APPENDIX G - CSIRfred.csir.co.za/.../smelter/eia_final_appendix_g... · Appendix G, page 1 ....

APPENDIX G:

CORRESPONDENCE RECEIVED FROM STAKEHOLDERS

Correspondence received from stakeholders

CORRESPONDENCE RECEIVED FROM STAKEHOLDERS DURING THE COMMENTS PERIOD FOR THE DRAFT ENVIRONMENTAL IMPACT REPORT

Copies of all correspondence received are included in this Appendix. Issues relevant to the EIA have been included in the Final Environmental Impact Report submitted to the authorities to review. The following individuals and groups submitted written comments on the Draft Environmental Impact Report: COMMENTS RECEIVED ON THE DRAFT EIR WHO ORGANISATION ALAN SOUTHWOOD DEAT WENDY POULTON ESKOM KHOLEKA MNTWAPI CACADU DISTRICT MUNICIPALITY JOHN RAIMONDO COEGA DEVELOPMENT CORPORATION NORTON TENNILLE SAEP THABO NDLOVU NATIONAL PORTS AUTHORITY OF SA PAUL MARTIN NATURE CONSERVATION, NMMM REBECCA SIMS-CASTLEY TERRESTRIAL ECOLOGY RESEARCH UNIT, UPE GUY CASTLEY SANPARKS ROB MC WILLIAMS ZWARTKOPS TRUST BRIAN REEVES WESSA EP JOHAN STUMPF SUNDAYS RIVER CITRUS COMPANY RONICA NDINISA SANCO/ ANC PR DE WIT DEPARTMENT OF WATER AFFAIRS & FORESTY SIPHO NGCABA ANC PARLIAMENTARY CONSTITUENCY DECEMBER MOYENI SOUTH AFRICAN COMMUNIST PARTY HARRY DANIELS SOUTH AFRICAN NATIONAL CIVIC ORGANISATIONMARY CLARKE MASIPHUHLISE E.V. NOMNGANGA AFRICAN NATIONAL CONGRESS MZINI GENERAL SUNDU SOUTH AFRICAN NATIONAL CIVIC ORGANISATIONMELIKHAYA HAPPINESS KULA INDIVIDUAL PHUMELELE LABITHI ECBA THANDO CHRISTOPHER JUKU AFRICAN NATIONAL CONGRESS SANDILE ELVIS DOBELA AFRICAN NATIONAL CONGRESS VUSUMZI MICHAEL JACOBS INDIVIDUAL MIRIAM BILLET INDIVIDUAL ERNEST MAYEKISO SANCO CLYDE NIVEN AMANZI CITRUS CO. (PTY) LTD DALUXOLO PAPUMA ANC THEMBINKOSI MKALIPI ANC

Appendix G, page 1


COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FROM: ALAN SOUTHWOOD DEAE&T, Provincial DATE: 18 October 2002 Good morning Sandy, It is a very comprehensive and in depth report and covers the potential impacts of the construction and operation of the plant. If all the mitigatory measures are implemented the impact on the environment will be acceptable except for the plants and animals in the close proximity of the smelter. Unfortunately due to the length and complexity of the report I was not able to read the first eight chapters. A reader must have a reasonable understanding of chemistry to understand certain aspects. General comments Page ii: the summary table should also include outputs, such as CO2, CO and so on. Page vi: are the references under "Application of best practice" not a bit dated (1994, 1996 and 1998)? Page vii: efficient and adequate dust control during the construction is imperative. Page ix: Contingency plans for spillage must be in place before construction and operation of the plant and harbour. Page3-3: One of the primary duties of the CDC is to ensure that the impacts on the environment do not result in long term damage. There is no statement to this effect under 3.3. Page 4-5, last paragraph: Check on the facts on the sentence "The Algoa Bay Island.... . As far as I am aware only the St Croix Group was declared a nature reserve and not the Bird Island group. Page 5-6, second last paragraph: the potential cumulative effects are a major concern to me. The government and CDC will have to take this into consideration before any decision is made to go ahead with Pechiney. We cannot have a situation in a few years time where other industries will quickly exceed acceptable levels Page 5-7: costs must always be acceptable to society. Page 6-6: the regional hazardous waste facility must be in place before any hazardous waste is produced. Page 6-8: what kind of impact will the 11.1 t/year have on the vegetation? Page 6-9: all contingency plans should be in place before the plant starts operating. Chapter 8: I am concerned about the potential air emission impacts on vegetation and animals (Pages 8 to 29). More in depth studies should be taken before any approval is given to develop. Is the cost of the smelter going to be the extinction of two butterfly species? Is this socially acceptable? Who will decode whether it is socially acceptable or not. The comments in he Summary Booklet (Page 7) are very pertinent in this regard. Alan Southwood Environmental Scientist Department Economic Affairs, Environment and Tourism Private Bag X5001 6057 Greenacres Tel: (27) (041) 585 1850 Fax: (27) (041) 585 1958 E-mail: [email protected] I may disagree with what you say, but I shall defend, to the death, your right to say it (Voltaire: 1694-1778).

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COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FROM: WENDY POULTON ESKOM DATE: 21 October 2002

21 October 02

W Poulton

011 8002634 COMMENTS FROM ESKOM ON THE ENVIRONMENTAL IMPACT REPORT FOR THE PROPOSED ALUMINIUM PECHINEY SMELTER WITHIN THE COEGA INDUSTRIAL DEVELOPMENT ZONE, PORT ELIZABETH, SOUTH AFRICA Thank you for the opportunity to comment on the Environmental Impact Report (EIR) for the proposed Aluminium Pechiney Smelter within the Coega Industrial Development Zone, Port Elizabeth, South Africa. Our general comments, specific comments on the content of the EIR and response to various queries are detailed below. Please note that all comments also apply to the Summary in the report. 1. GENERAL COMMENTS

Some of the issues raised in Chapter 16 are outside the scope of the Environmental Impact Assessment (EIA) process and should therefore be excluded.

Although concerns and comments that were identified during the EIA process need to be

detailed in the EIR, it is for information purposes and recommendations on policy issues cannot be included in a document of this nature. It is inappropriate for policy recommendations on electricity generation or economic policy to form part of this document.

Eskom’s Integrated Strategic Electricity Planning Process outlines potential future supply

and demand side options. Each new power generating plant will be required by law to do a full EIA and thus the specific impacts associated with that plant will be assessed.

A balanced approach needs to be taken, where all aspects are considered and no

subjective statements or recommendations made. Thus only facts should be stated.

The energy sector is complex and crosscutting in nature and thus issues need to be considered in the broader context of socio-economic implications.

2. SPECIFIC COMMENTS The format of the submission of specific comments on the Draft EIR did not allow for these comments to be included in this Appendix. Detailed comments from Eskom have been included in Appendix H. Head Office Resources and Strategy Megawatt Park Maxwell Drive Sunninghill Sandton P O Box 1091 Johannesburg 2000 SA Tel +27 11 800-8111 Eskom web site: http://www.eskom.co.za

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http://www.eskom.co.za/


COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FROM: KHOLEKA MNTWAPI Cacadu District Municipality DATE: 18 October 2002 Comments on the draft Environmental Impact Report for the Proposed Aluminium Pechiney Smelter within Coega Industrial Development Zone, Port Elizabeth 1. Materials handling In the case of the amount of hazardous waste, which will be produced, are there any waste disposal sites identified, if so how far are they from the residential areas and what impact will this have on the health of the surrounding communities. 2. Air emission impacts on vegetation and animals How will the impact of SO2 and HF emission on the indigenous vegetation be minimized? For the other small animals that are dependent on those plants what impact will acid rain have on them? 3. Water use and liquid waste Is there any surety that in terms of the project there will be enough amount of water from where because we all know that we have a short supply of water and there is a huge demand for it. Also what will be the impact of the project on ground water? 4. Water discharges to the marine environment What impact will the water discharges have on the small lives in the marine environment? 5. Social impacts Who will constitute the relatively small number of highly skilled permanent employees who will be employed, is it local labour. Will there be no relocation involved in the project and if that is the case did the project proponents inform the likely relocates of the situation and are there any mitigation measures put in place for the smooth relocation programme. K.Mntwapi GIS Specialist Cacadu District Municipality, Tel.: 041 508 7085, Fax: 041 508 7136, Cell: 083 3152084

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Safety Health & Environment

MEMO TO : Sandi & Mazizi Consultants

FROM : John Raimondo

DATE : 20 October 2002

REF NO. : JR/jr/7212/09

SUBJECT : Comments on DEIR for Aluminium Pechiney CSIR ENV-S-C 2002-092(A)

Our comments are in two parts. This Memorandum which contains our main issues and an Appendix which contains editorial and minor issues that are factually incorrect. In addition the report needs to be updated due to developments that have taken place since it was drafted. These points are also noted in the Appendix. We do not believe that it is necessary to attach our Appendix to your record of comments as they do not affect the assessment. All our major issues and any that may affect the assessment are contained within the table below.

# Issue 1 The report is well written, covers the issues we raised in the Scoping Report and is informative.

We are pleased to note that you have assessed the technology in terms of the Best Practicable Environmental Option as this means that it is clear where natural resource use and pollution is complying with our own policy guidelines. This approach sets a good example for other EIAs to follow.

