010 had Category 8 renamed to Category 8: Thermal Treatment of Hazardous and

General Waste and subdivided in more sub-categories such as Subcategory 8.1: Thermal Treatment of General and

Hazardous Waste and Subcategory 8.2: Crematoria and Veterinary Waste Incineration.

The authors refer to the possibility of dioxins and furans in the proposed incinerator emissions. Under a new sub-

category, Subcategory 8.2: Crematoria and Veterinary Waste Incineration no reference are made to dioxins and

furans Should dioxins and furans be present in your abattoir waste, the Scoping Report and AEL application should

place this listed activity under Subcategory 8.1: Thermal Treatment of General and Hazardous Waste with the

different applicable parameters to be monitored.

The Atmospheric Emission License Application will be seen as a new application, as the existing incinerators did not

have a registration certificates issued in terms of the Atmospheric Pollution Prevention Act, 1965 (Act 45 of 1965).

As the status of the incinerator will be for a new plant and the compliance emission monitoring for substances will

be according to that of a new plant within the amended Section 21 listed activities legislation, GN 893 of 22

November 2014.

The above-mentioned detail was discussed with Mr Peter Harmse at the DEA&DP Provincial office and it seems

necessary to discuss these uncertainties in detail before the Draft Scoping Report could be fully considered.

Regards

Marius Engelbrecht

Air Quality Officer/Environmental Health Practition er

tel: (021) 888 5811

2

sel/cell: 072 1225680

faks/fax: (021) 887 9365

e-pos/e-mail: [email protected]

“Yesterday is history, Tomorrow is a mystery. And Today?”

“Today is a gift. That's why we call it the present.”

From: Colleen McCreadie [mailto:[email protected]]

Sent: 28 November 2013 08:34 AM

To: Marius Engelbrecht Subject: RE: Upgrade of incinerator at Drakenstein Correctional Facility

Dear Marius

Definitely November, not July, sorry!!

And CWDM is automatically a registered party, so no need to register formally, thanks.

Take care

Kind regards

"Environmental Solutions for a Changing World"

Colleen McCreadie – Environmental Consultant

P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]

www.environmentalconsultants.co.za

Suite 105, Block B2, Tokai Village Centre, Vans Road, Tokai, Cape Town, 7966

From: Marius Engelbrecht [mailto:[email protected]]

Sent: 27 November 2013 02:38 PM To: Colleen McCreadie


Afternoon Colleen

3

With reference to the PPP for Drakenstein Crematorium. Is this correspondence seen as myself being an registered

stakeholder or should I still register.

In your e-mail you mentioned the hard copy and CD of the Draft Scoping Report will be couriered to our office on

the 29th

July, could that be the 29th

November 2013?.

Regards

Marius Engelbrecht


tel: (021) 888 5811

sel/cell: 072 1225680

faks/fax: (021) 887 9365





Sent: 27 November 2013 01:59 PM

To: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected];

Marius Engelbrecht Subject: Upgrade of incinerator at Drakenstein Correctional Facility

Dear Registered Stakeholders

PUBLIC PARTICIPATION PROCESS FOR INCINERATOR OPERATIONS AT THE DRAKENSTEIN CORRECTIONAL FACILITY,

PAARL, WESTERN CAPE

SEC Project Number: 0100812

DEA Integrated Application Reference Number: 12/9/11/L1176/9

CWDM Atmospheric Emissions Licence Reference Number: 7973879

A hard copy and a CD copy of the Draft Scoping Report for the above application will be couriered to your offices to

arrive by Friday 29th

July for review and comment.

Please can all comments be received by SEC by no later than 03/02/2014.

Kind regards

4



P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]



1

global

From: Colleen McCreadie

Sent: 04 February 2014 08:41 AM

To: 'Marius Engelbrecht'

Cc: [email protected]; Hans Linde ([email protected]);

Lucian Burger ([email protected]); Tom Esterhuizen ([email protected])


Dear Marius

Thank you for the detailed feedback as below.

We need to address the matter of the new list of air quality activities, and the associated minimum emissions

standards and monitoring protocol.

