SKUKUZA WASTE

SITE – S24G

RECTIFICATION

APPLICATION

PROJECT: Rectification of illegal activities undertaken at the Skukuza Waste site under NEMA and the Waste Act through a S24G process. APPLICANT: South African National Parks PROPERTY: Skukuza, Kruger National Park Governments Grond 142KU CONSULTANT: EMROSS Consulting P.O. Box 507 White River 1240 EAP: Mette Stavnsbo Rossaak

27 October 2016

Skukuza Waste Site S24G application __________________________________________________________________________________________________________________________________

Compiled by: EMROSS Consulting Page 1 of 3 e-mail: andrew@emross.co.za Version: 1.0

1. INTRODUCTION

EMROSS Consulting (Pty) Ltd. was appointed by Kruger National Park, as independent consultants,

to undertake the S24G rectification process for the Skukuza waste site. The processed was initiated

following a site visit and inspection by the lead authority who indicated in discussions on site that

KNP had commenced with a listed activity without environmental authorisation.

2. BACKGROUND

During 2013, KNP was offered a donation of waste management equipment from Nampack to

improve the existing Skukuza waste facility. This equipment would assist in reducing the impact of

the waste and improve waste recycling. KNP accepted this offer and proceeded with the site

improvements, not realising that the expansion would require an environmental authorisation.

During a site inspection on the 4th October 2013, attended by representatives from Department of

Environmental Affairs, Ehlanzeni District Municipality, Mpumalanga Department of Economic

Development Environment and Tourism, Department of Water Affairs and Kruger National Park, it

was discussed and agreed verbally that KNP should seek rectification under NEMA section 24G for

commencing listed activities without authorisation.

It should be noted that KNP have not received any formal letter or notification of non-compliance of

the waste site from any authority. The rectification process offered under section 24G of the National

Environmental Management Act is a voluntary process. This application is an effort by KNP to seek

rectification in order to ensure compliance going forward.

3. PROCESS

The information on exactly what activities had been deemed to be triggered by the authorities was

not clear and requests for information in this regard received no response. Emross have, therefore,

considered all aspects of the activity that could be illegal and have advised KNP to seek rectification

for all of these. The existing waste licences (issued under old legislation with no volume limits or

guides) do not reflect the actual waste management activities conducted on site, so it is likely that

these will have to be amended or reissued with new licences under the current legislation. With this

in mind, the application for rectification under the S24G includes all the activities.

As the application process for S24G rectification for environmental regulations can be combined with

for those for waste regulations, this has been undertaken and all applications are in this single

document.

Skukuza Waste Site S24G application __________________________________________________________________________________________________________________________________

Compiled by: EMROSS Consulting Page 2 of 3 e-mail: andrew@emross.co.za Version: 1.0

4. S24 G RECTIFICATION DOCUMENTS

The following documentation is provided:

1. This covering letter providing background

2. NEMA, NEM:WA, NEM:AQA S24G application for rectification form - completed

3. Appendices

a. Location maps and satellite images, before and after

b. Site plans before and after

c. Photographs of site

d. Existing permits and licenses, services provision and public participation

e. Applicant documentation

Full details of the specific regulations against which rectification are being sought are provided in

the completed application form.

5. PUBLIC PARTICIPATION

The required public participation process in an S 24G application was not defined, under the 2010

EIA regulations – and in this instance, the interested and affected parties (I & AP’s) are not clearly

defined. An email was sent to DEA – waste on the 17 February 2014 regarding public participation

process with a proposal. No reply has been received. It is therefore taken that this proposal was

found to be acceptable. This rectification process was commenced under the 2010 EIA regulations,

and the public participation was conducted in September – November of 2014. The public

participation process followed is:

Advertising of the application in local newspaper (The Lowvelder) and on the SANParks

website;

Direct notification of identified stakeholders (MDEDET, EDC, ICMA - this is essentially all the

officials who have been involved up to now);

Allowance for a 21 days comment period; and

Advertising and direct notification to registered stakeholders of decision once made.

Skukuza Waste Site S24G application __________________________________________________________________________________________________________________________________

Compiled by: EMROSS Consulting Page 3 of 3 e-mail: andrew@emross.co.za Version: 1.0

6. FINDINGS

The Skukuza waste site was visited and assessed after the expansion had been undertaken. The

state of the site was compared to historic information and satellite imagery. The following findings

were made.

The site has been in operation since 1994 and since then much progress has been made in

waste recycling technology and best practices.

The expansion of the site was found to have had minimum impact on the surrounding

environment. Much of this was already impacted by the Skukuza development itself. This is

despite the activity being undertaken in a National Park.

The site was found to be in an appropriate location, in relation to other developments within

the Skukuza Camp and sources of waste.

The storm water management and drainage was found to not be in accordance with the

National norms and standards for the storage of waste (NNSSW).

The legal document and procedure documentation management was not found to be easily

available for assessment.

7. CONCLUSION

The application for rectification is necessary and important for the state conservation agency. The

rectification process should be followed up with a review and improvement of the operating

procedures.

The error in not obtaining authorisation prior to the expansion was due, in part, to the expectation

that the waste licence in place was appropriate.

NEW Version: Section 24G Application form

DEPARTMENT OF ENVIRONMENTAL AFFAIRS Application form for the rectification of unlawful commencement or continuation of a listed activity in terms of S24G of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended.

WASTE 2015

Kindly note that: 1. This application form must be completed for all applications in terms of S24G of the National

Environmental Management Act, 1998 (Act No. 107 of 1998), as amended. 2. It is the responsibility of the Applicant / Environmental Assessment Practitioner (EAP) to ascertain

whether subsequent versions of the application form have been published or produced by the relevant competent authority.

3. The content of the application for rectification form comprises of: Section A: Application Information Section B: Activity Information Section C: Description of Receiving Environment Section D: Preliminary Impact Assessment Section E: Alternatives Section F: Appendices Section G: Declarations

4. An independent EAP must be appointed to complete the application form on behalf of the applicant; the declaration of independence must be completed by the independent EAP and submitted with the application.

5. The required information must be typed within the spaces provided. The sizes of the spaces provided are not necessarily indicative of the amount of information to be provided. The space provided extend as each space is filled with typing. A legible font type and size must be used when completing the form. The font size should not be smaller than 10pt (e.g. Arial 10).

6. The use of “not applicable” in the application form must be done with circumspection. 7. No faxed or e-mailed applications will be accepted. This application form must be submitted by hand

or mailed to the relevant competent. 8. Unless protected by law, all information contained in and attached to this application form may

become public information on receipt by the competent authority. Upon request, any interested and affected party must be provided with the information contained in and attached to this application form.

9. This application form constitutes the initiation of the S24G application process.

DEPARTMENTAL DETAILS

The Deputy Director General: Chemicals and Waste Management

Department of Environmental Affairs Private Bag X447 Pretoria South Africa 0001 SECTION A: APPLICATION INFORMATION

1. APPLICANT PROFILE INDEX

Cross out the appropriate box “”.

1.1 The applicant is an individual YES NO

1.2 The applicant is a company YES NO

1.3 The applicant is a state-owned enterprise or municipality YES NO

1.4 Other (specify) YES NO

1.5 There is more than one individual / company responsible for the unlawful commencement of listed activities

YES NO

Name of Project applicant:

South African National Parks – Kruger National Parks

RSA Identity number: 7 8 0 3 3 0 0 0 7 5 0 8 2

Contact person: Tracy-Lee Petersen

Position in company Environmental Manager

Registered Name of Company/ Closed

Corporation

Trading name (if any):

Registration number

Postal address: PO Box 394

SKUKUZA Postal code:

1350

Telephone: (013)735 4271 Cell: 072 020 7529

E-mail: Tracy.petersen@sanparks.org Fax: (013) 735 4051

Please Note: In instances where there is more than one individual / company responsible for the unlawful commencement of listed activities, please attach a list of with all contact details to the back of this page.

Environmental Assessment Practitioner

(EAP): EMROSS Consulting (Pty) Ltd.

Contact person: Mette Rossaak

Postal address: PO Box 507

WHITE RIVER Postal code: 1240

Telephone: (013) 750 2782 Cell: 082 339 9627

E-mail: mette@emross.co.za Fax: 086 675 4320

EAP Qualifications BSc. Hons Botany and +10 years of experience as EAP

EAP Registrations/Associations

ICB-EAPSA. IAIAsa

Name of Landowner(s): South African National Parks

Contact person(s): Tracy-Lee Petersen

Postal address: PO Box 394

SKUKUZA Postal code: 1350

Telephone: (013) 735 4271 Cell: 072 020 7529

E-mail: Tracy.petersen@sanparks.org Fax: (013) 735 4051

Please Note: In instances where there is more than one landowner, please attach a list of landowners with their contact details to the back of this page.

Municipality in whose area of jurisdiction the activity

falls: MPDMA32 Ehlanzeni District Municipality

Contact person: H. Mbuli

Postal address: 8 van Niekerk Street

NELSPRUIT Postal code: 1200

Telephone (013) 759 8593 Cell: 072 080 1821

E-mail: hmbuli@ehlanzeni.gov.za Fax: ( )

Please Note: In instances where there is more than one Municipality involved, please attach a list of Municipalities with their contact details to the back of this page.

Project title: Expansion Skukuza Waste Management Facility

Property location: Skukuza Camp, Kruger National Park

Farm/Erf name & number (incl. portion):

Governments Grond 142KU

SG21 Digit code: T0KU00000000014200000

Co-ordinates: Latitude (S): Longitude (E):

24o 59‘ 45.708“ 31o 36‘ 12.636“

Please Note: Where a large number of properties are involved (e.g. linear activities), attach a list of property descriptions to the back of this page. Indicate the position of the activity using the latitude and longitude of the centre point of the site for each alternative site. The co-ordinates must be in degrees, minutes and seconds. The minutes must be given to at least three decimals to ensure adequate accuracy. The EAP is required to contact the relevant competent authority with regards to the projection that must be used.

Street address: Na.

Magisterial District or Town:

SKUKUZA

Please Note: In instances where there is more than one town or district involved, please attach a list of towns or districts as well as complete physical address information for the entire area to the back of this page.

Closest City/Town: Skukuza Distance 0 Km

Zoning of Property: Conservation

Please Note: In instances where there is more than one zoning, please attach a map clearly indicating the zoning of the different portions.

Was a rezoning application required? YES NO

Was a consent use application required? YES NO

Please Note: Where planning approvals have been granted please attach the relevant approvals.

Owners consent: Letters of consent from all landowners or a detailed explanation by the applicant explaining why such letters of consent are not furnished must be attached to the application form. .

2. APPLICATION HISTORY (Cross out the appropriate box “” and provide a description where required).

Has any national, provincial or local authority considered any development applications on the property previously?

Yes No

If so, please give a brief description of the type and/or nature of the application/s: (In instances where there were more than one application, please attach a list of these applications)

An application for waste disposal was submitted in July 2000 and an application for waste

disposal was submitted in June 2002.