2 We note that section 1.6 states that predictions are based on the worst case scenarios. This is a valid approach, but it would be helpful to indicate the most likely scenario as well. We appreciate that this cannot be done for all the modeling already undertaken and so suggest that:

1. The point that predictions are based on the worst case scenario are emphasized in the Summary and the Conclusions; and

2. The likely variation from the predicted values for Sulphur Dioxide, Fluoride gases and storm water emissions is given.

3 The table on page 2-6 only gives the inputs to the project; it should also give the outputs – products, wastes, jobs and expenditure.

4 Note in Section 2.7 page 2-15 that it is a CDC requirement that all tenants, at the end of the life of their factories, remove all buildings from their sites and return it in the state that they received the site, unless alternative uses are agreed with the CDC.

5 Summary of all recommendations arising from the Draft EIR. It has become common practice for the authorities to make it a condition of approval in the Record of Decision that “all mitigation measures recommended in the EIR become part of this record of decision”. It is thus critically important that all the mitigation measures as well as other recommendations that you believe must be part of the ROD should be placed in one numbered and cross referenced table. This table should be included either in Chapter 17 or in a separate Annexure. It is not clear if Table 17.1 in fact meets this requirement or if it is only addressing the BPEO situation, as its title suggests.

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In addition it is vital that each item in that table is unambiguous in its intent and can be audited for testing the developer’s compliance with the item. In order to do this the timing and end effect or target should be given. We would thus recommend that Pechiney be consulted about this table to ensure that they understand the intent behind each item and the CSIR appreciates the technical feasibility of meeting the intent. It is not necessary that Pechiney agrees or accepts each item, only that there is no ambiguity regarding its intent and feasibility. The authorities can then decide which, if any, of the mitigation actions or recommendations made by the CSIR it wishes to impose on Pechiney. The authorities may wish to receive Pechiney’s comments on the Table, before finalizing the ROD. Any such discussion need not compromise the authority’s independence. Such consultation would be for the sole purpose of ensuring that any conditions imposed by the authority are feasible and auditable. A key recommendation is that of 17.2.3 stating that the recommendations for monitoring are included in an EMP. It should be stated that this EMP is to be included as part of Pechiney’s Environmental Management System.

6 The impact of air emissions on people has been well covered and is clearly stated. The CDC will work with Pechiney to monitor ambient concentrations of their emissions, using our existing three monitoring stations. We will also work with them to find ways to reduce their future Sulphur dioxide emissions in case their actual levels of emissions reduce opportunities for other industries to establish themselves within the zone. We have checked and confirm that the predicted ambient levels are within our original guidelines and are thus acceptable to us. We could not establish if the possible upset conditions had been modeled for the Fume Treatment Center [pg. 50 of Specialist’s report] to predict the 10 minute and 1 hour concentrations for fluorides, Sulphur dioxides and particulates. We would appreciate it if this matter could be clarified.

7 The impact of air emissions on vegetation, particularly by fluorides, is not well substantiated. It is noted that there is inadequate information to address this matter. It should be noted that the Pechiney smelter has been positioned within the IDZ metal cluster to minimize the air pollution effects on the “Butterfly valley” area. It should also be noted that “Butterfly valley” is not a good name to use and we intend changing all our maps accordingly, since the butterfly habitat is along the ridge and not in the valley. This area has been marked on our sensitivity maps and is currently being fenced. The CDC will be monitoring Aloeides clarki to determine its change, if any, over time. We will be using it as an indicator species. The recommended monitoring [Section 7 of the Specialist’s report] seems ideal from a theoretical perspective, but it may be more appropriate for the ROD to recommend that Pechiney, the CDC and relevant officials agree on what is to be monitored, for what purpose and under what conditions the monitoring may end. At present it would appear as though Pechiney must monitor the citrus plants for the life of their factory, even though it is predicted that the impacts will be negligible. It may be appropriate to indicate what information must be provided by the citrus industry – types of sprays used by themselves and other current practices and specifications.

8 Water discharges were assessed for two options, discharge of the storm water into the surf zone and into the harbour. The former was never considered an option by the engineers or planners and it is recommended that the final report only refers to the actual proposal which is to discharge storm water from Pechiney into pipelines that will discharge into the Coega river and hence the port, or directly into the port.

9 Following discussions with DWAF it is unlikely that process water will be discharged into the storm water system. This change and its implications need to be noted in Chapters 9 and 10.

10 The level of significance has been clearly defined on Page 5 – 13. It is recommended that a separate table be drawn up listing the items of medium and high impact after mitigation – provided that Pechiney confirms in writing that it is committed to implementing the relevant recommended mitigation. This will aid decision makers in making the necessary trade-offs. If all the medium and high impacts are in fact provided in Figure 17.1 then it is not necessary to produce the requested table.

11 Section 17.5.1 addresses the issue of emissions from the power supplied by Eskom. There may be an opportunity for Pechiney to purchase power from the Cahora Bassa hydroelectric power station – either directly or via Eskom, should contractual arrangements permit this option.

Appendix G, page 6


COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FROM: NORTON TENNILLE SAEP DATE: 21 October 2002 Dear Sandy: The draft EIA for the Pechiney smelter is not in fact available on or downloadable from the site given, http://smelter.csir.co.za. We are thus having difficulty submitting our comments today and hereby request an extension to make our comments until one day after the document is fully downloadable, given the fact that we are located in Cape Town and cannot examine the copies available in the site mentioned in the PE area. We have tried repeatedly to download it in pdf format as instructed on the site, but without success. In the meantime, we would like to submit, in anticipation of providing more detailed comments, the following: 1. Air Pollution study done by Ashwin Kumar of SAEP (attached). We believe the final EIA must respond to all the issues raised therein, in particular: (a) providing a clear definition of the air quality standards being applied to determine the carrying capacity of the air in the region for purposes of analysing the desirability/permissibility for the proposed Pechiney smelter; (b) a summary of all background data concerning air quality in the area, whether gathered by Pechiney or the CDC or its predecessors (and we hereby request that all such data be made available to us for our inspection; (c) an estimate of the percentage of the carrying capacity of the air in the Coega region, with respect to all pollutant parameters that would be affected by construction or operation of the proposed smelter; (d) appropriate public health background data and a health risk assessment of the impact of emissions from the proposed smelter on the affected population, especially in the most proximate communities such as Wells Estate, Motherwell, and Markman, but including all affected populations. We restate our oft-stated concerning that it is grossly inappropriate to site a metallurgical complex, and metals and minerals beneficiation facilities in the Coega area because of the proximity of the Coega IDZ, and the proposed location of the Pechiney smelter, to population centres. We believe all these issues must be confronted squarely in the context of the proposed Pechiney smelter. We believe the location of the Pechiney smelter and other such industries in the Coega IDZ would constitute a violation of the statutory and constitutional rights of the affected populations by posing undue risks to their health and well-being, as well of the principles of environmental and social justice. We believe that Pechiney as a multinational corporation seeking to avail itself of the natural resources of the Port Elizabeth area, including the carrying capacity of the air for dangerous pollutants, requires that exercise the highest degree of environmental and social responsibility, and avoid generating unnecessary and unjust risks for the local population, especially those in the historically disadvantaged communities. We hereby request an opportunity to meet with the management of Pechiney and the appropriate CSIR personnel to discuss our concerns in detail and pose questions concerning air quality issues. 2. Violation of human rights of residents relocated from and proposed to be relocated from the Coega IDZ. As we have repeatedly noted to the CDC, the Department of Environmental Affairs and Tourism, and the Department of Trade and Industry, the relocation and threatened relocation of residents of the Coega area to make way for Pechiney and other such industries has

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proceeded in violation of the rights of the residents who have been removed and are faced with removal. We believe their statutory and constitutional rights have been violated. We have made extensive submissions to the South African Human Rights Commission, and filed a formal complaint under the procedures provided for complaints by the SAHRC. We have received no response to date from SAHRC to date; nor has any action been taken on our complaint. We believe that Pechiney must commission a full, independent evaluation of the claims of human rights violations of the present and former Coega residents before proceeding, and make no decision concerning construction of a smelter at Coega until it is satisfied, and can satisfy the public, that the statutory and constitutional rights, both procedural and substantive, have been fully respected. In support of these contentions, we submit herewith our major documents filed with the SAHRC, which have also been copied to the Department of Environmental Affairs and Tourism. We also request an opportunity to meet with Pechiney management to discuss and document further our concerns in this regard. Please make available to us as soon as possible on the WWW the draft EIA and we will promptly make supplemental, detailed comments forthwith, within 24 hours of receipt. Please let us know as well when we can meet with representatives of CSIR and Pechiney. Sincerely yours, Norton Tennille Executive Director Southern Africa Environment Project Tel and Fax 021-685-3431 Email: [email protected] Note: The following documents were included in the submission of comments:

(1) Air Quality Management and the Coega IDZ – Prepared for the SAEP by Ashwin Kumar (SAEP Intern), August 2001

(2) Submission by the SAEP to the SA Human Rights Commission, 31 August 2001

(3) Submission by the SAEP to the SA Human Rights Commission, 24 October 2001

For copies of any of these documents please contact Norton Tennille at the above address.