At this stage, we suggest that we liaise with the air quality specialists, Airshed, and amend both their and our reports

where needed. We can then include the amendments in the Final Scoping Report, which we can then submit for

feedback by stakeholders in due course.

In the Final Scoping Report, we will also ensure that there is clarity on the capacity of the single new incinerator

which is being proposed.

In terms of the administration of the AEL application, may we just submit an electronic copy of the preliminary form

with the new activity/ies included for the purposes of your records?

Thank you

Kind regards



P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]




Sent: 23 January 2014 01:37 PM To: Colleen McCreadie

Cc: [email protected]; Hans Linde ([email protected])


Good Day Colleen

2

With reference to the Draft Scoping Report and preliminary Atmospheric Emission License (AEL) Application for the

upgrade of incinerators at Drakenstein Correctional Facility.

There are uncertainty within this report as the authors of the reports differ on the number and size of

incinerator/incinerators to be installed. The report refer to one large incinerator to replace the two current

incinerators. Reference are also made within the report to two replacement incinerators namely a red meat

incinerator that can burn at a maximum rate of 233 Kg/hour and a white meat incinerator to burn at maximum rate

of 353 kg/hour.

It must be noted that the amendments to Section 21 of the NEMA: Air Quality Act, GN 893 of 22 November 2014

places the incinerator for burning of veterinary waste under a new sub-category, Subcategory 8.2: Crematoria and

Veterinary Waste Incineration. The report and preliminary AEL application still refer to the incinerator for veterinary

waste under GN 248 of 31 March 2010 as Category 8 activities: Disposal of Hazardous Waste and General Waste.

The GN 248 of 31 March 2010 had Category 8 renamed to Category 8: Thermal Treatment of Hazardous and

General Waste and subdivided in more sub-categories such as Subcategory 8.1: Thermal Treatment of General and

Hazardous Waste and Subcategory 8.2: Crematoria and Veterinary Waste Incineration.

The authors refer to the possibility of dioxins and furans in the proposed incinerator emissions. Under a new sub-

category, Subcategory 8.2: Crematoria and Veterinary Waste Incineration no reference are made to dioxins and

furans Should dioxins and furans be present in your abattoir waste, the Scoping Report and AEL application should

place this listed activity under Subcategory 8.1: Thermal Treatment of General and Hazardous Waste with the

different applicable parameters to be monitored.

The Atmospheric Emission License Application will be seen as a new application, as the existing incinerators did not

have a registration certificates issued in terms of the Atmospheric Pollution Prevention Act, 1965 (Act 45 of 1965).

As the status of the incinerator will be for a new plant and the compliance emission monitoring for substances will

be according to that of a new plant within the amended Section 21 listed activities legislation, GN 893 of 22

November 2014.

The above-mentioned detail was discussed with Mr Peter Harmse at the DEA&DP Provincial office and it seems

necessary to discuss these uncertainties in detail before the Draft Scoping Report could be fully considered.

Regards

Marius Engelbrecht


tel: (021) 888 5811

sel/cell: 072 1225680

faks/fax: (021) 887 9365




3


Sent: 28 November 2013 08:34 AM To: Marius Engelbrecht


Dear Marius

Definitely November, not July, sorry!!

And CWDM is automatically a registered party, so no need to register formally, thanks.

Take care

Kind regards



P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]




Sent: 27 November 2013 02:38 PM

To: Colleen McCreadie Subject: RE: Upgrade of incinerator at Drakenstein Correctional Facility

Afternoon Colleen

With reference to the PPP for Drakenstein Crematorium. Is this correspondence seen as myself being an registered

stakeholder or should I still register.

In your e-mail you mentioned the hard copy and CD of the Draft Scoping Report will be couriered to our office on

the 29th

July, could that be the 29th

November 2013?.

Regards

Marius Engelbrecht


tel: (021) 888 5811

sel/cell: 072 1225680

4

faks/fax: (021) 887 9365





Sent: 27 November 2013 01:59 PM To: [email protected]; [email protected]; [email protected];

[email protected]; [email protected]; [email protected]; [email protected];

Marius Engelbrecht Subject: Upgrade of incinerator at Drakenstein Correctional Facility

Dear Registered Stakeholders

PUBLIC PARTICIPATION PROCESS FOR INCINERATOR OPERATIONS AT THE DRAKENSTEIN CORRECTIONAL FACILITY,

PAARL, WESTERN CAPE


DEA Integrated Application Reference Number: 12/9/11/L1176/9


A hard copy and a CD copy of the Draft Scoping Report for the above application will be couriered to your offices to

arrive by Friday 29th

July for review and comment.