Which authority considered the application(s):

In 2000 Department of Water Affairs and Forestry: Northern Province. In 2002 Department

of Water Affairs and Forestry: Mpumalanga.

Has any one of the previous application/s on the property been approved or rejected? If so provide a list of the successful and unsuccessful application/s and the reasons for decision/s.

Yes No

Both applications were approved. Ref 16/2/7/B900/Z20/1 and 16/2/7/X301/D37 respectively

Provide detail on the period of validity of decision(s) and expiry dates of the above applications/ permits etc.

No period of validity or expiry dates are indicated.

I hereby apply in terms of Section 24 G of the National Environmental Management Act (Act no 107 of 1998 as amended) for the rectification of the unlawful commencement or continuation of the listed activity(ies) in Section B of the application form:

Applicant (Full names)__Tracy-Lee Petersen______________ Signature:_______________________ Place: _______SKUKUZA____________________________ Date: ____________________________ EAP (Full names)__Mette Stavnsbo Rossaak_____________ Signature:_________________________ Place: __________WHITE RIVER_____________________ Date: ____________________________

SECTION B: ACTIVITY INFORMATION

1. ACTIVITIES APPLIED FOR: Separate rectification applications are required for one development site where more than one listed activity has commenced and where these unlawfully commenced activities constitute offences in terms of different EIA regulations (refer to Table 1 & 2 of the S24G guideline). Applicants and EAPS are strongly advised to discuss the merits of a combined application (if deemed applicable) with the relevant competent authority prior to the completion of this application form and submission thereof. The relevant competent authority will use its discretion in deciding to allow one rectification application for more than 1 Section 24F(2(a) contravention on one development site. All potential listed activities associated with the development must be indicated below. (See Annexures B, C, D and E). Only those activities for which the applicant applies will be considered. The onus is on the applicant to ensure that all the applicable listed activities are included in the application. Listed activities applied for. Identify the relevant listed activities applied for below:

ECA EIA Contraventions : Between 08 September 1997 end of day 09 May 2002

Activities unlawfully commenced with on or after 08 September 1997 and before end 09 May 2002: EIA Regulations promulgated in terms of the ECA, Act No 73 of 1989, as amended

Listed Activity(ies) Details of Activity(ies)

ECA EIA Contraventions : Between 10 May 2002 and before end of day 02 July 2006

Activities unlawfully commenced with on or after 10 May 2002 and before end 02 July 2006: EIA Regulations promulgated in terms of the ECA, Act No 73 of 1989, as amended

Listed Activity(ies) Details of Activity(ies)

NEMWA, 2009: Between 01 July 2009 and before 29 November 2013

Activities unlawfully commenced with in terms of the NEMWA, 2008 promulgated in terms of the NEMA, Act No 107 of 1998 after 01 July 2009 and…

Government Notice No. 718 List of Waste

Management Activities No(s):

Details of Activity(ies) requiring Basic Assessment

Government Notice No. 718 List of Waste

Management Activity No(s):

Details of Activity(ies) requiring a Scoping Report and EIA

NEMWA, 2013: Between 29 November 2013 and before end of day

Activities unlawfully commenced with in terms of the NEMWA, 2008 promulgated in terms of the NEMA, Act No 107 of 1998 after 29 November 2013 and…

Government Notice No. 921 List of Waste Management Activities No(s):

Details of Activity(ies) requiring Basic Assessment

3 (3) The recycling area at Skukuza as upgraded is 6000m2

3 (13) The expansion of the existing Skukuza waste site with 3500m2

5 (1) The storage of general waste at a facility that has the

Government Notice No. 921 List of Waste Management Activity No(s):

Details of Activity(ies) requiring a Scoping Report and EIA

3 (2) The sorting, shredding, crushing, screening and bailing of fractions of general waste, generated at Skukuza. To send for recycling

capacity to store 128m2 of unsorted general waste at any one time. Excluding the stored sorted wastes to be sent for recycling.

2. ACTIVITY DESCRIPTION (Cross out the appropriate box “” and provide a description where required).

(a) Is/was the project a new development or an upgrade of an existing development? New Upgrade

(b) Clearly describe the activity and associated infrastructure commenced with, indicating what has been completed, what still has to be completed and applicable commencement dates.

The existing authorised waste site has been expanded by 3500m2, from 2500m2 to 6000m2. The boundary fence has been relocated to enclose the new area. The following upgrades have been done: Two conveyer belts have been installed at the waste recovery facility, two storage shelters have been constructed along with waste storage cages, for storage of recyclable materials hazardous waste drums. An ablution block with 6 showers, 4 toilets and a kitchen area has been constructed, along with a one track through road constructed to facilitate truck movement.

(c) Provide details of all components of the activity and attach diagrams (e.g. architectural drawings or perspectives, engineering drawings, process flow charts etc.).

Buildings YES NO

Provide brief description:

Shelters for the sorted waste fractions and ablution block has been constructed.

Infrastructure (e.g. roads, power and water supply/ storage) YES NO

Provide brief description: A one track road has been constructed to facilitate truck movement around the recycling facility.

Processing activities (e.g. manufacturing, storage, distribution) YES NO

Provide brief description: Two conveyor belts have been installed at the waste recovery facility, one for recyclable materials and one for non-recyclable materials, in order to facilitate the sorting of wastes.

Storage facilities for raw materials and products (e.g. volume and substances to be stored)

Provide brief description YES NO Two cages have been erected for the storage of wastes received and two shelters have been constructed to shelter the recovered and sorted materials awaiting collection for recycling.

Storage and treatment facilities for solid waste and effluent generated by the project Yes No

Provide brief description

Other activities (e.g. water abstraction activities, crop planting activities) Yes No

Provide brief description

3. ACTIVITY NEED AND DESIRABILITY

Describe the need and desirability of the activity:

It is desirable to improve the waste management at Skukuza, to improve the levels of recycling and reduction

of waste incineration and disposal. The upgrading of the facility is not only desirable from an environmental

point of view but also from a labour point of view, in that it has improved the working conditions for the people

employed on site.

Indicate the benefits that the activity has/had for society in general and also indicate what benefits the activity has/had for the local communities where it is located:

As Kruger National Park is the property of the people of South Africa it is in the interest of society that the

operations at Skukuza is following best environmental practice.

4. PHYSICAL SIZE OF THE ACTIVITY

Indicate the physical spatial size of the activity as well as associated infrastructure (footprints):

6000 m2

Indicate the area that has been transformed / cleared to allow for the activity as well as associated infrastructure

6000 m2

Total area (sum of the footprint area and transformed area) 6000 m2

5. SITE ACCESS

Was there an existing access road? YES NO

If no, what was the distance over which the new access road was built? m

Describe the type of access road constructed: [indicate the position of the access road on the site plan]

6. SITE PHOTOGRAPHS Colour photographs of the site and its surroundings (taken of the site and from the site), both before (if available) and after the activity commenced, with a description of each photograph must be attached to this application. The vantage points from which the photographs were taken must be indicated on the site plan, or locality plan as applicable. If available, please also provide past and recent aerial photographs. It should be supplemented with additional photographs of relevant features on the site. Date of photographs must be included. Photographs must be attached under Appendix D to this form.

7. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES Please list all legislation, policies and/or guidelines that were or are relevant to this activity.

Legislation Administering Authority Type

Permit/ license/ authorization/comment

Date (if already obtained):

NEMA DEA Authorisation No

NEM:AQA Ehlanzeni DM License No

NEM:WA DEA License No

NEM:BA SAN Parks / DEA Comment No

POLICY/ GUIDELINES ADMINISTERING AUTHORITY

Norms and Standards for Storage of Waste 2013 DEA

SECTION C: DESCRIPTION OF RECEIVING ENVIRONMENT

Site/Area Description For linear activities (pipelines etc) as well as activities that cover very large sites, it may be necessary to complete copies of this Section for each part of the site that has a significantly different environment. In such cases please complete copies of Section C and indicate the area which is covered by each copy No. on the Site Plan.

Section C Copy No. (e.g. 1, 2, or 3):

1. GRADIENT OF THE SITE

Indicate the general gradient of the site(s) (cross out the appropriate box).

Flat Flatter than 1:10 1:10 – 1:5 Steeper than 1:5

2. LOCATION IN LANDSCAPE

Indicate the landform(s) that best describes the site (cross out (“”) the appropriate box (es).

Ridgeline Plateau Side slope

of hill/mountain

Closed valley

Open valley

Plain Undulating

plain/low hills Dune

Sea-front

Other

3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE Is the site(s) located on or near any of the following [cross out (“”) the appropriate boxes]?

Shallow water table (less than 1.5m deep) YES NO UNSURE

Seasonally wet soils (often close to water bodies) YES NO UNSURE

Unstable rocky slopes or steep slopes with loose soil YES NO UNSURE

Dispersive soils (soils that dissolve in water) YES NO UNSURE

Soils with high clay content YES NO UNSURE

Any other unstable soil or geological feature YES NO UNSURE

An area sensitive to erosion YES NO UNSURE

If any of the answers to the above are “YES” or “UNSURE”, specialist input may be requested by the Department. Information in respect of the above will often be available at the planning Sections of local authorities. Where it exists, the 1:50 000 scale Regional Geotechnical Maps prepared by Geological Survey may also be used.

4. SURFACE WATER Indicate the surface water present on and or adjacent to the site and alternative sites (cross out (“”)

the appropriate boxes)?

Perennial River YES NO UNSURE

Non-Perennial River YES NO UNSURE

Permanent Wetland YES NO UNSURE

Seasonal Wetland YES NO UNSURE

Artificial Wetland YES NO UNSURE

Estuarine / Lagoonal wetland YES NO UNSURE

5. VEGETATION AND GROUNDCOVER

5.1 VEGETATION / GROUNDCOVER (PRE-COMMENCEMENT) Cross out (“”) the block or describe (where required) the vegetation types / groundcover present on the site before commencement of the activity.

Indigenous Vegetation - good condition

x Indigenous Vegetation with scattered aliens

x Indigenous Vegetation with heavy alien infestation

Describe the vegetation type above:

Describe the vegetation type above: Describe the vegetation type above:

Granite Lowveld

Provide ecosystem status for above:

Provide ecosystem status for above: Provide Ecosystem status for above:

Vulnerable/ moderately protected

Indigenous Vegetation in an ecological corridor or along a soil boundary / interface

Veld dominated by alien species

Distinctive soil conditions (e.g. Sand over shale, quartz patches, limestone, alluvial deposits, termitaria etc.) – describe

Bare soil

Building or other structure

Sport field

Other (describe below) Cultivated land Paved surface

Natural veld impacted by neighbouring activities, fencing and material storage

5.2. VEGETATION / GROUNDCOVER (POST-COMMENCEMENT) Cross out (“”) the block or describe (where required) the vegetation types / groundcover present on the site after commencement of the activity.