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COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FROM: THABO NDLOVU National Ports Authority of SA DATE: 25 October 2002 Hello Frauke, Plse find my response to your questions, which is also NPA's comments on the Draft EIR: (1) Will disposal site 1, as described in the Port EIA specialist study, be used for disposal of the dredged material during operations? If not, what alternative sites are being investigated, or have been identified, for disposal of maintenance dredging material? Site 1 was identified for "only" the dumping of dredge material during the construction phase. That's the scope of the permit that NPA has obtained from MCM as well. The dredging permit that we have was issued based on the sediment analysis that was done, which also justified the location of Site 1, similarly when the port is operational sediment test will have to been done everytime maintenance dredging will be done and the the spoil might not necessarily be dumped at Site 1. Currently there are no sites that have been identified for the disposal of dregded material when the port is operational, i.e. we have not gone into detailed planning. (2) If Site 1 will be used for dredge material disposal during operations, have the recommendations for the modified location and dimensions of the disposal site been adopted? In designing the layout of the site the recommendation of the Specialist Report where taken into consideration. However, not in relation to the dumping of maintenance dredging material. (3) Does the current permit application for marine disposal of dredged material cover the disposal of construction-related dredged material only? If so, are additional studies required prior to the application for a permit for dredging material disposal during operations? Yes, the permit covers disposal of dredged material during the construction phase only. Yes, there will be a need for the other studies to be undertaken, viz. to concntration of contaminates in the sediments; assessment of the suitable site for the disposal of the material; etc. In fact, these studies are a requirement within the MCM permiting process. (4) What actions will be taken when the allowable limit for disposal of dredged material is reached at the offshore disposal site? The size of the site was determined based on the anticipated volume of dredged material that will be dumped. There will be continuos monitoring of the dumping process in order, among other things, to determine before hand if the allowable limit will be surpased. And if that happens the normal process of identifying another site through MCM will be undertaken. (5) As Aluminium Fluoride may be imported via Port Elizabeth harbour, does Port Elizabeth harbour have an EMP do deal with potential spillages into the port? NPA has an oil/Hazchem Spill Response Plan for the Port of Port Elizabeth. This plan outlines how spills should generally be handled within the Port. In addition, an more detailed EMP, which will cover the off-loading, transportation of the product, etc, will be developed.

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COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FROM: PAUL MARTIN Manager: Nature Conservation,

Parks and Recreation Department Nelson Mandela Metropolitan Municipality DATE: 21 October 2001 Sandy/Andries My comments on the Draft Pechiney Aluminium Smelter as follows: Resource Useage: Please state useage of resources (e.g. electricity & water) as a % of that currently consumed by e.g. the NM Metro as well as the actual unit quantities to allow the layman to compare the impact of the development on resource useage. E.g. I understand the electricity requirements are equivalent to that used by PE & EL combined - 860MW is meaningless – is this equivalent to the output of one power station? Similarly, water useage is stated to be 600 000 metres cubed p.a. and NMMM currently uses 66 300 million litres - what is the conversion factor - it is difficult for the layman to work out the % water use that the smelter will add. The reason SA has some of the lowest electricity costs in the world is because the environmental and health costs of burning low grade coal are not built into the price. Is SA therefore not subsidizing the overall electricity costs for the smelter - they are obviously coming to SA primarily because of the cheap electricity - why can SA produce electricity so much cheaper thatn the rest of the world? Water useage: The only thing the EIA has to say on this subject is that NMMM says that there is sufficient water for the project. However, as the PE area is a water stressed region, this relies on an inter-basin transfer from the Gariep Dam, with associated environmental and economic costs. DWAF is apparently wanting to minimise these types of schemes. Is DWAF happy with NMMM obtaining ever increasing amounts of water from the Gariep Dam – is there a limit to the amount of water that can be obtained from this source? As for electricity, is the full cost of water reflected in the price that it is being sold to the smelter at? Pollution: More detail on the process water and possible mitigation is required: where does it come from, why can it not be re-used or treated or concentrated and disposed of in a hazardous waste site rather than into the harbour? In particular, where do the high flouride levels come from? What problems are associated with high flouride levels in plants, water bodies and humans? The EIA seems to be saying that the rare plants and butterflies in the Area are at great risk from HF pollution. This is unacceptable. There should be methods available to ensure that the pollutants are kept below levels that will cause this type of damage. This is only the first of many industries for this area and already some of the heavy metal concentrations will exceed guidelines. Why can't the water be processed to reduce these concentrations? Where will the marine

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sediments be dumped and what will be the long-term effect of these dumped sediments on the marine environment? Stormwater, etc should be drained into the harbour as suggested as it is then easier to contain and treat any problems that arise before they get into the wider environment. % contribution of the smelter emissions to the total allowed in the guidelines set for the IDZ need to be clearly stated. E.g. it seems that approx 30% of the SO2 emission guidelines will be "used up" by the smelter, leaving limited scope for future industries. If monitoring shows an excessive build up of pollutants once the plant is operating, what can be done to reverse the situation, as it will presumably not be an option to close the factory down. Will the control systems make it uneconomic for a factory to produce pollution in excess of the levels laid down for it? St Georges Strand community is not mentioned when the effects of pollution on human health are assessed. Other: Is Pechiney regarded as an environmentally astute company? How have they performed environmentally in other countries? No mention is made of NMMM by-laws (not sure which ones will apply in this case, but they need to be considered). Dr Paul Martin Manager: Nature Conservation Parks & Recreation Department Nelson Mandela Metropolitan Municipality P O Box 12435 Centrahil Port Elizabeth 6006 Tel: 041-5859711 Fax: 041-5852907 email: [email protected]

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COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FROM: REBECCA SIMS-CASTLEY TERU DATE: 22 October 2002 21 October 2002 Sandy & Mazizi Consultants P.O. Box 23088 Port Elizabeth 6000 Dear Sandy and Mazizi

Re. Comments on Draft EIR for the proposed Aluminium Pechiney smelter within the Coega IDZ” - CSIR Report ENV-S.C 2002-092(A)

IMPACT ASSESSMENT AND MITIGATION: CH 6. MATERIALS HANDLING AND SOLID WASTE MANAGEMENT Page 6-16: Potential spillage of AlF4 and HFO - “If spillages are cleaned up promptly according to stringent housekeeping procedures then the negative impacts arising from materials handling is rated as being of low significance.” As this low significance impact rating is dependent on prompt and strict housekeeping procedures being carried out, Pechiney must ensure that there is an effective and efficient framework in place to ensure that any responses to such spills are dealt with immediately (i.e. within less than 24 hours). If a multi-agency contingency plan is required, then the contingency plan must be rehearsed with the appropriate agencies and a (frequently updated) database of names and 24-hour contact numbers for each agency be available in the event of an emergency. As part of this contingency plan, a GIS database should be in place incorporating spatial biophysical environmental data, including an environmental sensitivity index map highlighting the levels of sensitivity/tolerance thresholds of various components of the environment to all potential substances which could be spilled. This will allow for cleanup efforts to be carried out with max efficiency and effectiveness. Page 6-16: “During operations, the negative impact of waste generation on general landfill capacities would be of low significance … This significance will be further reduced if more waste is recycled or re-used …” Page 6-6: “The NMMM’s Integrated Waste Management Plan (IWMP) is currently being developed … There is therefore the potential for industrial developments … to send a larger component of waste for recycling.” To my knowledge NMMM’s IWMP has not yet be finalized nor formalized. It should therefore not be assumed that such facilities will be in place to deal with recycling issues to minimize the impact of Pechiney’s waste production. The NM Metro (formerly Port Elizabeth) does not have a strong history of recycling, so it should not be left up to the metro’s sole initiative to strengthen the metro community’s recycling ethic. If Pechiney wishes to report a reduced impact in this EIR, it should back this up with a commitment to playing a key role in the development of a materials recycling infrastructure which can actually deal with the capacity and nature of waste produced.