Please can all comments be received by SEC by no later than 03/02/2014.

Kind regards



P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]



1

global

From: Beverley Barry <[email protected]>

Sent: 10 July 2015 03:18 PM

To: Sukie Paras

Cc: [email protected]

Subject: COMMENTS ONT THE FINAL SCOPING REPORT FOR APPLICATION FOR A WASTE

LICENSE, ATMOSPHERIC EMISSIONS LICENSE AND ENVIRONMENTAL

AUTHORISATION FOR THE INSTALLATION OF AN INCINERATOR AT THE

DRAKENSTEIN CORRECTIONAL FACILITY NEAR PAARL, WESTERN CAPE

Attachments: SKM_C554e15071015140.pdf

Good Afternoon

Kindly find the attached documents for your attention.

Kind regards,

Beverly Barry

Personal Assistant to the Director: Air Quality Management

Department of Environmental Affairs and Development Planning

Western Cape Government

02nd Floor, Property Centre, 01 Dorp Street, Cape Town

Tel: 021 4832888

Fax: 021 4833254

E-mail: [email protected]

Website: www.westerncape.gov.za/eadp

"All views or opinions expressed in this electronic message and its attachments are the view of the sender and do not necessarily

reflect the views and opinions of the Western Cape Government (the WCG). No employee of the WCG is entitled to conclude a

binding contract on behalf of the WCG unless he/she is an accounting officer of the WCG, or his or her authorised representative. The

information contained in this message and its attachments may be confidential or privileged and is for the use of the named recipient

only, except where the sender specifically states otherwise. If you are not the intended recipient you may not copy or deliver this

message to anyone."

1

global

From: Zinhle Mbili <[email protected]>

Sent: 16 July 2015 07:38 AM

To: Sukie Paras

Subject: FW: Drakenstein Correctional Facility Incinerator Application

Attachments: Acceptance Letter Drakenstein.pdf

From: Zinhle Mbili

Sent: 15 July 2015 02:48 PM

To: Zinhle Mbili

Subject: RE: Drakenstein Correctional Facility Incinerator Application

Dear Sukie

Kindly receive the attached letter.

Regards

From: Zinhle Mbili

Sent: 24 June 2015 10:35 AM

To: Sukie Paras

Subject: RE: Drakenstein Correctional Facility Incinerator Application

Hi Sukie

Don't worry, I am sorted.

Regards

>>> Sukie Paras <[email protected]> 2015/06/24 08:22 AM >>>

Good day Zinhle,

Thank you for your response. I will unfortunately not be in the office tomorrow and Friday, as I will be attending

lectures. I will however be available on my mobile number at 084 409 8163 during our tea break between 10h00 –

10h30, or lunch break from 12h15 – 13h15.

Apologies for the inconvenience.

Kind regards

Sukie

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

"Environmental Solutions for a

Sukie Paras P: +27 (0) 10 590 9400

M: +27 (0) 84 409 8163

F: +27 (0) 21 712 5061

[email protected]


PostNet Suite 570, Private Bag X29, Gallo Manor, 2052

2

Changing World"

From: Zinhle Mbili [mailto:[email protected]]

Sent: 23 June 2015 11:20 AM

To: Sukie Paras Subject: Re: Drakenstein Correctional Facility Incinerator Application

Dear Sukie

Apologies Sukie, I am back in the office tomorrow. I will contact you.

Regards

>>> Sukie Paras <[email protected]> 2015/06/22 02:43 PM >>>

Good day Ms Mbili,

Please note as per the message to contact you, I have attempted calling your office and also left a voice message.

Please can you kindly let me know your query via email so that I may address it. I will however continue to try to

contact you telephonically.