Indigenous Vegetation - good condition

Indigenous Vegetation with scattered aliens

Indigenous Vegetation with heavy alien infestation

Describe the vegetation type above:

Describe the vegetation type above: Describe the vegetation type above:

Provide ecosystem status for above:

Provide ecosystem status for above: Provide Ecosystem status for above:

Indigenous Vegetation in an ecological corridor or along a soil boundary / interface

Veld dominated by alien species

Distinctive soil conditions (e.g. Sand over shale, quartz patches, limestone, alluvial deposits, termitaria etc.) – describe

Bare soil

Building or other structure

Sport field

Other (describe below) Cultivated land Paved surface

Please note: The Department may request specialist input/studies depending on the nature of the vegetation type / groundcover and impact(s) of the activity/ies. To assist with the identification of the vegetation type and ecosystem status consult http://bgis.sanbi.org or BGIShelp@sanbi.org. Information is also available on compact disc (cd) from the Biodiversity-GIS Unit, Ph (021) 799 8698. This information may be updated from time to time and it is the applicant/ EAP’s responsibility to ensure that the latest version is used.

5.3 VEGETATION / GROUNDCOVER MANAGEMENT Describe any mitigation/management measures that were adopted and the adequacy of these:

No apparent mitigation measures appear to have been adopted

6. LAND USE CHARACTER OF SURROUNDING AREA (PRE-COMMENCEMENT) Cross out (“”) the block that reflects the past land uses and/or prominent features that occur/red within +/- 500m radius of the site and neighbouring properties if these are located beyond 500m of the site. Please note: The Department may request specialist input/studies depending on the nature of the land use character of the area and impact(s) of the activity/ies.

Untransformed area Low density residential

Medium density residential

High density residential

Informal residential

Retail Commercial & warehousing

Light industrial Medium industrial Heavy industrial

Power station Office/consulting room

Military or police base/station/compound

Casino/entertainment complex

Tourism & Hospitality facility

Open cast mine Underground mine

Spoil heap or slimes dam

Quarry, sand or borrow pit

Dam or reservoir

Hospital/medical center

School Tertiary education facility

Church Old age home

Sewage treatment plant

Train station or shunting yard

Railway line Major road (4 lanes or more)

Airport

Harbour

Sport facilities Golf course Polo fields Filling station

Landfill or waste treatment site

Plantation Agriculture River, stream or wetland

Nature conservation area

Mountain, koppie or ridge

Museum Historical building Graveyard Archaeological site

Other land uses (describe):

7. REGIONAL PLANNING CONTEXT

Is/was the activity permitted in terms of the property’s existing land use rights? Please explain

The area is set off for conservation and tourism purposes. The waste recycling facility is an associated facility

of these uses.

Is/was the activity in line with the following?

o Provincial Spatial Development Framework (PSDF) YES NO Please explain

Specific activities in the KNP falls outside of these planning frameworks. The area is set off for conservation

and tourism purposes. The waste recycling facility is an associated facility of these uses.

o Urban edge / Edge of Built Environment for the area YES NO Please explain

Specific activities in the KNP falls outside of these planning frameworks. The area is set off for conservation

and tourism purposes. The waste recycling facility is an associated facility of these uses.

o Integrated Development Plan of the Local Municipality YES NO Please explain

Specific activities in the KNP falls outside of these planning frameworks. The area is set off for conservation

and tourism purposes. The waste recycling facility is an associated facility of these uses.

o Spatial Development Framework of the Local Municipality YES NO Please explain

Specific activities in the KNP falls outside of these planning frameworks. The area is set off for conservation

and tourism purposes. The waste recycling facility is an associated facility of these uses.

o Approved Structure Plan of the Municipality YES NO Please explain

Specific activities in the KNP falls outside of these planning frameworks. The area is set off for conservation

and tourism purposes. The waste recycling facility is an associated facility of these uses.

o Any other Plans YES NO Please explain

Specific activities in the KNP falls outside of these planning frameworks. The area is set off for conservation

and tourism purposes. The waste recycling facility is an associated facility of these uses.

8 SOCIO-ECONOMIC CONTEXT

8.1 SOCIO-ECONOMIC CONTEXT (PRE-COMMENCEMENT)

Describe the pre-commencement social and economic characteristics of the community in order to provide baseline information.

The site is part of a nationally protected area

8.2 SOCIO-ECONOMIC CONTEXT (POST-COMMENCEMENT) Describe the post commencement social and economic characteristics of the community in order to determine any change.

No change to the pre-commencement

CULTURAL/HISTORICAL FEATURES

Were there any signs or evidence (unearthed during construction) of culturally or historically significant elements including archaeological or palaeontological sites, on or in close proximity to the site?

YES NO

UNCERTAIN

If YES, explain:

If uncertain, the Department may request that specialist input be provided to establish whether such possibilities occurred on or close to the site. Briefly explain the findings of the specialist if one was already appointed:

Were any buildings or structures older than 60 years affected in any way? YES NO

Was it necessary to apply for a permit in terms of the National Heritage Resources Act, 1999 (Act 25 of 1999)?

YES NO

If yes, please submit or, make sure that the applicant or a specialist submit the necessary application to SAHRA or the relevant provincial heritage agency and attach proof thereof to this application.

SECTION D: PRELIMINARY IMPACT ASSESSMENT Please note, the impacts identified below refer to general impacts commonly associated with development activities. The list below is not exhaustive and may need to be supplemented. Where required, please append the information on any additional impacts to this application.

1. WASTE, EFFLUENT AND EMISSION MANAGEMENT (a) Solid waste management

Did/does the activity produce any general waste (e.g. domestic-, commercial-, certain industrial waste, including building rubble also known as solid waste) during the construction phase and/or the operational phase?

YES NO

If yes, briefly describe what type of waste was produced (i.e. green waste, building rubble, etc.) in which phase.

What quantity was/is produced during the construction period? m3

What was/is the estimated quantity that will be produced per month during the operational phase?

m3

Did/does the activity produce any hazardous waste (e.g. chemical, medical waste, infectious, nuclear etc.) during the construction and/or the operational phase?

YES NO

If yes, briefly describe what type of waste was produced (i.e. infectious waste, medical waste, etc.) in which phase.

What quantity was/is produced during the construction period? m3

What was/is the estimated quantity that will be produced per month during the operational phase?

m3

Where and how was/is waste treated / disposed of (describe each waste stream)?

Has the municipality or relevant authority confirmed that sufficient capacity exist for treating / disposing of the solid waste to be generated by this activity(ies)? If yes, provide written confirmation from municipality or relevant authority

YES NO

Does/did the activity produce solid waste that was/will be treated and/or disposed of at another facility other than into a municipal waste stream?

YES NO

If yes, did/has this facility confirmed that sufficient capacity exist for treating / disposing of the solid waste to be generated by this activity(ies)? Provide written confirmation from the facility and provide the following particulars of the facility:

YES NO

Did/does the facility have an operating license? (If yes, please attach a copy of the license.) YES NO

Facility name: Skukuza Waste Disposal Site Contact person: Ben du Plessis Postal address: Kruger National Park, Private Bag X402

Skukuza Postal code: 1350

Telephone: 013 735 4271 Cell:

E-mail: Ben.duplessis@sanparks.org Fax:

(b) Effluent

Did/does the activity produce sewage and or any other effluent? YES NO

What was/is the estimated quantity produced per month? 21 m3 Was/is the effluent treated and/or disposed of in a municipal system? YES NO If Yes, did/has the Municipality or relevant authority confirmed that sufficient unallocated capacity exist for treating / disposing of the sewage or any other effluent generated by this activity(ies)? Provide written confirmation from the Municipality or relevant authority. Was/is any effluent produced be treated and/or disposed of on site? YES NO If yes, briefly describe the nature of the effluent and how it was/will be disposed of: Did/does the activity produce effluent that was/will be treated and/or disposed of at another facility?

YES NO

If yes, did/has this facility confirmed that sufficient capacity exist(ed) for treating / disposing of the liquid effluent generated by this activity(ies)? Provide written confirmation from the facility and provide the following particulars of the facility:

YES NO

Does the facility have an operating license? (If yes, please attach a copy of the license.) YES NO Facility name: Skukuza Waste Water Treatment Facility Contact person: Ben du Plessis Postal address: Kruger National Park , Private Bag X402

SKUKUZA Postal code: 1350

Telephone: 013 735 4271 Cell:

E-mail: Ben.duplessis@sanparks.org Fax:

Describe the measures that was/will be taken to ensure the optimal reuse or recycling of waste water, if any: No apparent efficiency measures have been adopted

(c) Emissions into the atmosphere

Did/does the activity produce emissions that will be disposed of into the atmosphere? YES NO If yes, did/does it require approval in terms of relevant legislation? If yes, attach a copy to this application

YES NO

Describe the emissions in terms of type and concentration and how it was/will be treated/mitigated: The site has six waste incinerators. This is a historic installation and was not part of the expansion.

The facility does not have an atmospheric Emissions license for this.

NEM:WA GNR248 part 17, category 8: The disposal of general waste by incineration.

The emissions are not measured.

(d) Describe any mitigation/management measures that were adopted and the adequacy of these: No apparent mitigation measures have been adopted. Without emission measures it is difficult to establish

the need for mitigation.

2. WATER USE (a) Please indicate the source(s) of water for the activity by crossing out (“”) the appropriate box(es)

Municipal Water Board

Groundwater River, Stream, Dam

or Lake Other

The activity did/does not use water

If water was/is extracted from a groundwater source, river, stream, dam, lake or any other natural feature, please indicate the volume that

was/is extracted per month: Not measured m3 Please provide proof of assurance of water supply eg. letter of confirmation from Municipality/water user associations, yield of borehole etc.

Did/does the activity require a water use permit / license from DWAF? If yes, attach a copy to this application

YES NO

If yes, please submit the necessary application to Department of Water Affairs and Forestry and attach proof thereof to this application.

(b) Describe any mitigation/management measures that were adopted and the adequacy of these: No apparent mitigation measures have been adopted. The facility has the potential for water saving installations, but these have not been utilized.

3. POWER SUPPLY (a) Please indicate the source of power supply eg. Municipality / Eskom / Renewable energy source.

Eskom

Has the Municipality or relevant service provider confirmed that sufficient electricity capacity (i.e. generation, supply and transmission) exist for activity(ies)? If yes, provide written confirmation from Municipality or relevant service provider.

YES NO

If power supply was/is not available, where was/is it sourced from?

(b) Describe any mitigation/management measures that were adopted and the adequacy of these:

A solar geyser has been installed to provide hot water for the shower facilities. No other apparent power saving measures appear to have been considered.

4. ENERGY EFFICIENCY (a) Describe the design measures, if any, that have been taken to ensure that the activity is energy efficient: No apparent design measures have been applied to ensure energy efficiency.

(b) Describe how alternative energy sources have been taken into account or been built into the design of the activity, if any: A solar geyser has been installed to supply hot shower water.