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Page 6-11: “The processing of SPL waste (either in cement or lime kilns, using AUSMELT process or in the steel industry) has a potential positive effect … will reduce the amount of SPL being disposed of by landfill.” SPL must only be sent to kilns which can operate at a high enough temperature to break down the hazardous components efficiently. The minimum effective temperature for the break down needs to be stated in the EIR. CH 7. AIR QUALITY Page 7.4: Dust during construction – potential severe impact on sensitive vegetation. The impact of dust during the construction phase on the sensitive protected habitats within the IDZ is likely to be severe. Reduction in the condition of the vegetation has the potential to kill certain plant species, as well as indirectly have a negative knock-on effect within the entire ecosystem, including the fauna. Apart from causing reduced photosynthesis and production (and other effects mentioned within the draft EIR), dust also changes the colour of the vegetation, reducing effectiveness of camouflage of certain vertebrate and invertebrate species. This increases the mortality of these species through predation and might have severe implications for their survival in the wild. This could be an important concern for the endemic butterfly species within the IDZ. Page 7-11: During construction – Contain dust – Water (possibly sea water) can be used as a wetting or binding agent on the unpaved roads and terraces. The recommendation to reduce airborne dust by spraying seawater on the construction site is not ecologically sound. Seawater will increase the salinity of the soil in the immediate and surrounding area. Stormwater runoff from the construction site will spread the salt through the natural drainage system within the IDZ landscape (including Butterfly Valley) with a resultant impact on the local vegetation. Other trace elements in the seawater might also have negative impacts on soil chemistry with detrimental impacts on the vegetation. Alternative mitigation is required. Page7-10: Pot start-up – abnormally high emissions No indication is given of the emissions that will be produced during pot start-up when the plant becomes active. I understand that they will be abnormally high. Please give an indication of this in the report with possible impacts to the environment. Page 7-17: “Pechiney’s direct contribution to GHG’s = 0.218%” “The estimated contribution to GHG emissions from Eskom for power generation PA’s use = 2.2% of SA’s total CO2 emissions.” South Africa is one of the 20 largest contributors in the world towards global greenhouse gas emissions (and one of the largest contributors per capita), accounting for 15% of Africa's CO2 emissions (Van Horen, 1996: 59). In 1994, South Africa's coal-fired power stations emitted 1 ton of CO2 for every MWh of electricity produced. (Van Horen, 1996: 6, 59). 2.2% of SA’s GHG’s is an incredibly high contribution to GHS’s considering this is due to the electricity generation for a single plant. This must be recognized as a DIRECT impact of Pechiney and not brushed over as an eventuality of Eskom’s future production increases. SA has an international obligation to reduce it’s GHG emissions. This compromises that obligation. CH 8. EFFECT OF GASEOUS EMISSIONS ON VEGETATION AND ANIMALS Page 17-5: “In the case of both SO2 and HF emissions, it is anticipated that tolerance thresholds of plants and vegetation communities ... will not be exceeded beyond the boundaries of the IDZ.” These thresholds are not known for local vegetation, therefore the above statement cannot be made. The potential effects of SO2 and, more importantly, HF emissions (even trace amounts) on the nearby ecosystem is of great concern.

1. It is well recognized that wild animals do not respond to chemicals in the same manner that domestic animals do. In many cases they have extremely low thresholds. As in the case of veterinary drugs, wild animals are considerably more sensitive than their domestic counter parts. The same drug and dosage given to a domestic animal would be fatal for a wild animal. It should therefore be kept in mind that the international guidelines used in the draft EIR might not be suitable for Pechiney and the Coega IDZ considering the close proximity of the Addo Elephant National Park (AENP).

2. The potential of HF to cause skeletal flurosis is of particular concern. HF has been shown to cause loss of calcium from the teeth and bones of domestic cattle. Given the potential sensitivity of wild herbivores to HF, even trace amounts of HF on the surface of the vegetation and within the vegetation, could cause significant skeletal flurosis within the fauna of AENP. It needs to be stressed that minor,

Appendix G, page 13


sub-lethal changes in the physiology of an individual in the wild can be indirectly lethal. Individuals in the wild live within a highly competitive system where the ability to compete for food and to avoid predators is critical for survival. If these abilities are compromised by weak teeth or bones, chances of survival are low.

3. In terms of the effects of SO2, HF and NO2 (including the NO2/SO2 combination) on vegetation. Loss of productivity, early senescence, leaf chlorosis, leaf necrosis, etc are all serious effects within an ecosystem that is being preserved as a functional system. If vegetation productivity is lost, the impact of herbivore grazing and browsing may negatively impact on the ability of the vegetation to regenerate itself, with a resultant loss of certain plant species and restructuring of the plant communities. This will have negative impacts on the rest of the ecosystem.

4. No mention is made of the effects of SO2, HF and NO2 (including the NO2/SO2 combination) on the interstitial fauna within the draft EIR. These are the microscopic animals which form the basis of a healthy ecosystem. They serve to breakdown plant litter to release nutrients into the soil and also help to bind the soil and to retain moisture within the soil. The effect of the above air emissions on this component of the ecosystem should be investigated.

5. The effects of prolonged release of SO2, HF and NO2 (including the NO2/SO2 combination) emissions over an extended period of time have not been discussed in sufficient detail in the draft EIR. It is especially important to determine whether such emissions are likely to alter the chemistry of the soil within the areas outside the IDZ as this could result in serious impacts on the natural vegetation by making certain nutrients unavailable to the plants (especially in the case of acid precipitation).

In conclusion, the EIR has not dealt adequately with potential impacts of SO2, HF and NO2 (including the NO2/SO2 combination) emissions on the vegetation and fauna outside of the IDZ. This is of particular concern because it has the potential to jeopardize other economic activities outside the IDZ which are of regional importance. These include the ecotourism (AENP and private gamefarms), the mohair industry and citrus farming. Ecotourism is an industry which is growing rapidly and which brings much money into the region. However, it is an industry which is dependent on an intact, functional ecosystem. The Subtropical Thicket Ecosystem Planning project (STEP) is a regional project funded by the Global Ecosystem Fund (World Bank) to provide a strategic conservation plan for the Thicket Biome in South Africa. It is noted with concern that very little consultation was made with this group with regards to potential impacts on this vegetation type. It is recommended that this group be contacted. The project manager is Dr Andre Boshoff (tel. 041-5042 844, [email protected]). Dr Graham Kerley could provide expert advice on impacts on herbivores in the region. Page 17-5: “Within the IDZ, the impacts on indigenous vegetation are expected to be of medium significance, implying some visible effects … (leaf chlorosis, early leaf senescence, some change in species composition in the long-term), but not to the extent that there would be major ecosystem failure”. A reminder might be in order here. A number of sensitive NO GO areas have been declared within the IDZ. These have been established in order to protect the existence of a number of endemic and endangered/rare species in their natural state. In order to achieve this, it will not be sufficient to merely place a fence around the areas of concern. The ecological integrity of the species’ habitats needs to be maintained. A species within an ecosystem is interdependent on the health of other components within the ecosystem. “Some visible effects” on vegetation, such leaf chlorosis, early leaf senescence and some change in species composition in the long-term, imply sever physiological and ecosystem changes. To individuals reliant on a functional natural system for their survival, these sorts of effects can be indirectly lethal. As we are attempting to protect ENDEMIC species, this means that if they do not survive within the IDZ, these species will be driven to extinction. Avoiding “major ecosystem failure” is therefore not a suitable objective to be striving for. Rather the objective should be to maintain a functional ecosystem. It has been rightly stated in the draft EIR that the impacts of the above pollutants are exacerbated by dust on the leaf surface. It has been assumed in the report that the effects of construction (i.e. dust) will not coincide with the effects of operations (i.e. air emissions). However, it is highly likely that once Pechiney is operation, other tenants will be carrying out construction within the IDZ with a resultant generation of dust. More cognizance should therefore be given to the potentially greater impact of this combination of dust and air emissions on the local ecosystem. Recommendations to wash the vegetation by spraying it with water is unacceptable and not ecologically sound as it will change the water regime of the ecosystem. The ecosystems within the IDZ are adapted for a semi-arid, drought-prone environment, therefore water is an important determinant of the structure of the local vegetation communities. Changing the water regime of the system is likely to have a detrimental effect on the ecosystem.

Appendix G, page 14

mailto:[email protected]


The impact of both dust and air emissions on fauna and flora within the IDZ should be rated as HIGH. Alternative mitigations are required. CH 10. WATER DISCHARGES TO THE MARINE ENVIRONMENT Pumping contaminated waste water and stormwater runoff into the surfzone north of the port is unacceptable. The coastline north of Coega is characterized by a high energy surf zone which drives the production of phytoplankton which forms the base of the marine food chain and is a critical resource for the marine ecosystem within Algoa Bay. This ‘surfzone production area’ extends along the entire northern section of Algoa Bay past Woody Cape. It is also an important source of food and nutrition for the fauna and flora of the Alexander dunefield (one of the largest coastal dunefields in the southern hemisphere and is one of the few functioning sand corridors left in SA.) Given the critical importance of this area and the surfzone, the models carried out for the EIA are not adequate to pick up potential impacts on the marine environment. The model is also inadequate in terms of predicting impacts associated with longterm release of hazardous waste water into the marine environment. The option of pumping the waste water and stormwater runoff into the port and dredging the port is also ecologically unacceptable, especially if the intention is to dump the dredged material out at sea. Dredged material will bury the benthic habitat thereby destroying a number of important habitats, such as the breeding grounds for numerous species upon which the local fisheries depend, including calamari. In addition the released sediment will result in persistent plumes in the water column which will increase turbidity and block out light. This will interfere with proper functioning of the marine ecosystem by inhibiting phytoplankton growth. Furthermore, releasing heavy metals into the marine environment which can potentially be taken up by fish and other marine species which are later likely to be consumed by humans poses potential health hazards. Contaminants must be removed from the water before it is discharged into the marine environment. CH 14. SOCIAL IMPACTS Page iv – “Key challenges for improving infrastructure and services are to improve the quality of education and to overcome the severe housing backlog”. What impacts will meeting these challenges have on the ecosystem? In order to provide more housing, natural vegetation will need to be removed. Should you have any queries or require further information regarding the points above, please do not hesitate to contact me. With best regards Rebecca Sims-Castley Tel: 041-5042 493 [email protected]

Department of Zoology, University of Port Elizabeth, P.O. Box 1600, Port Elizabeth 6000 Tel: +27 41 5042493 Fax: +27 41 5042946 Email: [email protected]

Appendix G, page 15


Conservation Services, PO Box 20419, Humewood, 6013, South Africa

Tel: +27 41 5085413 Fax: +27 41 5085415 E-mail: [email protected]

COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FROM: DR GUY CASTLEY SANParks DATE: 21 October 2002

Sandy Wren Sandy & Mazizi Consulting PO Box 23088 Port Elizabeth, 6000 21 October 2002 Dear Sandy Re: Comments on draft EIR, proposed Pechiney Aluminium Smelter, Coega IDZ Herewith comments from SANParks on the proposed development of the aluminium smelter in the Coega IDZ. The comments are in no particular order and may include issues that were previously raised at the focus group meeting held at Bayworld. - The long term sustainability is questionable given that the proposed life span for the plant is only 30-40 years. In

environmental terms this is relatively short in comparison to the need for the retention of environmental habitats and ecological functioning. There are also no indications as to the future demand for Al after the next ten year cycle or indeed after the smelter has outlived its purpose.