Kind regards

Sukie



Sukie Paras P: +27 (0) 10 590 9400

M: +27 (0) 84 409 8163

F: +27 (0) 21 712 5061

[email protected]


PostNet Suite 570, Private Bag X29, Gallo Manor, 2052

From: Reception

Sent: 18 June 2015 10:55 AM

To: Sukie Paras

Subject: tele msg

Hi Sukie

Please phone Zinhle Mbili re Drakenstein application

(012) 3999785

Regards

Charlene


"Environmental Solutions for a

Charlene Solomon P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

[email protected]


Suite 105, Block B2, Tokai Village Centre, Vans Road, Tokai,

3

Changing World" Cape Town, 7966

This message and any attachments transmitted with it are intended solely for the addressee(s) and may be legally

privileged and/or confidential. If you have received this message in error please destroy it and notify the sender. Any

unauthorized usage, disclosure, alteration or dissemination is prohibited. The Department of Environmental Affairs

accepts no responsibility for any loss whether it be direct, indirect or consequential, arising from information made

available and actions resulting there from. The views and opinions expressed in this e-mail message may not

necessarily be those of Management.

This message and any attachments transmitted with it are intended solely for the addressee(s) and may be legally privileged and/or confidential. If you have received this message in error please destroy it and notify the sender. Any unauthorized usage, disclosure, alteration or dissemination is prohibited. The Department of Environmental Affairs accepts no responsibility for any loss whether it be direct, indirect or consequential, arising from information made available and actions resulting there from. The views and opinions expressed in this e-mail message may not necessarily be those of Management.

c. Draft EIA Phase

6) Proof of Public Participation Undertaken

op Tafelberg is waarmee dieinwoners van die maan gesienkon word; vlermuis-agtige mensewat onder andere buffels opgraslande gejag het en ja, die ouliegstorie oor Van Hunk serokery word ook vermeld.

Wat wel waar is, is dat daar indie 1950s ’n wilde perd daar bogevind is. Manuel meld dat toedie kabelkarretjie in 1929 ingebruik geneem is, mense geklahet dat die horison geskend isdeur “die puisie” wat natuurlikdie kabelkar se “huisie” is.

Manuel vertel van die geluidvan die vishoring – wat ek selfkan onthou – wat weggesterf heten die gevierde hond Just Nui-sance (sy standbeeld bestaandarem nog) en dat daar selfseenmaal ’n tolhek was waar SirLowry- en Victoria- en Sear-lestraat byeenkom.

So, niks nuut onder die son ...en die opelugkonserte deurorkeste en die ou teater, dieTivoli op die kruising van Dar-ling- en Pleinstraat, waaraan die

spotprenttekenaar DC Boon-zaier ook baie geskryf het – beidein sy dagboeke en as resensent inkoerante. Straatname wordbespreek, duidelik altyd ’nkwessie en dat Kaapstad self eens“Cape Grab” genoem is omdatdie herbergiers (toe die stad ookbekend was as “the Tavern of theseas” ) so inhalig was.

Manuel wys foto’s van die ouKloktoring by die hawe teen1900 waar die kabelkar ook nognie teen die berg sigbaar was nie,van die besige skeepsbedryf, vandie hawehoof in al sy glorie, vandie klassieke toegangspoort byGoewermentslaan wat lankal totniet is, van die trems en selfs datpikkewyneiers so volop sooshoendereiers was.

Hy skryf dat daar teen 1950nog vier tweewielwaentjies(“Hansom Cabs”) in gebruik wasin die sogenaamde Maleierbu-urt, maar dat daar eens ongeveer200 sulke perdewaens in die stadrondgekletter het.

Manuel sê tereg dat ’n stad

meer is as oudhede en geboue;dat die menslike element groot-liks bydra tot die atmosfeer enkarakter daarvan. So was daarakrobate, violiste harp- endraaiorrelspelers met fez-draende apies, en ook die eksen-trieke Jan Greyling met sy beson-der lang neus wat altyd sy vioolgespeel het wanneer ‘n gebouafbrand.