5. NOISE IMPACTS

(a) Did/does the activity result in any noise impacts? YES NO If yes, please describe and indicate the measures implemented to mitigate and manage these impacts?

The waste management activity results in general noise from trucks, bailers and crushers. No apparent noise mitigation measures have been installed.

Please note: The Department may request specialist input/studies depending on the nature of the land use character of the area and potential noise impact(s) of the activity/ies.

6. VISUAL IMPACTS

(a) Did/does the activity result in any visual impacts? YES NO

If yes, please describe and indicate the measures implemented to mitigate and manage these impacts?

(b) Did/does the activity result in potential lighting impacts at night? YES NO

If yes, please describe and indicate the measures implemented to mitigate and manage these impacts? (c) Were/are there any alternatives available to address this impact? YES NO If yes, please describe these alternatives?

Please note: The Department may request specialist input/studies depending on the nature of the land use character of the area and potential visual impact(s) of the activity/ies.

7. SOCIO-ECONOMIC IMPLICATIONS OF THE ACTIVITY

(a) What was/is the expected capital value of the activity on completion? R 8 000 000.00

(b) What was/is the expected yearly income or contribution to the economy that will be generated by or as a result of the activity?

R 300 000.00

(c) Did/does the activity contribute to service infrastructure? YES NO

(d) How many permanent new employment opportunities were created? 9 (e) What was/is the expected current value of the employment opportunities to date? R (f) What percentage of this accrued to previously disadvantaged individuals? 100 %

How was (is) this (to be) ensured and monitored (please explain):

8. PRELIMINARY IMPACT ASSESSMENT Briefly describe the impacts (as appropriate), significance rating of impacts and significance rating of impacts after mitigation. This must include an assessment of the significance of all impacts. Please note: This is a preliminary impact statement. The Department may request specialist input/studies depending on the type and nature of the impact(s) of the activity/ies.

Possible Impacts

Significance rating of impacts after mitigation (Low, Medium, Medium-High, High, Very High):

The expansion of the waste management facility, has had minimal impact on the physical environment.

Low

3500m2 of a vulnerable vegetation type has been cleared. As the area was not part of a functional ecosystem, this is not considered a significant loss.

Low

The site consumes minimal resource; power and water. This has not been changed mush by the expansion.

Low

The site has minimal waste output; sewage. This has not been changed mush by the expansion.

Low

SECTION E: ALTERNATIVES As part of this report, consideration must be given to alternatives that are/may have been possible had an environmental impact assessment been undertaken prior to the commencement of the activity. Please provide a detailed description of the alternatives (whether location, technology or environmental) that were/are possible in terms of this application.

Kruger Park received a donation of equipment for the sorting of waste at the waste management facility, and a decision was made to expanded the site to improve the storage space and the accessibility of the facility.

There are no reasonable alternatives to the improved accessibility.

There are various alternatives to the technology and mode of operating the waste management facility. None of these would result in less space requirement.

The assessed impacts of the expansion are not considered significant and as such the requirement for an alternative is not considered relevant.

SECTION F: APPENDICES The following appendices must be attached where appropriate:

Appendix Cross out (“”) the box if Appendix is attached

Appendix A: Location map X

Appendix B: Site plan(s) X

Appendix C: Owner(s) consent(s) X

Appendix D: Photographs X

Appendix E: Permit(s) / license(s) from any other organ of state including service letters from the municipality

X

Appendix F: Additional Impact Assessment Information

Appendix G: Report on alternatives

Appendix H: Any Other (describe)

SECTION G: DECLARATIoNS

G1: Declarations ot the EAP

f.

c.d .

lndeDendent Environmenial Assessment Practitio

declare undef oath that l-act as the independent environmental assessment practitionef in this application ;do not have and will not have any financial interest in the lndertaking of the aclivity, othef thanremuneration forwork performed in lerms of the S24G of the National Environmenial lvanagementAcl, read togetherwith the felevant Environmental lmpact Assessment Regulaiions;do not have and will noi have a vested interest in the proposed activity prcceedlng;have no, and will not engage in, conllicting interests in the undedaking ofthe activity;undertake to dlsclose, to the competent auihority, any material information that has of may have thepotentialto inlluence the decjsion ofthe competent authoity oflhe objectivity of any fepod, plan ordocumenl required in terms of the S24G ol the Naiional Environmental l\,lanagernent Act, readtogethef wlth the Environmental lmpactAssessmentRegulations, 2006;will ensure lhal all documents will contain a I relevant facts in respect of the app ication & that alldocumentation is distibuted or made available to interesled and affected padies. I wil ensure thatparticipaUon by interested and affected parties is facilitated in such a manner that ail interested andaffected padleswillbe provjdedwith a feasonable opportunityto parlidpate and to provide comnentson documents that are prcduced forth rectification application.will ensufe ihat lhe comments of all inierested and affecied parties are considered and recorded inrepofrs thal are submitted to the competent authority in respect of the application, provided thatcomments that are made by interested and affected parties in respect of a final report that will besubmitted to the competent authodty may be atiached to the repori without lurther amendment to there0on:

h. will keep a register of all interested and affected parties that participated in a publicparticipation process; and

Ine a licatio ef sucqinformation is favourable to the applicant or not.

Signalurelhe env ronmental assessment Dractitioner:

M RO5) ton *LL't-nName ofco|..pa'ry:

Datei g 1+6()-6

Signalule"ofthe Coniissioner ofOalhsl

01(

2)O\ 6 -A1 ->1

'sun fd^E)n+ /-!-\

. will provide the competent authority with access to all information at my disposal regarding

Date:I

cial stamp (beloa)r

2016 -07- ?1CO|\ , IMUNITY ! ' : ' ! :JE C!NTRE

g!Il-!!:i- r' 1' :i '=Y:1'.:

oa l r ,A ; r . : ! : : : : : rL r ' - : ? l

: a t r T H a L F i a t l ' , r E : " - '

G2: Declarations of the Applicant

2. TheAppiicant

a)

ForJ- Lee Pel, rs"n ,decrafe underoarh thai r,

e)

c)

d )

re of t l ie applcani l

am the appl icant in this appl icat ion;

appo;nted the environmental assessmeht p.actitioner as indicated under Gl above toact as the independent environmental assessment practitioherfor this apptication;

will provide the environmental assessment practitioner and the competent authoritywith access to all information at my disposalthat is retevantto the apptication;

am responsjble for complying with the di.ective or conditions of any environmentaauthorisation issued by the competent author!ty;

understand that I will be required to pay an administration fine in terms of S24G{2) ofthe Act and that a dec;sion in this regard will only be forthcoming after payment ofsuch a f ine;and

hereby indemnify, the government of the Republic, the competent authority and all itsofficers, agents and employees! from any liability arising out of the content of anyreport, any procedure or any action for which the appticant or environmentaassessment practitioner is responsible in terms ofthe Act.

6ou t h AAr 'con /lohana/ Pctrk sName ofcornpany:

Sigrature oi the Co

sRtia()-6-O

of Oaths:

.i ' ]

ao\ +-OB- a \Date:

cofl sT +15 L€Designat ion:

Offlclalstamp (below):

ARF} LGV. ! j: -. !i'JirUlA

!,,::;-;'-a.;--j -'' ' ,- *l'cl

SKUKUZA WASTE SITE LOCATION THOPO MAP APPENDIX A

Topographic map 2431 DC .

SKUKUZA WASTE SITE LOCATION SATELLITE IMAGE APPENDIX A

Source: Google Earth

SKUKUZA WASTE SITE LOCATION SATELLITE IMAGE APPENDIX A

22 June 2002

SKUKUZA WASTE SITE LOCATION SATELLITE IMAGE APPENDIX A

30 July 2011

SKUKUZA WASTE SITE LOCATION SATELLITE IMAGE APPENDIX A

26 July 2013

SKUKUZA WASTE SITE LOCATION VEGETATION TYPE APPENDIX A

SKUKUZA WASTE SITE LOCATION SOIL CLASS APPENDIX A

SKUKUZA WASTE SITE SITE PLANS (BEFORE) APPENDIX B

SKUKUZA WASTE SITE SITE PLANS (AFTER) APPENDIX B

SKUKUZA WASTE SITE CONSENT APPENDIX C

As the applicant and the land owner is the South African National Parks, there is no document for this. Included is the consent for the Kruger National Park Environmental Manager to sign the application on behalf of the applicant along with her ID document

Department of Environmontal Affairs

Private Bag X447

Pretoria

0001

This letter seeks to conflrm that the Kruger National Park: Strategic

Conservation Planner and Envhonmental Manager, Ms Tracy-Lee Petersen, is

duly authorised to sign the declaration form for the S 24 (g) application for the

Skukuza Waste Site to the departinent on behalf of South African Natjonal

Parks.

Yours sincerely

E n q u j n 6 s : Tt act -Le e P ete6e nStalegb Con6etuation Plannet ahdEnvircnnental tulanageL krget Nationat Park

' tracy. peteen@sanpatks og

kgalagadi transf rohtier

AUTHORISATION TO SIGN DECLARATION ON BEHALF OF SOUTH

AFRICAN NATIONAL PARKS: SEGTION 24 (c) APPLICATION, SKUKUZA

WASTE SITE, KRUGER NATIONAL PARK

Mr Danid, Pienaar

ACTING MANAGING EXECUTIVE:

Date:

KRUGER NATIONAL PARK

SKUKUZA WASTE SITE PHOTOGRAPHS APPENDIX D

An aerial photograph illustrating the layout of the Skukuza Waste Site. A= processed waste storage facility; B= staff ablutions; C= processed waste storage facility; D= materials recycling facility; E= general waste storage facility; F= ring road

View of the back end of the staff ablutions (B) from a north-westerly direction.

Frontal view of the processed waste storage facility for plastic (A).

Frontal view of the processed waste storage facility for paper and cardboard (C).

SKUKUZA WASTE SITE PHOTOGRAPHS APPENDIX D

View of the materials recycling facility (D) from a north-westerly direction.

View of the materials recycling facility (D) from a south-easterly direction.

View of the general waste storage facility (E) from a southerly direction.

Site access

LIST OF PERMITS / LICENSES:

WASTE DISPOSAL LICENSES

Letter from Lowveld and Escarpment Regional Services Council dated 11 March 1994,

giving permission for establishment of waste site. 16/9/2(5088)

Authorisation for General Waste Disposal Site (not dated, may be incomplete)

Ref: 16/2/7/X301/D37 (DWAF)

Letter regarding Inspection Report for Skukuza Landfill Site (Not dated, may be incomplete

– no report) Ref: A24/2/1 (DEAT)

Authorisation for General Waste Disposal Site (dated 31 July 2002)

Ref: 16/2/7/B900/Z20/1 (DWAF)

OPERATIONS LICENSE SKUKUZA WASTE WATER TREATMENT FACILITY

Certificate for Class E works – Skukuza WWTW Wastewater Works dated 20 August 2014

Letter confirming capacity and accept of effluent

ATMOSPHERIC EMISSIONS LICENSE – WASTE INCINERATORS

Not licensed

ESKOM POWER SUPPLY CONFIRMATION

Letter confirming supply and capacity of power supply.

