PO Box 30134, Tokai, 7966 Telephone: , Fax:

Transcription

1 Draft Basic Assessment Environmental Impact Assessment Report: Proposed Upgrade to the Existing Mineral Processing Facility at Minrite (Pty) Ltd, Stasie Road, Lutzville, Western Cape Province. 17 th August 2018 PO Box 30134, Tokai, 7966 Telephone: , Fax:

2 BASIC ASSESSMENT REPORT BASIC ASSESSMENT REPORT IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT NO. 107 OF 1998) AND ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS, 2014 (AS AMENDED) October 2017 PROJECT TITLE Proposed Upgrade to the Existing Mineral Processing Facility at Minrite, Stasie Road, Lutzville, Western Cape Province. [17 th August 2018] REPORT TYPE CATEGORY REPORT REFERENCE NUMBER DATE OF REPORT Pre-Application Basic Assessment Report (if applicable) 1 Not Applicable Not Applicable Draft Basic Assessment Report 2 SEC Reference No: th August 2018 Final Basic Assessment Report 3 or, if applicable Revised Basic Assessment Report 4 (strikethrough what is not applicable) Notes: Pending has not yet been produced Pending 1. In terms of Regulation 40(3) potential or registered interested and affected parties, including the Competent Authority, may be provided with an opportunity to comment on the Basic Assessment Report prior to submission of the application but must again be provided an opportunity to comment on such reports once an application has been submitted to the Competent Authority. The Basic Assessment Report released for comment prior to submission of the application is referred to as the Pre-Application Basic Assessment Report. The Basic Assessment Report made available for comment after submission of the application is referred to as the Draft Basic Assessment Report. The Basic Assessment Report together with all the comments received on the report which is submitted to the Competent Authority for decision-making is referred to as the Final Basic Assessment Report. 2. In terms of Regulation 19(1)(b) if significant changes have been made or significant new information has been added to the Draft Basic Assessment Report, which changes or information was not contained in the Draft Basic Assessment Report consulted on during the initial public participation process, then a Final Basic Assessment Report will not be submitted, but rather a Revised Basic Assessment Report, which must be subjected to another public participation process of at least 30 days, must be submitted to the Competent Authority together with all the comments received. BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 1 of 114

3 DEPARTMENTAL REFERENCE NUMBER(S) Pre-application reference number: File reference number (EIA): NEAS reference number (EIA): File reference number (Waste): NEAS reference number (Waste): File reference number (Air Quality): NEAS reference number (Air Quality): File reference number (Other): NEAS reference number (Other): BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 2 of 114

4 CONTENT AND GENERAL REQUIREMENTS Note that: 1. The content of the Department s Circular EADP 0028/2014 (dated 9 December 2014) on the One Environmental Management System and the Environmental Impact Assessment ( EIA ) Regulations, 2014 (as amended), any subsequent Circulars, and guidelines must be taken into account when completing this Basic Assessment Report Form. 2. This Basic Assessment Report is the standard report format which, in terms of Regulation 16(3) of the EIA Regulations, 2014 (as amended) must be used in all instances when preparing a Basic Assessment Report for Basic Assessment applications for an environmental authorisation in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998) ( NEMA )and the EIA Regulations, 2014 (as amended) and/or a waste management licence in terms of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) ( NEM:WA ), and/or an atmospheric emission licence in terms of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) ( NEM:AQA ) when the Western Cape Government: Environmental Affairs and Development Planning ( DEA&DP ) is the Competent Authority/Licensing Authority. 3. This report form is current as of October It is the responsibility of the Applicant/ Environmental Assessment Practitioner ( EAP ) to ascertain whether subsequent versions of the report form have been released by the Department. Visit the Department s website at to check for the latest version of this checklist. 4. The required information must be typed within the spaces provided in the form. The size of the spaces provided is not necessarily indicative of the amount of information to be provided. The tables may be expanded where necessary. 5. The use of not applicable in the report must be done with circumspection. All applicable sections of this report form must be completed. Where not applicable is used, this may result in the refusal of the application. 6. While the different sections of the report form only provide space for provision of information related to one alternative, if more than one feasible and reasonable alternative is considered, the relevant section must be copied and completed for each alternative. 7. Unless protected by law, all information contained in, and attached to this report, will become public information on receipt by the competent authority. If information is not submitted with this report due to such information being protected by law, the applicant and/or EAP must declare such non-disclosure and provide the reasons for believing that the information is protected. 8. Unless otherwise indicated by the Department, one hard copy and one electronic copy of this report must be submitted to the Department at the postal address given below or by delivery thereof to the Registry Office of the Department. Reasonable access to copies of this report must be provided to the relevant Organs of State for consultation purposes, which may, if so indicated by the Department, include providing a printed copy to a specific Organ of State. 9. This Report must be submitted to the Department and the contact details for doing so are provided below. 10. Where this Department is also identified as the Licencing Authority to decide applications under NEM:WA or NEM:AQA, the submission of the Report must also be made as follows, for- Waste management licence applications, this report must also (i.e., another hard copy and electronic copy) be submitted for the attention of the Department s Waste Management Directorate (tel: and fax: ) at the same postal address as the Cape Town Office. Atmospheric emissions licence applications, this report must also be (i.e., another hard copy and electronic copy) submitted for the attention of the Licensing Authority or this Department s Air Quality Management Directorate (tel: and fax: ) at the same postal address as the Cape Town Office. DEPARTMENTAL DETAILS REGION 1 (City of Cape Town & West Coast District) CAPE TOWN OFFICE REGION 2 (Cape Winelands District & Overberg District) GEORGE REGIONAL OFFICE REGION 3 (Central Karoo District & Eden District) Department of Environmental Affairs and Development Planning Attention: Directorate: Development Management (Region 1) Private Bag X 9086 Cape Town, 8000 Registry Office 1 st Floor Utilitas Building 1 Dorp Street, Cape Town Queries should be directed to the Directorate: Development Management (Region 1) at: Tel.: (021) Fax: (021) Department of Environmental Affairs and Development Planning Attention: Directorate: Development Management (Region 2) Private Bag X 9086 Cape Town, 8000 Registry Office 1 st Floor Utilitas Building 1 Dorp Street, Cape Town Queries should be directed to the Directorate: Development Management (Region 2) at: Tel.: (021) Fax: (021) Department of Environmental Affairs and Development Planning Attention: Directorate: Development Management (Region 3) Private Bag X 6509 George, 6530 Registry Office 4 th Floor, York Park Building 93 York Street George Queries should be directed to the Directorate: Development Management (Region 3) at: Tel.: (044) Fax: (044) BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 3 of 114