Sielkundiges sal seker sê hyhet ‘n Nero-kompleks gehad!Dan was daar ook mans wat soosCharlie Chaplin uitgedos was enby die hawe rondgeparadeer het.Interessant is ook dat munisipaleverkiesings soos nuwejaarspa-rades was – die optredes vanorkeste wat kleurvolle rosettegedra het is deur groot skaresgeniet, want vir ongeveer 80 jaarlank was dit tradisie dat werkgew-ers hulle personeel verlof gegeehet om die feestelikhede by tewoon.

Niemand wat egter vandagnog leef kan sê hy of sy het al diegebeure wat Manuel beskryfbeleef het nie – heelwat daarvanhet meer as 100 jaar gelede al uit-gesterf.

Tog is daar ook genoeg daar-van wat mens wel kan onthou asjy darem al self oor die halfeeumerk is en daarom ontlok dieinhoud van hierdie boek beidenostalgie en “historiese belang-stelling” van die akademiesesoort.

Nietemin, een ding is sekeroor nostalgie: dis soos ’n oumuntstuk. Die eerste maal wat jydit verloor, is jy spyt.

Maar dekades later is jou spytpersoonlik meer werd en die ver-lies veel groter.

HISTORY BolanderWednesday November 27 20134

ALL PRICES QUOTED ARE FOR A SINGLE RESIDENTIAL PROPERTY

UNDER NEW MANAGEMENT

OM\04\09308344

R350-00 excl vat

Gas Inspection

R399-00excl vat

Beetle and Electrical Inspection

R350-00 excl vat

PlumbingInspection

www.electrabug.co.za Tel: 021 851 7423 [email protected]

ELECTRIC FENCING INSPECTION R450-00 excl vat

NOTICE OF A MEETING OF THE COUNCIL

OF THE CITY OF CAPE TOWN

A meeting of the Council of the City of Cape Town will be held on

Wednesday 4 December 2013 at 10:00 in the Council Chamber, 6th floor,

Podium Block, Civic Centre, 12 Hertzog Boulevard, Cape Town.

Please note that limited seating is available in the public gallery of the

Council Chamber and, therefore, seats will be allocated on a first come, first

served basis. If you wish to attend the meeting, you are requested to contact

Michelle Alberts on 021 400 3708 between 09:00-16:00. All requests for

attendance must be received by no later than a day before the meeting. You

will be required to provide your surname, initials

and contact telephone number. Visitors are

kindly requested to be seated by 09:30.

ACHMAT EBRAHIM

CITY MANAGER

PUBLIC PARTICIPATION PROCESS FOR INCINERATOR OPERATIONS

AT THE DRAKENSTEIN CORRECTIONAL FACILITY, PAARL, WESTERN CAPE


DEA Integrated Application Reference Number: 12 / 9 / 11 / L1176 / 9


Introduction and project description

Sillito Environmental Consulting (SEC) has been appointed as the independent Environmental

Assessment Practitioner (EAP) to undertake a Scoping / EIA - type application process on behalf of

the Department of Public Works (DPW). The process is being undertaken to ensure the legal

compliance of the upgrade of two oil - fired incinerators at the Drakenstein Correctional Facility in Paarl.

Legislative context

The proposed upgrade of the incinerators triggers the following activities listed in terms of the

prevailing national environmental legislation and regulations:

• Activity 26 of Government Notice No. R546 of the EIA Regulations, published in 2010 in terms

of the National Environmental Management Act, Act No. 107 or 1998, as amended.

• Category A, Activity 2; and Category B, Activities 8 and 11 of the list of waste management

activities contained in Government Notice No. 718 of 2009 published in terms of the National

Environmental Management: Waste Act, Act No. 59 of 2008 (NEMWA); and

• Category 8: Disposal of hazardous and general waste contained in the Minimum Emission

Standards contained in Government Notice No. 248 of 2010 published in terms of the National

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

An integrated application for Environmental Authorisation and for a Waste Licence; as well as an

application for an Atmospheric Emissions Licence therefore needs to be applied for from the relevant

competent environmental authorities.