CONFIRMATION OF WATER SUPPLY & LICENSES

KNP SKUKUZA WASTE SITE PERMITS / LICENSES APPENDIX E

RE: INSPECTION OF SKUKUZA Landfitt si ie

The above matter refers.

5:1[1?1.-il]l?ection,report^clnducred by my deparrment in cqllaborarjon lvjth youroeparunent on the 1 November 2002 regarding the permiting process qf Ure mention;dlandfi,l.

Please UndIhe attached report, and should you need any furliter asslstance on the matterdon't hesitate to contact me.

Yours sincerely

( -r--Ttbil*,r" ns uDeputy Director : Waste Managemsnt and

r\t Fr I r|rrr rlg '.rrr\wr

. bEpARTt ENT: ENvtRo MENTAL aFFAIRB aNo rouRtsMREPUBIIC OF 90UTH AFRICA

01 T . r t !?_ t2 , 31O te l t , r r r : (27 .12 ! !22 26s :

H;ffii-enqutrter: L M6fi tangr.r

tel! (012) 310 3536 Frx! (O1Z) 3Zq 1167 E.dr.ih Lmahtangu@otonap\.a/.govcr.za

Yaruschka NaiduDept. WsterAffairs and FqresiryMpumalanga Reglon

Fax 013 755 1687

Dear Ms Naidu

Communit prcgrammes

Contact Details: Private Bag X402

Skukuza 1350 Tel: 013 735 4134 Cell: 082 990 5378 ben.duplessis@sanparks.org

28 May 2015 Ref.16/2/7/B900/Z20/1 Attention: Ms: Mette Rossaak Emross Consulting (Pty) Ltd. Tel 013 750 2782

Cell 082 3399 627

Fax 086 675 4320

Dear Mette Re: Skukuza waste disposal site A. Skukuza waste disposal site effluent

Skukuza WWTW is register as a Class E Works certificate Nr.24015717 and with SAWIS Reg. Nr D00210-02. This WWTW is design with a capacity NDWF of 422m³/day with a retention time of 102 days.

The current inflow is 305m³/day and the Skukuza waste disposal facility water consumption is 600lt/day.

Skukuza WWTW has capacity for this additional effluent.

The person responsible for Skukuza WWTW is: Mr. B.J. Du Plessis Private Bag X402 Skukuza 1350 Tel: 013 735 4134 Cell: 082 990 5378 ben.duplessis@sanparks.org

B. Skukuza waste disposal site electricity supply.

SANParks is the distributor of ESKOM electricity in the Kruger National Park.

There is a 3.5Kw mini sub that feed the Laundry and the Skukuza waste disposal site.

Currently the Laundry use 1.8 Kw and the Skukuza waste disposal site 0.3Kw

The mini sub has capacity for this additional electricity needed. C. Waste volumes

Mondays to Fridays 2-3 tons/day

Saturdays 1-1.5 ton/day

Sundays 0.5 – 0.8 ton/day D. Water Availability

The Skukuza waste disposal facility water consumption is 600lt/day;

The Skukuza water supply has availability for this additional water needed. Regards Ben Du Plessis Manager: Water and Waste Management

SKUKUZA WASTE SITE ADDITIONAL INFORMATION APPENDIX H

CONTENTS:

Public Participation

Operational Environmental Management Programme

KNP SKUKUZA WASTE SITE PUBLIC PARTICIPATION

Following a site inspection on 4 October 2013 (attendance register and minutes included)

KNP were requested to complete a section 24G application for the expansion of the

Skukuza waste site.

A proposal for the format of public participation was sent to DEA on 18 February 2014, to

date no further correspondence has been received regarding this subject and thus it is

concluded that the format is acceptable to DEA.

A notice of s24g process to be undertaken was posted in the Lowvelder Local Newspaper

on 5 September 2014 (copy of advert included).

E-mails were sent to identified parties to notify of the process undertaken on 10 November

2014 (copy of email and responses included).

The draft s24g document was circulated to the identified interested parties on 1 September

2015. A 30 days comment period was provided for.

To date no objections or comments have been received.

Copies of all documents and communications mentioned above are included in the

following pages.

APPENDIX H

From: Tracy-Lee Ann Petersen

Sent: Thursday, November 07, 2013 2:58 PM

To: 'hmbuli@ehlanzeni.gov.za'; 'moolmanw@dwa.gov.za'; Blake Schraader; Ben du

Plessis; 'mthekedi@mpg.gov.za'; Linford Molaba; 'nsinje@environment.gov.za'; Phohlo,

Zingisa; 'Duduzile A Sibiya'

Cc: lmahlangu@environment.gov.za; Mthombothi, Nocawe

Subject: Skukuza Waste Site

A�achments: 320622201000_0001.pdf

Dear All

Following our mee6ng and site visit to the waste site in Skukuza, Kruger Na6onal Park on the 4th

October 2013

(see a;ached a;endance register), the following resolu6ons were concluded as detailed below:

1. A Sec6on 24 (G) applica6on for rec6fica6on must be made by SANParks to the Na6onal DEA for

commencing with listed ac6vi6es without environmental authoriza6on;

2. An EAP must be appointed by SANParks (KNP) to make the above-men6oned applica6on to the

department ;

3. The Scope of works to be undertaken by the EAP must include:

o terms of reference

o a BAR process for the listed ac6vi6es as detailed by MDEDET during previous site visits and a site

visit made on the day of the afore-men6oned mee6ng;

o an atmospheric emission licence applica6on in terms of the Air Quality Act 39 of 2004. An

applica6on in this regard was made to the DEA a number of years ago but never culminated in a

licence being issued.

o an Integrated Waste Management Plan based on the NEMA: Waste Act 59 of 2008 and best

prac6ce principles.

In order to set 6me frames for the above-men6oned applica6ons please issue the KNP a formal le;er to inform us

on the department’s decision in terms of the Sec6on 24 (G) applica6on and other requirements that would have

to be met.

Please do not hesitate to contact me if you require any further informa6on related to the Skukuza waste site.

Regards

Tracy

Tracy-Lee Petersen

Strategic Conserva�on Planner and Environmental Manager

KRUGER NATIONAL PARK

SOUTH AFRICAN NATIONAL PARKS

Tel : +27 13 735 4271

Fax: +27 13 735 4051

*Cell: 074 5805583

PO Box 394

Skukuza

1350

E-mail: tracy.petersen@sanparks.org

Web: www.sanparks.org

Subject: Re: Skukuza Waste Site S24G

From: "Zingisa Phohlo" <zphohlo@environment.gov.za>

Date: 2014/02/18 08:01 AM

To: mette@emross.co.za

CC: "Duduzile Sibiya" <DASibiya@mpg.gov.za>, "Lucas Mahlangu" <Lmahlangu@environment.gov.za>,

"Tracy-Lee Petersen" <TracyP@sanparks.org>

Dear Mette,

All applications are forwarded to Mr Lucas Mahlangu. His contact number is 012 310 3536. I have also copied him in this email.

Regards,

>>> Mette Rossaak <mette@emross.co.za> 2/17/2014 2:17 PM >>>

Dear Zingisa,

Kruger National Park has appointed Emross Consulting as environmental practitioners to undertake the required actions for a S24G rectification

process for the unauthorised expansions at their Skukuza waste site.

Please can you confirm if you are the correct contact person for this S24G rectification application. If this is not the case, please let me have name and

contact details of the correct person.

We would like to prepare for and commence the public participation process for this application.

This is our proposed way forward for the public participation:

Advertising of the application in local newspaper (The Lowvelder) and on the SANParks website;

Direct notification of identified stakeholders (MDEDET, EDC, BBRLM - this is essentially the officials who have been involved up to now);

Allowance for a 21 days comment period; and

Advertising and direct notification to registered stakeholders of decision once made.

We are identifying the exact transgressions (the letters/emails to KNP do not identify which listed activities have been contravened) and would like to

submit this list to DEA for approval / acceptance as each of these will need to be specifically addressed in the S24G report.

Please let me know if this is acceptable to you, and if you have any comments on the above process and stakeholder and role player identification.

Kind regards

--Mette RossaakCertified Environmental Assessment Practitioner

Emross Consulting (Pty) Ltd.Tel 013 750 2782 / 013 007 0077Cell 082 3399 627Fax 086 675 4320

This message and any attachments transmitted with it are intended solely for the addressee(s) and may be legally privileged and/or confidential. If

you have received this message in error please destroy it and notify the sender. Any unauthorized usage, disclosure, alteration or dissemination is

prohibited. The Department of Environmental Affairs accepts no responsibility for any loss whether it be direct, indirect or consequential, arising from

information made available and actions resulting there from. The views and opinions expressed in this e-mail message may not necessarily be those

of Management.

{*

*Ltl

":iiI e

r c ; o J c r T J '

:6 r : g ; .r- j tr 4., ; :- *-A:d 'E

=

wqf F

TL

l i:iigg iEiiiiiiii ggeiill iiiii iiiii' ;il;llilli ; s u iiiii

seE$

s:€EE3E

;

Esb

=. =._ .F- 'E l !; i ;=;.=;-11.ie19: . i - : r= = : i : ! : : a , I- i :== ' I -= : ; : l j i + i I= : .= : : : :a : : i ' - : E I! : : = : . ; = : E 3 d 6 L

:il

,)::;:

::i

tJ isggl igsEi ig iitigsigi

= : = =- i 2==t.j -.. 5z-a.==_._.=., :;gg: =-..:-- e ;€ E:?==.1=i=. : !!E;: : =z - : 4 : - i , l : iE -

: ! q s : '

I l^: gs+*ie

l-*lg,; :, €i ;cajLJ =:-. EE iE€E

i , - i i s;se,,+::g.3cM€E*E:FE";jq: !! EeEE: E ; + . . i F = . o . ' a . ' E = ! 79J!g:s i5;r : ; E9ie

: !g : : ;d : E= ;E i !

a i n n i : : 5 ' - .

Subject: KNP Skukuza Waste - NOTICE OF SECTION 24G RECTIFICATION PROCESS

From: Me�e Rossaak <me�e@emross.co.za>

Date: 2014/11/10 12:06 PM

To: Doctor Shabangu <shabangud@bushbuckridge.gov.za>, Golden Mthembi <mthembig@inkoma3cma.co.za>,

Thomas Gyedu-Ababio <thomasga@inkoma3cma.co.za>, Herbert Mbuli <hmbuli@ehlanzeni.gov.za>,

moolmanw@dwa.gov.za, Fikile Theledi <mtheledi@mpg.gov.za>, nsinje@environment.gov.za, Zingisa Phohlo

<zphohlo@environment.gov.za>, Duduzile Sibiya <DASibiya@mpg.gov.za>, Gezephi Nyalunga

<ghnyalunga@mpg.gov.za>

NOTICE OF SECTION 24G RECTIFICATION PROCESS

Notice is hereby given that an application has been lodged with The National Department of Environment in terms of section24G of the National Environmental Management Act, 1998 (Act 107 of 1998) for rectification of unlawful commencement ofthe following activity:

THE EXPANSION AND UPGRADE OF WASTE TREATMENT FACILITY AT SKUKUZA REST CAMP,KRUGER NATIONAL PARK.