- There need to be some definitive statements made about the potential for the 2nd potline scenario and whether this potential development will proceed in the future. Clearly if the emissions outlined in this report are from only a single potline the impact from two potlines would be even greater.

- What percentage of the air quality limits set for the entire IDZ are met by the emissions from the proposed smelter, and for which components?

- In the previous EIA for the rezoning and the port development a number of no-go areas or green belts were identified which supported sensitive habitats or species. From the discussion and figures provided it is apparent that the emissions from the smelter site will have a negative impact on the site as well as the immediate vicinity. How has the conservation of these sensitive areas and/or species now been compromised as a result of the proposed smelter. Restrictions were previously put in place to reduce impacts on these environments but it is immediately apparent that these systems would not escape the impacts from the smelter. It is also apparent that there are no mitigatory measures that can be put in place to reduce such impacts.

- What are the impacts of the fallout on the groundwater reserves in the IDZ and beyond? The emissions to the atmosphere include particulate F as well as other material. How easily are these elements taken up by the groundwater which may result in future impacts on plant species productivity and performance? Are these compounds likely to accumulate in the groundwater until concentrations reach unacceptable levels or do they degrade naturally and if so how?

- A greater breakdown is required for the 6% of water being used from Nooitgedacht Treatment Works. Where does the plant receive its water and how is the provision of this water reflected in the general rates etc. within the Port Elizabeth metro. Will the increased demand from this source require additional discharges from the Darlington Dam and at what frequency?

- Flouride emission levels exceed local legislative acceptable levels (irrespective of whether these are guidelines or standards), this is non-negotiable regardless of what the World Bank guidelines etc. may indicate. The use of international standards should be used when there are no such standards for South Africa.

Appendix G, page 16


- Dredging is proposed to alleviate build up of heavy metals within the port basin. Where will these spoils be dumped and what about subsequent accumulation of these compounds at the dump site. How often will this dump site have to be moved due to acceptable levels being exceeded according to the London Convention, that is, how long will it take before the LC guidelines are exceeded in the open ocean as presumably these compounds will settle out and accumulate here after dumping from the port basin. Have there been any sediment dispersion studies undertaken to investigate the potential area of impact associated with such dumping activities? What are the possible alternatives here? There has been no assessment of the impacts of these heavy metals on the marine interstitial fauna. Implementing a monitoring programme which focuses on Perna perna, a rocky shore species, may provide little insight to the impacts of the discharge or dumping on soft bottom fauna.

- It is indicated that as a result of the emissions having a high F load that stormwater (i.e. surface runoff) will need to be classified as wastewater for discharge. How will it be possible to manage the stormwater across the entire site as well as IDZ/area of influence (i.e. fallout area for emissions)? The stormwater system that will be in place in the IDZ will only capture runoff from roads, roofs etc., what about the infiltration of these compounds into the soils and subsequently groundwater? Monitoring of groundwater for concentrations of compounds can not therefore only be restricted to the smelter site. The discharge of these compounds into freshwater sources outside the IDZ boundaries is also possible given that the dispersion plumes cover the catchment basin for the Sundays River, a river which is of significantly greater conservation value than the Coega River. This aspects has not been taken into account for the proposed smelter development and it should therefore not be assumed that there will be no impact on freshwater resources, particularly if stormwater concentrations are estimated to be significantly higher that that of the process wastewater, if wastewater is discharged to the marine environment.

- Further information is required on the status of agreements with Eskom with regards to the supply of power. It appears that the current power supply to Port Elizabeth via the Grassridge substation now and with future expansions proposed (Eskom’s own EIA process) may not be able to handle the increased demand by the Smelter and possibly the IDZ. This is based on the figures that have been supplied by Eskom in their EIA studies for the construction of the new 400kV line and upgrading of the 220kV to a 400kV line which pass through the Addo Elephant National Park. The 860MW required by Pechiney does not indicate whether this include the additional power required for commissioning of the smelter (routinely more power is required for startup). This does also not include what is required for the remainder of the IDZ or the Port Elizabeth metropole. Clearly the three 400kV lines that will bring power into the region are only able to supply about 1100MW of power (based on Eskom figures) which may not be sufficient to meet future demands. A breakdown of the current power distribution is required. SANParks would be opposed to any further powerline development which may have a negative impact on the existing Addo Elephant National Park and the proposed expansions to this park.

- The possible impact of F on wildlife productivity, given possible impacts on bone and teeth requires closer investigation. The proximity of the Addo Elephant National Park (areas of which are included in dispersion plumes) is of concern as the park currently holds a number of critically endangered (IUCN classification) species such as black rhino as well as regionally isolated populations of African elephant and Cape buffalo. The uptake of F emissions through freshwater resource contamination in the park over time is of particular concern and these potential impacts have not been adequately addressed. More detailed information is required as to the impacts on wildlife, and the monitoring of water resources within the park may be required to ensure that there are no impacts on these biodiversity resources. The emissions may also jeopardise future options for SANParks to expand their operations through contractual arrangements with potential partners such as PPC as the impacts in these areas would be more severe given the reduced distance from the smelter site. Although the above discussion focuses on the AENP fauna the indigenous and endemic fauna resident in the green belt areas of the IDZ is of concern. These areas were specifically set aside to protect these species, the survival of which is now being compromised through direct and indirect impacts.

- Are there any possible alternative treatment options, over and above the standard recycling options listed in the specialist reports, that can be investigated to reduce the severity of the emissions and discharges to the environment?

- What are the stormwater and process waste water impacts on marine life, are there any limits in this marine environment and are these exceeded by the discharge and or subsequent dumping of dredged sediments? Impacts from the specialist studies indicate that the impact of discharge is likely to exceed acceptable limits within a short time frame for certain elements. What are the impacts on marine life prior to these levels being exceeded and the continued cumulative impacts?

- Impacts on the proposed park are not restricted to the visual aspects, air quality, and marine discharges are also of immediate concern, particularly with the islands near the port. The long-term cumulative impact on the marine environment is of particular concern. There is also no discussion around the potential impacts on the fallout risk on the islands themselves. With a number of important birds breeding on Jahleel Island as well as the other islands the possible impacts of F on eggshell formation etc. may need to be considered. Accumulation in these environments is also a concern.

Appendix G, page 17


- Negative social impacts – the people employed during construction will remain in the area and will therefore exacerbate negative impacts for the region post construction, therefore operational social impacts will not be of low significance.

- What is the frequency of recommended monitoring activities? E.g. air quality (daily, weekly, peak, emissions, etc. number of monitoring points that will be established?), impacts on plants and wildlife. Recommendations need to be more specific in many cases, particularly how the discharges to the marine environment and impacts on marine life / islands will be monitored.

- Monitoring, who will ensure that these recommendations are implemented, how often will these activities be reviewed and will there be an independent audit process in place?

- Why is SA the preferred site given that there are no fatal flaws in Australia? How to the development costs associated with the development differ between these two sites and are financial incentives such as those offered by South Africa being offered by Australia. Are the bulk of the raw materials not to imported from Australia? If not where are these raw materials being imported from? Does the Australian site have a port or planned port facility attached?

- Does the new AP50 technology have fewer environmental costs that the previous technologies? - Are there older air quality standards which are legally enforceable and what are these? - How long do pots remain unhooded in the commissioning phase and for how long are hood required to be

removed and for how long ? - Look at Greenhouse Gas emissions on a per hectare basis to compare this to other industries throughout SA.

This may give a more realistic representation of how the proposed smelter is contributing to SA’s GHG emissions.

- How will potential losses in crop production as a result of gaseous emissions be addressed, how will these be monitored and related back to the smelter or IDZ?

- The stated unknown impacts on indigenous vegetation is of concern to SANParks given our interest in conserving natural environments, landscapes and species. Shifts in plant community structure could result in shifts in wildlife communities and the capacity of the habitats to support certain species. Where information is not available the precautionary principle should be adopted, which does not necessarily mean that one only looks at the worst case scenario. It is important to note here that the studies indicated that there were no possible mitigation measures possible which is of extreme concern given the risk of extinction for sensitive or threatened species etc. on the long-term ultimately leading to a loss of SA’s biodiversity.

- Secondary impacts (acidic precipitation, accumulation) in areas beyond the IDZ. What is the half life of these compounds in the environment and will they break down? If these compounds do not break down naturally how long would it take, for F particulates as an example, to reach unacceptable levels. If there is no natural breakdown there is bound to be an increased potential risk to vegetation and wildlife over time which has not been addressed in the studies. It is important to note that this accumulation is not restricted to the smelter site or the larger IDZ.