Registering as an Interested and Affected Party

If you would like to register as an interested and affected party (I&AP), please do so in writing, giving

your name and full contact details as well as an indication of any direct business, financial, personal

or other interest that you may have in relation to this proposal. Please quote the SEC Project Number

provided above in all your correspondence. Contact details are as follows:

Colleen McCreadie

Environmental Consulting cc

P O Box 30134, Tokai, 7966

Tel: (021) 712 5060; Fax: (021) 712 5061

E-mail: [email protected]

Registering as an I&AP will entitle you to further project information, to be kept informed of project

progress and provide you with an opportunity to comment on all reports produced when they

become available for public review. At this stage, the Draft Scoping Report is available for review

and comment. Copies have been placed in the Paarl Public Library, Market Street, Paarl

(tel: 021 807 4871). Opening hours are:

Monday, Wednesday and Thursday: 9am to 7pm

Wednesday: 12pm to 7pm

Friday: 9am to 5:30pm

Saturday: 9am to 12:30pm

The report is also available for download on the SEC website:

www.environmntalconsultants.co.za.

Responses (by fax, post or email) from any interested party should be received by

SEC within 40 calendar days of publication of this notification

(that is, no later than 01 / 02 / 2014)

OM

/ 0

1 / 9

457776

Nostalgie, lees ek onlangs in diemedia, is tipies ná “ingrypendesosiale verandering, soos wat

die afgelope 20 jaar in Suid-Afrikabeleef is.” Dit hang sekerlik af wie tersprake is indien mens wonder waarnaterugverlang word.

Ek onthou dat ek sowat tien jaargelede na ’n toespraak geluister hetvan ’n oud-inwoner van Distrik Ses. Dieman was (toe al) ouerig en die enigsteeen daar wat in daardie omstredebuurt gewoon het.

En toe hy die name van etlikemense van daardie tyd en plekopnoem het almal verveeld rondgekyk.

Toe hy uiteindelik in trane uitbars,het die gehoor ongemaklikrondgeskuif. Daar was simpatie, maarnie empatie nie – want empatie vereis’n gedeelde ervaring.

Daaraan is ek herinner toe ekGeorge Manuel se boek I remember CapeTown (uitgegee deur Don Nelson,1977) gelees het. Talle historiese foto’s

is afgewissel met pikante illustrasiesdeur die bekende spotprenttekenaarTony Grogan, wat bydra tot die nostal-gies-historiese atmosfeer wat die boekvan 111 bladsye optower.

Manuel, wat onder andere ’n joer-nalis was, is in 1915 in Johannesburggebore, maar die insig en deerniswaarmee hy die verhaal van die moed-erstad vertel getuig van werklike liefdevir beide die stad en sy mense.

Hy het duidelik ook navorsinggedoen, soos oor die legendes aan-gaande Tafelberg – hy noem bv. “diegroot maan-bluf.”

In die New York Daily Sun is ’n sto-rie geskryf dat daar ’n reuse teleskoop

Nostalgie is net soos ’n ou munt■ Voorbladvan IrememberCape Town,wat my net R 120 in ’nRichmondseboekwinkelgekos het.

c. Draft EIA Phase

1

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From: Microsoft Outlook

To: Nomhle Magwaca


Subject: Delivered: Draft Environmental Impact Report-Drakenstein correctional facility, Erf

899& 894 Paarl

Your message has been delivered to the following recipients: Nomhle Magwaca ([email protected]) Subject: Draft Environmental Impact Report-Drakenstein correctional facility, Erf 899& 894 Paarl

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From: Microsoft Outlook

To: [email protected]; [email protected];

[email protected]; [email protected];

[email protected]; [email protected]; [email protected]


Subject: Relayed: Draft Environmental Impact Report-Drakenstein correctional facility, Erf

899& 894 Paarl

Delivery to these recipients or groups is complete, but no delivery notification was sent by the destination server: [email protected] ([email protected]) [email protected] ([email protected]) [email protected] ([email protected]) [email protected] ([email protected]) [email protected] ([email protected]) [email protected] ([email protected]) [email protected] ([email protected]) Subject: Draft Environmental Impact Report-Drakenstein correctional facility, Erf 899& 894 Paarl

APPENDIX C - Sillito Environmental · PDF [email protected] Tel: 082 925...

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Transcript of APPENDIX C - Sillito Environmental · PDF [email protected] Tel: 082 925...