Description of unlawful activity: The existing authorised waste site, at Skukuza, has been expanded by 3500m2

, from 2500m2

to 6000m2

. The boundary fence has been relocated to enclose the new area. The following upgrades have been done: Twoconveyer belts have been installed at the waste recovery facility, two storage shelters have been constructed along withwaste storage cages, for storage of recyclable materials and hazardous waste drums. An ablution block with 6 showers, 4toilets and a kitchen area has been constructed, along with a one track through road to facilitate truck movement. This is aduel s24g rectification process as both waste and environmental management activities requiring authorisation have beenundertaken.

Should you have any comments or concerns related to this process, please reply to this email before 10 December 2014.

Regards--

Mette RossaakCertified Environmental Assessment Practitioner

Emross Consulting (Pty) Ltd.Tel 013 750 2782Cell 082 3399 627Fax 086 675 4320

S24GRECTIFICATION

FOR THEEXPANSION

AND UPGRADEOF SKUKUZAWASTE SITE

August 2014.

REF:

BACK GROUND INFORMATION DOCUMENT

CONSULTANT:EMROSS Consulting P.O. Box 507White River1240Phone: 013 750 2782Cell: 082 3399 627Fax: 086 675 4320Email: andrew@emross.co.za

APPLICANT:South African National ParksContact: Tracy-Lee PetersenPostal address: PO Box 394Skukuza1350Phone: 013 735 4271Fax: 013 735 4051Email: tracy.petersen@sanparks.org

PROPERTY:Governments Grond 142KU

EMROSS Consulting Tel: 013 750 2782 Cell: 082 3399 627 Page 1 of 5 e-mail: andrew@emross.co.za

INTRODUCTION

South African National Parks (the applicant) has contracted EMROSS Consulting (Pty) Ltd., as

independent environmental consultants, to determine whether the expansion and upgrading of

the Skukuza Waste Site commenced unlawfully, and if so, provide recommendations for the

rectification of unlawful activities in terms of S24G of the National Environmental Management

Act, 1998 (Act No. 107 of 1998).

Government Notices no. R 544-546 stipulates activities which require authorisation, in terms of

the National Environmental Management Act (Act 107 of 1998). Government notice 543

prescribes the manner in which the assessment must be undertaken.

Government Notice 921 provides a list of waste management activities that are likely to have a

detrimental effect on the environment..

UPGRADING AND EXPANSION OF WASTE SITE

As part of the need to operate in a more sustainable and environmentally friendly manner, South

African National Parks proceeded with the expansion and upgrading of the Skukuza Waste Site

(Figure 1) in order to improve waste management efficiency.

The upgrades were aimed at increasing the storage capacity and reducing the reliance on

landfill and waste product incineration at the Waste Site. This was achieved by constructing

additional storage facilities and upgrading the existing waste building into a materials recycling

facility, where waste could be sorted accordingly and transported to recycling stations outside

the Kruger National Park (Figure 2). Further developments include the construction of an

ablution block for staff members as well as a ring road to allow for easy access and departure

for waste disposal trucks to and from the Waste Site.

These upgrades were undertaken in the absence of seeking the appropriate authorisation from

the Mpumalanga Provincial Government Department of Economic Development, Environment

and Tourism; and commenced under outdated waste license regulations. As a result, the

applicant has requested that EMROSS Consulting (Pty) Ltd. perform the necessary

assessments to determine whether the expansion and upgrading of the Skukuza Waste Site

triggered any of the relevant legislation, and if so, provide recommendations for the process of

seeking rectification in terms of S24G for any unlawful activities committed.

EMROSS Consulting Tel: 013 750 2782 Cell: 082 3399 627 Page 2 of 5 e-mail: andrew@emross.co.za

Figure 1: Satellite image indicating the location of the Skukuza Waste Site (GoogleEarth).

Figure 2: Aerial photograph illustrating the various facilities at the Skukuza Waste Site. A= processed waste storage facility; B= staff ablutions; C= processed waste storage facility; D=

materials recycling facility; E= general waste storage facility; F= ring road.

EMROSS Consulting Tel: 013 750 2782 Cell: 082 3399 627 Page 3 of 5 e-mail: andrew@emross.co.za

LEGISLATIVE CONTEXT

In terms of the National Environmental Management Act (NEMA), the expansion of the

Skukuza Waste Site is regarded as an activity having a potential significant environmental

impact, and as such this is listed under schedule of activities requiring environmental authorisation,

prior to commencement.

The applicable listings are as follows:

National Environmental Management Act: Government Notice R 544:

Activity 24: “The transformation of land bigger than 1000m² in size, to residential, retail,

commercial, industrial or institutional use, where, at the time of the coming into effect of this

Schedule such land was zoned open space, conservation or had an equivalent zoning.”

National Environmental Management: Waste Act: Government Notice R 921:

Category A (3):

Recycling or recovery of waste:

“(2): The sorting, shredding, grinding, crushing, screening or bailing of general waste at a facility

that has an operational area in excess of 1000m².”

“(3): The recycling of general waste at a facility that has an operational area in excess of

500m²,...”

and

Construction, expansion or decommissioning of facilities and associated structures and

infrastructure:

“(13): The expansion of a waste management activity listed in Category A or B of this Schedule

which does not trigger an additional waste management activity in terms of this Schedule.”

The storage of general wastes is a Category C activity, which means that the site and operations

are required to meet certain norms and standards.

This means that the upgrading and expansion of the Skukuza Waste Site required a Basic

Environmental Assessment to be conducted in order to obtain environmental authorisation for

the developments. As a result, a rectification process needs to be followed in accordance with

S24G. Furthermore, it is advisable to develop an operational management plan which aims to

address any issues and mitigate any negative impacts which may have affected the surrounding

environment.

EMROSS Consulting Tel: 013 750 2782 Cell: 082 3399 627 Page 4 of 5 e-mail: andrew@emross.co.za

The proposed developments may also be subject to regulations contained in other legislation, such as the:

National Heritage Resources Act (No 25 of 1999, Section 38);

Conservation of Agricultural Resources Act (No 43 of 1983);

National Water Act (No 36 of 1998);

National Environmental Management Act (No 107 of 1998);

Constitution of the Republic of South Africa (Act 108 of 1996);

Promotion of Access to Information Act (No 2 of 2000); and

Mpumalanga Nature Conservation Act (No 10 of 1989).

THE S24G ASSESSMENT PROCESS

The legislation calls for a basic assessment to establish potential environmental and social

impacts of the proposed development. The assessment will look at avoiding or minimising

potential environmental damage and promote sustainable development.

The assessment process commences with a planning stage. During this stage;

An application is lodged with the decision making authority, in this case the National

Department of Environment as SAN Parks is a Government Agency.

Site visits by specialists may be required if deemed necessary to assess the site and

potential impacts that could be caused by the proposed development, and

Potential interested and affected parties to the development are identified.

The planning stage is followed by a participation stage. During this stage;

A site visit is conducted with the decision making authority, and

Notices and advertisements are publicised and identified interested and affected parties

are consulted.

Once property information and public comment has been obtained, various assessments and

specialist inputs are incorporated into a report, assessing the proposed development in context

of the site. This report is made available for comment and finally submitted with comments to the

lead authority for decision making.

PUBLIC PARTICIPATION PROCESS

According to the Constitution of the Republic of South Africa everybody has the right to have the

environment protected, amongst others through sustainable development. Everybody also have

the right to be informed and to access information.

Therefore a very important part of the Environmental Impact Assessment is to identify and

receive comment from interested and affected parties relating to the proposed development.

This is done by contacting neighbouring landowners, by advertising the process in the

Lowvelder, by erecting notices on site, and also by contacting special affected parties such as

the Kruger National Park and the Mpumalanga Tourism and Parks Agency.

EMROSS Consulting Tel: 013 750 2782 Cell: 082 3399 627 Page 5 of 5 e-mail: andrew@emross.co.za

Registered interested and affected parties have the right to comment on reports regarding the

development to be submitted by the consultant to the department.

In return the registered interested and affected party is expected to:

Submit all comments in writing to the consultant;

Adhere to time frames given for commenting or submit a written motivation for why a

longer commenting period is needed; and

Disclose any direct business, financial, personal or other interest in the development

and/or approval or refusal of the development.

The whole assessment process is expected to last approximately 6 months, there will be three

opportunities to provide comments on the assessment, comments are however welcome at any

time in the duration of the assessment.

WHO TO CONTACT

Should you wish to register as an interested and affected party to this process and should you

have any special concerns that you wish to be addressed during the assessment process,

please send your name and contact details and issues to be addressed to:

Emross Consulting Pty Ltd.

Andrew Rossaak

PO Box 507

White River

1240

Cell: 082 339 9627

Fax: 086 675 4320

E-mail: andrew@emross.co.za

There is also a simple registration form on our website which you may wish to use.

Website: www.emross.co.za

Notice will be published in the Lowvelder Local Newspaper.

Interested and affected parties have 30 days to register. We will, however, be accepting

comments throughout the process. In order for issues to be fully assessed, it would be

preferable to receive these at the start of this process.

Subject: Checked: KNP Skukuza Waste - NOTICE OF SECTION 24G RECTIFICATION PROCESS

From: thomasga@inkoma$cma.co.za

Date: 2014/11/10 12:42 PM

To: Me*e Rossaak <me*e@emross.co.za>

Recipient: thomasga@inkoma$cma.co.za

Subject: KNP Skukuza Waste - NOTICE OF SECTION 24G RECTIFICATION PROCESS

NOTICE OF SECTION 24G RECTIFICATION PROCESS No$ce is hereby given that an applica$on has been lodged with The Na$onal

Department of Environment in terms of sec$on 24G of the Na$onal Environmental

Subject: Read: KNP Skukuza Waste - NOTICE OF SECTION 24G RECTIFICATION PROCESS

From: Moolman Wilna <MoolmanW@dwa.gov.za>

Date: 2014/11/10 04:54 PM

To: Me-e Rossaak <me-e@emross.co.za>

DISCLAIMER: This message and any attachments are confidential and intended solely for the addressee. If you have

received this message in error, please notify the system manager/sender. Any unauthorized use, alteration or

dissemination is prohibited. The Department of Water Affairs further accepts no liability whatsoever for any

loss, whether it be direct, indirect or consequential, arising from this e-mail, nor for any consequence of its

use or storage.