- What do the consultants mean by ‘ecosystem failure’? If there are potential long term changes in the community composition with resultant changes in how the ecosystem functions then there may indeed be certain ecological processes that fail, particularly for certain species (e.g. butterflies, particularly if the ecological requirements are poorly understood). Just because the entire ecosystem doesn’t become sterile does not mean that this is not a point of concern. The long term cummulative impacts here are of critical importance, bearing in mind that the thresholds highlighted here are likely to be reached even sooner given additional developments in the IDZ (although not necessarily of direct concern to Aluminium Pechiney). It is these cumulative impacts within the IDZ that have been raised time and time again that continue to create significant concern for the survival of sensitive environments.

- Water use registration. DWAF need to be made aware that even though the NMMM may have approved the water supply for the smelter, that the water use cycle includes significant discharges to the environment which include elevated F, Zn and Al levels. These are not only discharged through wastewater but also through filtration into groundwater. Will NMMM need to register this use prior to construction of the smelter?

- What is Algoa Bay listed as in terms of water resource discharge. Furthermore, what percentage of the total IDZ allocated discharge does the discharge from Pechiney contribute to?

- If is mentioned that during construction sea water may be used to water down gravel roads to minimise dust impacts. What are the potential impacts of this sea water on local vegetation as well as groundwater?

- Stormwater runoff may not be discharged into any water resource given that it contains waste from the industrial activities, see conditions Chapter 9, page 7. Stormwater will contain F particulate emissions from fallout as well as possible other compounds. What about the fallout that creates stormwater runoff beyond the Pechiney site itself?

- What are the ‘bunded’ areas referred to in the report? - Additional groundwater analysis are required. The depth of water table across the site should be determined to

predict potential risk of contamination through discharges. What percentage of rainfall accumulates in the stormwater system compared to that which permeates into the groundwater? There are also apparently well

Appendix G, page 18


developed aquifers in the areas which could be negatively impacted as a result. The effects on natural water resources may therefore still exceed DWAF and SA guidelines regardless of whether this is discharged to the marine environment. How are impacts on groundwater mitigated from medium to low? This is assumed to be through implementation of a monitoring system, but a monitoring system does not reduce the level of the impact, it only informs one as to when levels have been exceeded. There may be geohydrological data available from the Council for Geosciences who have recently completed studies in the Algoa Bay area. Possibly investigate these data sources.

- Does Pechiney have a general authorisation for the water use and why is a licence not required? This is not immediately clear in the report.

- What constitutes a complex industrial wastewater? - Impacts on marine sediments and constituent fauna are not restricted to Coega port as AlF brought in via PE port.

Does the existing port have an EMP to deal with potential spills into the port? - Does the CDC have a licence to discharge at sea and if so was this licence issued only for the dumping of certain

materials (does this include CN, Zn, Al etc.)? - The EIR makes mention of the ‘planned’ greater AENP (GAENP). These plans are currently being

implemented with the park already present with over 130 000ha currently held in the terrestrial environment and SANParks currently responsible for the management of the Algoa Bay islands. The impacts are therefore not envisaged but are real threats to the existing park and are also not restricted to the aesthetics as highlighted previously.

I hope that these comments are constructive and urge you to contact me should there be any queries with any of the issues raised here. Yours sincerely

Dr Guy Castley Animal Ecologist cc. Dr Mike Knight

Mr Lucius Moolman

Appendix G, page 19


COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FROM: ROB MC WILLIAMS ZWARTKOPS TRUST DATE: 19 October 2002 October 19, 2002 Sandy & Mazizi Process Design, Management & Facilitation P.O. Box 23088 Port Elizabeth 6000 Re: Zwartkops Trust Comments regarding “Final Scoping Report” dd. July 2002. Pechiney Aluminum Smelter within the Coega Industrial Development Zone. It is the Trusts opinion that taking into account the high environmental and health risk, that the Smelter must be located elsewhere i.e. at the source of raw material – this will save having to transport raw material to the point of processing. It must be assumed that the country of source Australia is not anxious to continue with smelting plants due to gas and solids pollution. 1. The fact that Pechiney have been in existence since 1998 does not ensure that this operation will not be prone to both ground and atmospheric Pollution: Pechiney appear to be hesitant in supplying details of pollution solids and gas emissions. This raises doubts and makes us very suspicious – must we now must assume that Pechiney will be directly responsible for any health and safety to the local and P.E. population. The bottom line it is the stated policy that no health hazards are acceptable however the standards are interpreted. 2. The (Sea) document was hardly completed when plans where already being made to impinge on the “NO GO” areas. Therefore in the opinion of the general public the studies become redundant. It makes no worthwhile sense to absorb a potentially productive and labour intensive farming area that will guarantee more jobs than a process operated smelting plant with a limited life span. The people need to be informed that employment is going to be curtailed as a result of the export of the aluminum as it cannot create more jobs in PE or the rest of the Country. Farming and Tourism are far more lucretive and less hazardous and have a life of more than a restriction of the Smelter life 3. Communities have recently been moved from a heavily industrial polluted are namely Wastech to an area adjacent to heavy industry. This area is considered too close to the Township of Motherwell and Bluewater Bay. A glaring example of communities being surrounded and suffocated by noxious industry is the Witbank area, and others. The C.D.C. has stated that Industries will be responsible for any pollution or damages to communities and houses in Motherwell, Bluewater Bay, Amsterdamhoek, Swartkops and other areas or these Industries will be penalized. Once established this will be too late. In our opinion the C.D.C. must take responsible to for any costs. 4. It is of note that Pechiney have other options in the location of the plant i.e. Australia. Pechiney can enlarge the Australian plant effecting a saving to all concerned and thus saving us from massive pollution. This is strange, as it appears as if the Communities in Australia are also anxious to be rid of this noxious processing plant. 2/ 5. What agreement was reached with Eskom? This must be made known to the general public, it has been stated that “transparency” will be of keynote. What we want to know is whether Eskom is going to sell electricity cheaper to the IDZ than the rest of the Metropole – meaning that factories in P.E. will be subsidizing them. This is not acceptable. Do factories in the IDZ pay rates to the NMMN or the Government? This must be made apparent. 6. Referring to Zone 5 this is too close to existing residential areas. The aquifer water, which is free of free of chlorine, appears to be chemically preferable by Pechiney to existing water supply. This implies that Pechiney will be interfering with existing aquifers.

Appendix G, page 20


7. Conveyor belt transport of materials even though enclosed poses a high risk area of Pollution resulting from high and gale force winds. We have been assured that all conveyors situated at the Harbour and over-land will be enclosed – picture of factory does not show the extent of storage areas to house +- 250000 tons of raw material – this storage has to be on concrete floor and under cover. 8. How much dust from the pots referred to will be prone to being blown into the atmosphere. Also will dust emissions be conducted throughout the night? We are told this is a very Dusty Process – what precautions have been taken. The dry scrubbing unit that treats the PAH begs the questions of whether any dust emissions will be open to the atmosphere. Should dust be found outside the factory limits the factory must be by necessity closed down assurances are required in writing from Pechiney. 9. What is the source of liquid pitch referred to and how will it be transported in the plant. Will it be enclosed? The control on the pumping of liquid pitch under regulated temperature conditions from ship to the point of usage is of concern in that any spill will be disastrous to the surrounding vegetated areas as well as the sea and surf zone. This will destroy plankton, shell fish and bait fish necessary to the greater Algoa Bay fish population. 10. Unsightly power lines leading from the Grassridge cutting across an area heavily populated by Aloes Plants to Coega. Question how many power lines (cables) are envisaged in the short and long term. We have been told that this plant uses more power than PE and EL put together – are the major power lines going to be above ground or underground. Diagrams of pylons and the number of must be given. 11. What has not been taken into account through a proper study comparison is the cost and risk to Tourism as a result of Industries considered to be a high-risk potential due to unacceptable and general air, water and vegetation pollution. 12. The off loading of liquid pitch and the risk of spill will decimate fauna and flora located on the immediate three island reserves together with the fish and bird life that abounds this area as well. We need guarantees that will safeguard the area. Conveyors must be totally covered, if not as specified the plant must not be commissioned. Pechiney to give guarantees in writing. 13. Where will the high demand for the necessary processing water be sourced? Any demand on the existing aquifer will be disastrous for Uitenhage and surrounding farmers who are dependent on this source of water. In times of drought what will be the alternative for the aquifer. Will this also not be to the disadvantage to householders and communities. Should underground water be contaminated who will be held accountable, C.D.C., Pechiney or DWAF this needs to be highlighted. Port Elizabeth is in a drought area which can extend over a long period of time. During any such period who will take the responsibility for determining who gets the water Pechiney, the communities or the towns people. 14. Recruitment of workers it has been stated and assurances have been given that the recruitment will be confined to local labour. Past experience supported by the events at Moss Gas and elsewhere will be certain to create a mass of job seekers. This will lead to hard ship poverty, and lack of housing. Who will provide for these unemployed people? Pechiney must stipulate how many coloured, white and black workers they will employ on a permanent basis. We are aware that initially construction workers will be in demand creating short term employment. The CDC have been creating a false impression regarding the number of long term jobs available. The CDC must take this into account financially and take responsibility for this problem to come. 15. The Statement that pollutants are being trapped beneath a layer of cool air (affecting dispersion) raises serious concerns by the environmentalists in this area. The landscape coastline and vegetation of the Eastern Cape is unique particularly in the area set aside at Coega. In the interests of attracting tourists to this area should be left untouched and in a pristine condition. “Allow the tourist trade to develop on it’s own and without pollution.” What happens to the pollutants after the have been trapped under this layer of cool air. This was discussed at the meeting at Bay World no explanation or outcome was offered. How do you come by cool air. What sort of liquid do you use to create cool air. Should these pollutants escape would the answer be brushed aside. 16. The Eastern Cape is the meeting place if six biomes of SA. This habitat diversity is the basis for very high conservation and tourism value. This does not occur anywhere else in SA, in fact many of our plants do not occur anywhere else in the World. The Government should be capitalizing on this uniqueness and only plan for those selective Industries that are labour intensive and free of pollution. The important question is, “How can the