Read KNP Skukuza Waste - NOTICE OF SECTION 24G RECTIFICATION PROCESS

Subject: Read: KNP Skukuza Waste - NOTICE OF SECTION 24G RECTIFICATION PROCESS

From: Moolman Wilna <MoolmanW@dwa.gov.za>

Date: 2014/11/10 04:54 PM

To: Me-e Rossaak <me-e@emross.co.za>

Attachments:

Read KNP Skukuza Waste - NOTICE OF SECTION 24G RECTIFICATION PROCESS 7.5 KB

winmail.dat 4.2 KB

Subject: Re: KNP Skukuza Waste - NOTICE OF SECTION 24G RECTIFICATION PROCESS

From: Golden Mthembi <mthembig@inkoma'cma.co.za>

Date: 2014/11/11 10:20 AM

To: me.e@emross.co.za, Doctor Shabangu <shabangud@bushbuckridge.gov.za>, Thomas Gyedu-Ababio

<thomasga@inkoma'cma.co.za>, Herbert Mbuli <hmbuli@ehlanzeni.gov.za>, moolmanw@dwa.gov.za, Fikile Theledi

<mtheledi@mpg.gov.za>, nsinje@environment.gov.za, Zingisa Phohlo <zphohlo@environment.gov.za>, Duduzile

Sibiya <DASibiya@mpg.gov.za>, Gezephi Nyalunga <ghnyalunga@mpg.gov.za>

Good morning.

The office of the IUCMA wish to have an input to the opera'on. Please finish me with the full details to ensure that

we give our technical input in accordance with the Na'onal Watet Act.

Regards

Golden

Sent from my Samsung Galaxy smartphone.

Subject: Re: KNP Skukuza Waste - NOTICE OF SECTION 24G RECTIFICATION PROCESS

From: Me�e Rossaak <me�e@emross.co.za>

Date: 2015/01/14 11:00 AM

To: Golden Mthembi <mthembig@inkoma0cma.co.za>

Hi Golden,

Best wishes for the New Year to you.

The sewage from the ablution block goes through to the Skukuza sewage plant. This plant does have sufficientcapacity to deal with the sewage generated at site. This facility is authorised by DWS and the information available onthe green drop website.

There is currently no storm water management installed and storm water of the site goes into the veld.

We are having some delays from KNP side but I will send ou the s24 document once ready.

If you have any questions please feel free to contact myself or Andrew.

Kind regards

Mette RossaakCertified Environmental Assessment Practitioner

Emross Consulting (Pty) Ltd.Tel 013 750 2782Cell 082 3399 627Fax 086 675 4320On 2015/01/14 08:50 AM, Golden Mthembi wrote:

Good Morning Me�e,

I hope I am not too late for response to your email bellow.

From our side we need to know and understand the type of sewage disposals system used. And is it authorised in terms of the Na0onal Water

Act, 1998 (Act 36 of 1998). If not I am available to have a site pre-consulta0on mee0ng to get such infrastructure authorised in terms of

Na0onal Water Act.

Regards

Golden

Subject: RE: KNP Skukuza Waste - NOTICE OF SECTION 24G RECTIFICATION PROCESS

From: "Golden Mthembi" <mthembig@inkoma(cma.co.za>

Date: 2015/01/15 10:40 AM

To: <me0e@emross.co.za>

Morning Me0e

I will be wai(ng. And we will be able to comment on the Stormwater Management Plan.

Regards

Golden

Subject: S24G Applica�on Expansion Skukuza Waste Site

From: Me�e Rossaak <me�e@emross.co.za>

Date: 2015/09/01 01:47 PM

To: Golden Mthembi <mthembig@inkoma�cma.co.za>, Thomas Gyedu-Ababio <thomasga@inkoma�cma.co.za>, Herbert

Mbuli <hmbuli@ehlanzeni.gov.za>, moolmanw@dwa.gov.za, Fikile Theledi <mtheledi@mpg.gov.za>,

nsinje@environment.gov.za, Zingisa Phohlo <zphohlo@environment.gov.za>, Duduzile Sibiya <DASibiya@mpg.gov.za>,

Tracy-Lee Petersen <TracyP@sanparks.org>, Ben du Plessis <ben.duplessis@sanparks.org>, Gezephi Nyalunga

<ghnyalunga@mpg.gov.za>, wrikhotso@environment.gov.za, Lucas Mahlangu <lmahlangu@environment.gov.za>

Dear Interested Party,

The draft report for rectification of illegal activities in connection with the expansion and upgrade of the SkukuzaWaste Management Facility is available for your review and comment until 30 September 2015.

The document can be downloaded from our website; www.emross.co.za/downloads

Should you be unable to download the document, please contact us for alternative arrangement.

Please feel free to share this notification to other parties, who you may think will be interested.

You may submit comments to us via reply to this email address, via fax no 086 675 4320 or via registered mail to POBox 507, White River, 1240.

If you have any questions, please feel free to contact myself or Andrew.

Kind regards

--

Mette RossaakCertified Environmental Assessment Practitioner

Emross Consulting (Pty) Ltd.Tel 013 750 2782Cell 082 3399 627Fax 086 675 4320

Subject: S24G Applica�on Expansion Skukuza Waste Site

From: Me�e Rossaak <me�e@emross.co.za>

Date: 2015/09/01 02:01 PM

To: tshabangu@ehlanzeni.gov.za

Dear Mr Shabangu,

Please see the message below. I have not been able to get through to Mr. H. Mbuli who a�ended the inspec�on of the waste

management facility.

Sincerely

Me�e Rossaak

EMROSS Consul�ng

-------- Forwarded Message --------

Subject:S24G Applica�on Expansion Skukuza Waste Site

Date:Tue, 1 Sep 2015 13:47:04 +0200

From:Me�e Rossaak <me�e@emross.co.za>

Reply-To:me�e@emross.co.za

To:Golden Mthembi <mthembig@inkoma�cma.co.za>, Thomas Gyedu-Ababio <thomasga@inkoma�cma.co.za>,

Herbert Mbuli <hmbuli@ehlanzeni.gov.za>, moolmanw@dwa.gov.za, Fikile Theledi <mtheledi@mpg.gov.za>,

nsinje@environment.gov.za, Zingisa Phohlo <zphohlo@environment.gov.za>, Duduzile Sibiya

<DASibiya@mpg.gov.za>, Tracy-Lee Petersen <TracyP@sanparks.org>, Ben du Plessis

<ben.duplessis@sanparks.org>, Gezephi Nyalunga <ghnyalunga@mpg.gov.za>, wrikhotso@environment.gov.za,

Lucas Mahlangu <lmahlangu@environment.gov.za>

Dear Interested Party,

The draft report for rectification of illegal activities in connection with the expansion and upgrade of the SkukuzaWaste Management Facility is available for your review and comment until 30 September 2015.

The document can be downloaded from our website; www.emross.co.za/downloads

Should you be unable to download the document, please contact us for alternative arrangement.

Please feel free to share this notification to other parties, who you may think will be interested.

You may submit comments to us via reply to this email address, via fax no 086 675 4320 or via registered mail to POBox 507, White River, 1240.

If you have any questions, please feel free to contact myself or Andrew.

Kind regards

--

Mette RossaakCertified Environmental Assessment Practitioner

Emross Consulting (Pty) Ltd.Tel 013 750 2782Cell 082 3399 627Fax 086 675 4320

Subject: Read: S24G Applica�on Expansion Skukuza Waste Site

From: "Goldem Mthembi" <mthembig@iucma.co.za>

Date: 2015/09/03 10:15 PM

To: "'Me-e Rossaak'" <me-e@emross.co.za>

Reporting-UA: iucma.co.za; Microsoft Outlook 14.0

Final-Recipient: rfc822;mthembig@iucma.co.za

Original-Message-ID: <55E59038.1090203@emross.co.za>

Disposition: manual-action/MDN-sent-manually; displayed

Subject: Read: S24G Applica�on Expansion Skukuza Waste Site

From: "Thomas Gyedu Ababio" <thomasga@iucma.co.za>

Date: 2015/09/07 12:30 PM

To: "'Me0e Rossaak'" <me0e@emross.co.za>

Reporting-UA: iucma.co.za; Microsoft Outlook 15.0

Final-Recipient: rfc822;thomasga@iucma.co.za

Original-Message-ID: <55E59038.1090203@emross.co.za>

Disposition: manual-action/MDN-sent-automatically; displayed

Subject: Read: S24G Applica�on Expansion Skukuza Waste Site

From: Zingisa Phohlo <ZPhohlo@environment.gov.za>

Date: 2015/09/03 05:41 AM

To: Me-e Rossaak <me-e@emross.co.za>

Your message

To: Zingisa Phohlo

Subject: S24G Applica�on Expansion Skukuza Waste Site

Sent: Tuesday, September 1, 2015 1:47:04 PM (UTC+02:00) Harare, Pretoria

was read on Thursday, September 3, 2015 5:40:04 AM (UTC+02:00) Harare, Pretoria.

This message and any a-achments transmi-ed with it are intended solely for the addressee(s) and may be legally privileged

and/or confiden�al. If you have received this message in error please destroy it and no�fy the sender. Any unauthorized

usage, disclosure, altera�on or dissemina�on is prohibited. The Department of Environmental Affairs accepts no

responsibility for any loss whether it be direct, indirect or consequen�al, arising from informa�on made available and ac�ons

resul�ng there from. The views and opinions expressed in this e-mail message may not necessarily be those of Management.

Final-recipient: RFC822; ZPhohlo@environment.gov.za

Disposition: automatic-action/MDN-sent-automatically; displayed

X-MSExch-Correlation-Key: b0LtWi+Mikm7076xr40Krg==

X-Display-Name: Zingisa Phohlo

Subject: Read: S24G Applica�on Expansion Skukuza Waste Site

From: Lucas Mahlangu <LMahlangu@environment.gov.za>

Date: 2015/09/04 08:21 AM

To: Me,e Rossaak <me,e@emross.co.za>

Your message

To: Lucas Mahlangu

Subject: S24G Applica�on Expansion Skukuza Waste Site

Sent: Tuesday, September 1, 2015 1:47:04 PM (UTC+02:00) Harare, Pretoria

was read on Wednesday, September 2, 2015 2:57:34 PM (UTC+02:00) Harare, Pretoria.

This message and any a,achments transmi,ed with it are intended solely for the addressee(s) and may be legally privileged

and/or confiden�al. If you have received this message in error please destroy it and no�fy the sender. Any unauthorized

usage, disclosure, altera�on or dissemina�on is prohibited. The Department of Environmental Affairs accepts no

responsibility for any loss whether it be direct, indirect or consequen�al, arising from informa�on made available and ac�ons

resul�ng there from. The views and opinions expressed in this e-mail message may not necessarily be those of Management.

Final-recipient: RFC822; LMahlangu@environment.gov.za

Disposition: automatic-action/MDN-sent-automatically; displayed

X-MSExch-Correlation-Key: gflrbqPe10235BftfLorSA==

X-Display-Name: Lucas Mahlangu

SKUKUZA WASTE SITE OPERATIONAL EMPr

Page 1 of 7

October 2015

ENVIRONMENTAL MANAGEMENT

PROGRAMME FOR THE SKUKUZA

WASTE MANAGEMENT FACILITY

EMROSS Consulting Pty Ltd

P.O. Box 507, White River 1240

Tel 013 750 2782

Fax 086 675 4320

E-mail: andrew@emross.co.za

Page 2 of 7

Table of Contents

1 SCOPE .................................................................................................................................................. 3

2 AGREEMENT ........................................................................................................................................ 3

3 RESPONSIBLE PERSON ..................................................................................................................... 3

4 LEGAL REGISTER - INCIDENT AND COMPLAINTS REPORTING ................................................... 3

5 AUDIT PROCESS ................................................................................................................................. 4

6 SITE IMPACTS AND MITIGATION ....................................................................................................... 4

6.1 ACCESS CONTROL AND VEHICLES ............................................................................................................... 4

6.2 SITE SETUP .................................................................................................................................................. 4

6.3 SCAVENGER INTERACTION ....................................................................................................................... 5

6.4 NUISANCE .................................................................................................................................................... 5

6.5 SERVICES ..................................................................................................................................................... 5

6.6 STORMWATER MANAGEMENT ................................................................................................................... 6

6.7 TRAINING ..................................................................................................................................................... 6

6.8 EMERGENCY PREPAREDNESS PLANS ..................................................................................................... 6

7 MONITORING PROGRAMMES ........................................................................................................... 7

7.1 DAILY MONITORING .................................................................................................................................... 7

7.2 WEEKLY MONITORING ............................................................................................................................... 7

ABREVIATIONS:

WMF = Waste Management Facility

INDEX

Page 3 of 7

1 SCOPE

The Environmental Management Programme provides guidance and proposes viable and suitable mitigation

measures for possible impacts associated with the waste management facility.

The National Environmental Management Act requires a number of guiding principles to be taken into

account in waste handling facilities, such as; life cycle approach, producer responsibility, the precautionary

principle and the polluter pays principle.

The National Environmental Management Waste Act National Norms and Standards for the Storage of

Waste GNR926 of 29 November 2013 has reference.

2 AGREEMENT

It is important to note that the Environmental Management Programme is to be read as a contract between

the implementing agent (contractor or personnel) and the WMF owner. It is therefore crucial that the

implementing agent understands the contents and adhere to its requirements, failure to do so can lead to

penalties levied against the implementing agent or license/authorisation holder.

The project manager must institute measurements to ensure that the implementing agent adhere to the

environmental obligations agreed upon.

3 RESPONSIBLE PERSON

The day to day responsibility for environmental matters lies with the site manager. An independent external

Environmental Auditor shall audit the WMF bi-annually.

The site manager shall be responsible for daily, weekly and monthly monitoring and record keeping along

with bi-annual auditing.

The WMF owner – SA National Parks – holds the duty of care as the 'person' who must ensure that they

prevent pollution/degradation from occurring or to minimise and rectify the pollution or degradation where it

cannot reasonably be avoided.

4 LEGAL REGISTER - INCIDENT AND COMPLAINTS REPORTING

A legal register must be kept accessible at Skukuza at all times, its location must be known to the workers

on site. This register must be made available for audits. The site manager will be responsible to ensure that

the register is kept up to date. All environmental incidents must be reported to the Competent Authority (DEA)

and the Environmental Auditer, and the responsible person will sign the logging of the incident, to ensure that

the information contained in the register is correct. The register must contain the date, time and place of any

incident that took place. Remedial measure taken and outcomes must also be mentioned in the diary.

A copy of all relevant permits and authorisations and all reports submitted to the Competent Authority, must

be kept in the legal register, and made available on request, at all times.

Any complaints received from the public, must be communicated to the site manager, immediately and the

complaint must be attended to, as soon as possible, and addressed to the satisfaction of all concerned parties. A

complaints report must be logged in the legal register.

Page 4 of 7

Records must be made to the legal register of types and volumes of waste processed on site along with storage

times.

A record must be kept of all hazardous waste entering and leaving the site. Safe Disposal Certificates must be

obtained and logged in the legal register.

Monitoring reporting as specified in section 7 must be logged in the legal register.

5 AUDIT PROCESS

Upon authorisation by DEA, an audit check-list will be established. Internal audits will be conducted bi-

annually with the site manager (or his/her representative) present. Audits with an external independent

auditor must also be conducted bi-annually. The completed audit must be signed by both the auditor and

project officer (or representative).

Audit times should be arranged by agreement with not less than 24hours notice.

A copy of the external audit report must be submitted to the Competent Authority and all audit reports must

be logged in the legal register.

6 SITE IMPACTS AND MITIGATION

6.1 ACCESS CONTROL AND VEHICLES

The WMF must have effective access control to prevent unauthorised entry. Appropriate signage in at least

three official languages must be displayed at the entrance to the facility. The sign must indicate the risks

involved in entering the site, hours of operation, the name and contact details of the person responsible for

the operation of the facility.

All vehicles used or kept on site must be free of oil or other lubricant and fuel leaks.

Vehicles parked on site must be on an impermeable surface or have suitable drip trays, to facilitate

containment and clean-up of any accidental spills.

6.2 SITE SETUP

The WMF must be operated as a Waste Transfer Station, there must be no disposal of waste, to ground,

on site.

All buildings and infrastructure must be in accordance with approved civil engineering designs, carried out

by a registered professional engineer. All buildings must also be in accordance with KNP technical

specifications.

The WMF must be constructed to maintain, on a continuous basis, a drainage and containment system,

capable of collecting and storing all run-off water arising from the WMF. The system must maintain a

freeboard of half a meter even during extreme weather events or flooding.

The hazardous waste storage facility must have an impermeable and chemical resistant floor and ensure

that the waste is sheltered from weather and UV degradation. The facility must also be lockable and have

a proper roof.

Page 5 of 7

A hazardous waste container resting on the ground must be underlain by barriers, which will not deteriorate

with permeability rate of the waste stored.

The design of the WMF must ensure containment of all waste. There must be no waste escaping site by

wind, storm water or scavenger interaction.

The WMF site must be neat and tidy at all times. There should be no waste materials lying around the site.

Waste materials must be appropriately stored and contained at all times.

The waste site must be locked or secured when no personnel are on site. There must be no delivery of

waste to the WMF outside of opening hours, when the site has no personnel to receive the waste.

6.3 SCAVENGER INTERACTION

The site must be fenced (electric and other), as appropriate, to ensure that scavengers cannot enter the

site. This applies to all scavengers coming from ground, air or any other way.

Any food wastes must be handled on the same day it arrives, to minimise scavenger attraction and

conflict.

No food waste is to be dumped to land at the WMF. Food should be composted or treated using bokashi,

worm farm or other natural food disposal method, contained in appropriate enclosed containers/ facilities.

6.4 BURNERS

The burners are regulated through GNR893 of 22 November 2013, in terms of the National Environmental

Management: Air Quality Act. The burning of waste is listed under category 8, subcategory 8.1.

Monitoring equipment must be installed on the burners in terms of these regulations.

6.5 HYGIENE WASTE

If a contract is in place with a hygiene waste services, all such waste must be ensured to enter the right

collection facilities, including hygiene waste generated at staff quarters and be managed and treated by the

hygiene waste contractor.

In the absence of a hygiene waste contractor, any hygiene waste, including disposable nappies, should be

incinerated as appropriate.

6.6 NUISANCE

Odour; the site must not emanate odours or emissions at levels which may cause nuisance.

Noise; machinery used on site should not have sound levels in excess of 45dB.

Light; there should be no flood light or similar installed on site that is on at night.

6.7 SERVICES

All services and equipment must be kept in good working order and without leaks (particularly

hydrocarbons).

Page 6 of 7

6.8 STORMWATER MANAGEMENT

No obstructions of any storm water system will be allowed.

If waste handling equipment is to be washed on site, any wash water must be collected in the water

containment system.

No surface storm water from the WMF, may be channelled directly into any watercourse. All surface runoff

must be managed prior to entering any natural drainage system so as to not pollute or negatively impact on

the natural hydrology and morphology of the watercourse.

6.9 TRAINING

All personnel on site must be trained in proper waste handling and the emergency preparedness plans in

section 6.10

The sorting of waste at source must be encouraged from all waste sources sending waste to the WMF.

Personnel working in housekeeping, shops or restaurants must be trained in appropriate waste handling

and sorting.

6.10 EMERGENCY PREPAREDNESS PLANS

Disasters are a constant threat when working on waste management facilities.

Fire – particularly relating to prevention, management and dangers of burning waste (emissions). No open

fires will be allowed on the WMF under any circumstances. It will be expected by all personnel to be trained

in basic response to accidental fires. The site must have serviced and fully functional firefighting equipment

on site in the event of accidental fires.

Medical disaster

The site is not in close proximity to medical care for injuries on duty or evacuation in the case of serious

illness. The contractor should develop and maintain a medical disaster management procedure that will be

communicated to all staff. These procedures will, as a minimum, have evacuation protocols, medical

attention detail and a list of necessary contact numbers included. This procedure is to be displayed in the

site office. Contractors will be required to have a first aid kit available on site at all times.

Accidental spills of hazardous waste or fuels/lubricants

Spill remediation kits must be available on site and staff must be trained to handle potential spills.

Dangerous scavenger interactions

Scavengers entering the site may pose a danger to the workers on site. Personnel must be trained as to

how to react should scavengers enter the site. Scavenger response emergency numbers must be known

to all personnel on site.

Personnel should also be aware of dangers of habituating scavengers to finding food at the WMF.

Page 7 of 7

7 MONITORING PROGRAMMES

The Site Manager is responsible for delegating monitoring tasks and ensuring that monitoring records are

kept up to date at all times.

7.1 DAILY MONITORING

The emission monitoring must be done as per NEM:AQA regulations.

Continuous, on-line measurement of the following emissions and operating parameters is required:

Particulate matter, O2, CO, NOx, SO2, HCl, HF, VOC/TOC, Emission exhaust volume (e.g. Nm3/hr) and flow

rate (e.g. m/s), Water vapour content of exhaust gas (humidity), exhaust gas temperature, internal process

temperature, pressure, and availability of air pollution control equipment (including exit gas cooling).

The perimeter fencing must be checked for breaches

Any waste which may unintentionally have escaped the site must be recovered

The storm water drains must be checked for blockages during the rainy season

It must be checked that the site is neat and secure and that no waste is accessible, to scavengers or

otherwise, prior to personnel leaving the premises at end of working day.

7.2 WEEKLY MONITORING

The integrity of hazardous waste storage containers

Storm water containment capacity and integrity

Human – wildlife conflict – particularly scavenger issues on site, scavenger break-ins etc.

7.3 QUARTERLY

A Quarterly Emissions Monitoring Report must be compiled as per NEM:AQA regulations.

7.4 ANNUAL MONITORING

Emissions monitoring equipment must be subjected to an annual surveillance test

Measurements of heavy metals, dioxin and furan must be done annually (but twice in first year)