Appendix G, page 21


CDC plan the degradation and the destroying of these areas, a legacy from time immortal and which will never be reproduced elsewhere”. The Pechiney Aluminium Company must be made aware ( if they are not already ) of this wanton degradation of the natural resources of this area, i.e. Fauna and flora, and an appeal also must be submitted to them in order for a full evaluation to be made. This must be done after full consideration of all the facts. Should the CDC go ahead, they must be held totally accountable in their personal capacity for any degradation of the area along with Pechiney. It is understood that legal papers are in the process of being drawn up for all parties to sign. Items dealing with Fauna – Invertebrates, Vertebrates, i.e. reptiles, birds and mammals that are prevalent in the CDC area and surrounding area set aside for the Pechiney smelter and The Marine Ecosystem round and in the Harbour. 17. Referring to the extent of the scoping report on this very important aspect it would be difficult for any Country claiming to be proactive in sustaining the Worlds Fauna and Flora wily nily or be party to the destroying of this important environmental asset. The fact also that the Greater Addo Elephant National Park will extend from the immediate Eastern bank of the Coega River Mouth, must be also a mitigating factor against a shared boundary with a potentially high hazardous Industrial area. In accordance with world stake holders a billion rand must be deposited for the rehabilitation of any area that the CDC and Pechini derogates. Failure to do this places their credibility in question. Who will pay for the rehabilitation of the waste area when the smelter is closed down after 30 years of operation life. 18. Taking into account the full development and occupancy of the Motherwell Township, there will be an additional need for beaches to be conserved between Coega Mouth, Jooste Park and St. George’s Strand. Furthermore, additional pollution free recreational space and access along the length of the beaches will also be needed to cope with a heavy influx of users. 19. The railways should be responsible for the provision of a Metro rail service. A rail linkage must be built not only in the Coega area but in the Metropole as well. Roads throughout our City and surrounding areas must be improved. 20. The Zwartkops Trust at the outset of the proposal by the IDZ stressed that a sewerage plant must be included to service the Coega area. Within 5 years the Fishwater Water Treatment Plant will by the addition of Coega have absorbed the plants capacity. The Trust has in the interest of protecting the sensitive nature of the wetlands that will be lost should it be planned to increase the capacity of the Fishwater Flats plant, been against this development. It has also become necessary to install a larger sewage pipe under Settler’s Bridge to take sewage from Coega until the capacity of Fishwater Flats is absorbed in two to three years time. This must be paid for by the CDC. They must take responsible for this pipe until such time when the CDC have their own sewage works. 21. Noise Pollution. It has been reported that the Smelting Plant operates 24 hours per day at a noise level of 70 decibels. Question does Pechiney and the CDC not consider this level to be excessive to the health of those families living within a radius of 20 Km,s or less. 22. The CSIR is not an independent agency and therefore as a consultant, there will be the question of vested interest where any controversy arises. The CSIR can expect to be challenged in respect to any areas of concern as they may occur. 23. Air Quality (including effects on human health, plants and agriculture) this is a very significant item that can have very serious consequences to humans, animals and those fruit and agriculture farms in the immediate area. Prevailing high seasonal winds will result in pollution being carried as far as B/Bay and surrounding Townships. This, it is a pointed out will be to the detriment of health and the value of our properties. Full account must be taken of the very negative issue to the wavering of approval for the siting of a smelting plant even though the visual impact and the pollution, that will be experienced is of great concern. We have also learned that the outer site area of the Aluminum Smelter situated in Australia is a bright yellow, and where the growth of all plant life has been destroyed. Sulphur Dioxide which forms acid rain will also have a disastrous affect on the surrounding plants and bush and especially the protected plant species situated at Coega Kop and other protected plant species situated in the Bokerveld and the adjacent Addo Park. The animal life both wild and domestic will be

Appendix G, page 22


affected through the eating of plants that have been contaminated by pollution. This in turn will be transmitted to humans through beef and milk. The Trust is also totally against increasing any further agents into the atmosphere that will further contribute to global warming. Again operating standards must be submitted stating who will be accountable for any losses incurred by Pechiney and or the CDC. We need specific out-puts. How much sulphuric acid, sulphur dioxide, the cyanide in question must by necessity be encapsulated and stored at a fully licensed toxic waste site. This includes any gases and heavy metals that may be produced by Pechiney. How will this be handled and who will be accountable. Will this specific body be identifiable and readily available, there is s need to know. 24. Through past experience with local noxious Industries communities have suffered from pollution, odours and contaminated dust. For example, during 2001 a petition signed by 625 residents of Amsterdam Hoek, Bluewater Bay and Swartkops was totally ignored by the relevant authorities in Government and the local NMMM. (Refer Mr. Lloyd Pretoria and Steyn NMMM) The Trust therefore has little or no confidence in the CDC Statement that sufficient controls will be in place to ensure that the Atmosphere will be free of pollution detrimental to humans, animals and the ozone layer. The big question is, given all the assurances that have been is who will be qualified to carry out the policing. a.) If there is a reduction in air quality at the time that the Smelter is on stream then it will be too late to shut down for process reasons and the upshot will be that yet another noxious industry will have to be added. b.) The same goes for the highly populated township of Motherwell which is the closest township to the pollution. Most people living there have no concept of Pollution. c.) The total operation of the smelter is seen as a very real pollution source. d.) The run off as referred to must not be directed into the sea. More importantly, has consideration been given to 1:50 and 1:100 floods that will occur. The effects of this run off will be disastrous. 25. Planning is underway in Motherwell and elsewhere to develop areas that will attract Tourists. In order to compliment these people in Motherwell are currently being trained as Tourist Guides. It seems futile therefore if the area is not attractive as a result of noxious odours and a deterioration of the surrounding vegetation that will have disastrous consequences. Can we on behalf of this community ask that Guarantees be given by the appropriate authority. 26. Can an uninterrupted supply of electricity and water be guaranteed, given the number of power failures that have been experienced locally? In the event of a power failure, will preference be given to the Smelter at the disadvantage of the NMMM ratepayers, residents and communities? The provision of backup electrical generators burning low-grade coal will also add to an already noxious and sulphurous condition. An uninterrupted supply of water and electricity must be guaranteed to PE ratepayers. Pechiney must have their own supply including water when below 40% of the supply dam’s capacity. The use of aqifer water and the pollution thereof is a no no. The water supply to Uitenhage must be guaranteed and not polluted by run-off from Pechiney’s operation. 27. Except for our communities who have lived adjacent to and have the experienced the effects of Toxic Waste Disposal Site, most other migrant labour will be unaware of the health hazards of pollution. This being overshadowed by a desperate need to find a working and living environment. The question at what price to these human beings. It is a proven fact that very few of Motherwell people are aware of the full facts of what they are facing in the future as regards to their quality of clean air and health conditions that they will have to face. The grassroots communities have absolutely no idea of the pollution they will be exposed to from an Industry such as an aluminum smelting operation. The question is where will they be moved to in the event of suck occurrences being untenable and a danger to health. 28. The Trust questions the need for the Smelter’s need and location, premised on the damage that will be incurred to the ecology and the health economics and the well being of our populace. The land area in question in terms of the indigenous fauna and flora cannot be denied. It is unique and also deserves to be preserved for prosperity. Industry while the lifeblood of our people can be more favorably located elsewhere in areas more in keeping with Pollution output and the environment.

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29. “Specifies that without these port Facilities the project is considered unviable.” Blasting of Coega Kop over a period of 3 years if not properly controlled is going to have serious effects on the following and in terms of the Swartkops Estuary a disaster will be irreversible. Of importance it must be submitted that although requested a risk analysis has yet to be undertaken. a) Affect on precision Industry in the immediate area i.e. Markman Township on machines and measuring equipment. b) Effect on dwellings (foundations, walls and windows) Motherwell, Amsterdam Hoek and Bluewater Bay as was the case when blasting for the extension of the Harbour breakwater took place. c) The high risk of collapse of the 29 years of stored toxic liquid waste contained in the Aloes Wastech site and the slip into the adjacent Swartkops River. If this occurs it will mean the demise of the Estuary. Is this not a concern to the Department of the Environment who should be supporting that a Risk analyst be carried out? d) The Trust will not be swayed by an explanation that the blast is air related. During the breakwater blasting it was definitely proven that it was ground related. Attention must also be drawn to the recent blasting carried outside Grahamstown for a bypass. Houses in the immediate area were damaged. A well-known Seismologist living in Grahamstown supported the grievances of the house owners. 30. Air pollution It is stated that air pollution will cause no Chronic illness and is therefore this considered to be of low importance. Does one therefore understand that it is accepted that residents who suffer illness especially respiratory will only be treated when the illness is of a Chronic nature. According to our constitution we entitled to clean air and our health and it is very doubtful if this industry can measure up to this requirement. The export market regarding citrus and deciduous fruits are very stringent regarding the marketing condition and of the fruit. Citrus is very susceptible to any air pollution and any resultant skin blemish will result in outright rejection prior to being picked. This could have the effect of wiping out the citrus export Industry situated at Addo and Kirkwood. Has account been taken of the result of thousands of farm workers being unemployed in this very lucrative farming area. Obviously not. In Conclusion: Can one be expected to take an or any Environmental Assessment seriously when there is a statement made that “ Cyanide “ can be readily discharged into the Couga Harbour and if it becomes problematical to the Harbour floor it can readily dredged up. No mention is made where the Cyanide deposit should then be deposited. How can Cyanide the most deadliest of poisons to any living system, be irresponsibly discharged into the Harbour or the Eastern Surf zone and when it becomes problematic – be dredged up. No mention is made as to what damage will be caused to the shellfish in the ocean. Is this also of importance? For your information, South Africa has signed the International Agreement NOT TO POLLUTE THE SEA. The Swartkops Trust has researched the world wide the pro’s and con’s of the operation of an Aluminum Smelting plant. The conclusion gained being that in every case, is that these operations without exception are an ecological disaster to the environment and the health of abutting communities. The Trust therefore recommends that taking the following factors into account that an alternative isolated location should found. a) High risk of toxic waste and air pollution. b) Health risk to surrounding communities. c) Risk to the closure of other industries and of loss of jobs due to closure of i.e. citrus farms. d) Low employment due to plant operating functions being filled by qualified and experience imported personnel. e) High risk of sea pollution i.e. cyanide, which will destroy shellfish, bait fish and a large variety of fish that abound in Algoa Bay. Yours faithfully R. McWilliams Chairman Zwartkops Trust

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COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FROM: BRIAN REEVES WESSA EP DATE: 21 October 2002 Sandy & Mazizi Consulting cc P.O. Box 23088 Port Elizabeth 6000 Dear Ms. Wren WESSA EP COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE ESTABLISHMENT OF AN ALUMINIUM SMELTER WITHIN THE COEGA IDZ The proposal to establish an aluminium smelter within the Coega IDZ offers potential to contribute to the economic development of the Eastern Cape. Although the Wildlife and Environment Society of South Africa, Eastern Province Region (WESSA EP) is generally satisfied with the adequacy of the Draft Environment Impact Report, we would hereby like to submit issues that need consideration in the decision-making process. Solid Waste Pechiney has indicated that it will look to send significant quantities of its waste to the proposed recycling centre at Arlington. It would be appropriate for Pechiney, as part of its responsibility to the community, to ensure that this recycling centre is functioning once the smelter becomes operational. Spillage Spillage is listed as a low negative impact, provided that prompt and stringent ‘house-cleaning’ procedures are put in place. In reality, response to spillage may not be prompt due to the logistics involved in co-ordinating the various agencies involved. For this reason, WESSA EP believes that a spill contingency plan be developed as a condition of the record of decision. Effects of emissions on flora and fauna Although the Draft EIR states that certain vegetation show sensitivities to fluoride, no baseline data exist on effects of fluoride on natural vegetation and indigenous animals. This important issue needs consideration because indigenous flora and fauna respond differently to pollutants, and may display a range of sub-lethal physiological effects, which could subtly alter fitness and ecosystem dynamics. The proximity of the proposed smelter to the Greater Addo National Park further emphasises the need to closely examine the effects of emissions on indigenous flora and fauna. WESSA EP would like to further note that an increase in precipitation acidity will alter the availability of certain nutrients in the soil, and will result in additional ecosystem disturbances. The suggested mitigation measure to remove particulate contamination of vegetation habitat utilised by Lyceanid butterflies (i.e. spraying with water) will artificially alter the amount of available water to the vegetation, and may result in changes to plant community structure. This mitigation measure is not practical and is inconsistent with ecological principles. Greenhouse gasses and energy Studies have shown that reductions in greenhouse gas emissions are unlikely in the immediate future from process considerations alone. Reductions are more likely to come from energy conservation measures than from technological developments. For this reason, WESSA EP believes that it is important that Pechiney evaluate possible energy conservation measures that would be implemented in the operation of the smelter. Incineration Although the DWAF Minimum Requirements for the Handling, Classification and Disposal of Hazardous Waste recommend that medical waste be incinerated, WESSA EP maintains that the incineration of medical waste is a

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dirty, destructive and inefficient waste management technique. Medical waste incineration has been identified as the largest cause of dioxins in the environment. Dioxins have devastating effects on foetal development, and are confirmed carcinogens and potent immune system toxins. The US Environment Protection Agency (US EPA) has described dioxins as “one of the most, if not the most, potent of toxins known”. They are dangerous in very small quantities, persist in the environment and tend to bio-accumulate. For this reason, WESSA EP suggests that Pechiney consider alternatives to medical waste incineration. One such alternative is the sterilisation of medical waste (e.g. by autoclaving or microwaves) before recycling or disposal in landfills. The Draft EIR states that dioxins and furans will potentially be emitted from the smelter, but the impact of emitting these substances is not addressed. Wastewater discharge WESSA EP believes that discharge to the marine environment should be avoided. This is aligned with national government’s policy to minimise discharges to the nearshore environment. The dumping of dredge spoil (containing toxins such as cyanide) from maintenance dredging is concerning when the potential status of Algoa Bay as a Particularly Sensitive Sea Area is taken into account. WESSA EP believes that wastewater should undergo treatment before it is allowed to be discharged into the marine environment. Water-use The smelter is expected to use approximately 600 000 cubic meters of water per year. The Eastern Cape experiences periodic severe droughts, and water-use may be limited. How will the Nelson Mandela Metropolitan Municipality’s commitment to supply water to the smelter affect other water users during these periodic droughts? Conveyors Butterfly Valley has been identified as an environmentally sensitive area. However, the conveyor corridor is stated to go through a section of this area. WESSA EP firmly believes that development should not be allowed in this sensitive area. Traffic Although the Draft EIR takes increased traffic levels into account, it does not assess the impact of increased vehicular emissions. WESSA EP believes that this issue should not be overlooked. WESSA EP trusts that its comments will be seen as constructive, and aimed at ensuring an informed decision-making process. Yours sincerely Brian Reeves Environmental Officer

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COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FROM: JOHAN STUMPF SUNDAYS RIVER CITRUS COMPANY DATE: 18 October 2002

COMMENTS Do you have any comments in response to the Draft Environmental Impact Report for the proposed Aluminium Pechiney smelter at Coega? Although the report indicates very little effect on citrus trees, we would like to make comments on and record four specific areas of concern: 1) The broader Coega Development’s effect on the environment is still unknown. The smelter will already utilise approximately a third of the SO2 allowed levels. This does not leave room for a lot of other industries. The SR Valley is very concerned with regard to the cumulative effect by additional developments – both from a specific cumulation of SO2 and HF, as well as the effect that other emissions may have in conjunction with emissions from the smelter. 2) The SRV is ideally situated with regard to natural enemies for citrus pests. Furthermore, the SRCC has a program for breeding Aphytis parasitoids for control of red scale. This is released in large quantities to naturally fight Red scale. As a result of this, the SRV is the citrus area in RSA with the least requirement for chemical control of pests. As this is becoming more and more important in overseas markets, this is a competitive advantage for product from the Sundays River Valley. The effect of emissions from the smelter on both the natural enemies as well as the Aphytis parasitoids is not known. There is no research available on this subject. In the event of these insects being sensitive to emissions, it could be disastrous for the SR Valley and make a large part of the citrus industry unviable; currently providing jobs for up to 30 000 people in season. Ideally the SR valley would prefer that the EIA include some detail assessment on the effect of emissions on these insects, as insects are much more sensitive to emissions than vegetation. 3) In order to monitor trends with regard to air quality, the SR Valley would prefer that monitoring should be expanded to include the SR Valley. Current monitoring locations at Motherwell, Amsterdam Plain and Coega are not sufficient to indicate negative trends within the citrus growing area. The SRV would prefer if Pechiney and/or the LDC can contribute to air monitoring equipment at Barkley Bridge, Addo and at Kirkwood. 4) Although the SR Valley acknowledges that the probability for a negative effect on the citrus industry is small, there is a chance that with other industries locating within the IDZ as well as the unknown effect of emissions on the natural enemies of citrus pests, the citrus industry could be negatively affected. The SR Valley would like to see a policy with regard to compensation of the citrus industry in the SR Valley, should such damage occur. In general, if above four points could be addressed, the Sundays River Valley would support the development of the Pechiney Aluminium Smelter in the Coega IDZ.

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Do you have any specific comments, which you would like to raise in connection with the Environmental Impact Assessment Process? No. Regards Johan Stumpf MANAGING DIRECTOR Representing: Sundays River Citrus Company (Pty) Ltd and the citrus industry in the Sundays River Valley Contact details: 042 – 233 0320 (Tel) 042 – 233 0014 (Fax) [email protected]

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