5 TABLE OF CONTENTS: Section Page(s) Section A: Project Information 16 Section B: Description of the Receiving Environment 28 Section C: Public Participation 41 Section D: Need and Desirability 44 Section E: Details of all the Alternatives considered 49 Section F: Environmental Aspects Associated with the Alternatives 56 Section G: Impact Assessment, Impact Avoidance, Management, Mitigation and Monitoring 65 Section H: Recommendations of the EAP 99 Section I: Appendices 100 Section J: Declarations 102 APPENDICES: APPENDIX Appendix A: Locality Map X Appendix B: Appendix C: B1: Site Development Plan(s) X B2: Simplified Process Flow Diagram X B3: Detailed Process Flow Diagram X Photographs Confirm that Appendix is attached X Appendix D: Biodiversity Overlay Map X Appendix E: Copy of comment from HWC. X Appendix F: Appendix G: Public participation information: including a copy of the register of I&APs, the comments and responses report, proof of notices, advertisements and any other public participation information as is required in Section C above. Appendix F1: Register of Interested & Affected Parties Appendix F2: Site Notice & Proof of Placement Appendix F3: Newspaper Advertisements & Proof of Placements Appendix F4: Proof of Notification Appendix F5: All Comments Received Appendix F6: Comments & Responses Table Appendix F7: Comments Received from DEA & DP: Land Management & Waste Management: Pre-application Consultation Phase Specialist Report(s) Appendix G1: Noise Impact Assessment Appendix G2: Traffic Impact Assessment Appendix G3: Air Dispersion Modelling Study X X X Proof Pending X Proof Pending Pending Pending Pending X X X X X Appendix H : EMPr X BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 4 of 114

6 Appendix I: CV of EAP X ACRONYMS USED IN THIS BASIC ASSESSMENT REPORT AND APPENDICES: BAR Basic Assessment Report CBA DEA DEA&DP DWS EIA EMPr ESA HWC I&APs Critical Biodiversity Area National Department of Environmental Affairs Western Cape Government: Environmental Affairs and Development Planning National Department of Water and Sanitation Environmental Impact Assessment Environmental Management Programme Ecological Support Area Heritage Western Cape Interested and Affected Parties NEMA National Environmental Management Act, 1998 (Act No. 107 of 1998) NEM:AQA National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) NEM:ICMA National Environmental Management: Integrated Coastal Management Act, 2008 (Act No. 24 of 2008) NEM:WA National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) NHRA National Heritage Resources Act, 1999 (Act No. 25 of 1999) PPP Public Participation Process BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 5 of 114

7 DETAILS OF THE APPLICANT Applicant / Organisation / Organ of State: Minrite (Pty) Ltd Contact person: Martin Calitz Postal address: 14 Park Lane, Century City Telephone: (027) Postal Code: 7441 Cellular: Fax: (027) martin@minrite.com DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER ( EAP ) Name of the EAP organisation: Sillito Environmental Consulting (Pty) Ltd (SEC) Person who compiled this Report: Lauren Elston EAP Reg. No.: N/A Contact Person (if not author): Lauren Elston Postal address: PO Box Tokai Telephone: (021) Postal Code: 7966 Cellular: Fax: (021) laurene@environmentalconsultants.co.za Bachelor of Science (Honours) Degree: Environmental Management. EAP Qualifications: Bachelor of Science Degree: Environmental & Geographical Science and Oceanography & Atmospheric Sciences. Please provide details of the lead EAP, including details on the expertise of the lead EAP responsible for the Basic Assessment process. Also attach his/her Curriculum Vitae to this BAR. Lauren has a Bachelor of Science Honours Degree in Environmental Management obtained from UNISA (cum laude) and a Bachelor of Science Degree (Environmental & Geographical Science, Atmospheric Science and Oceanography) obtained from UCT in She has more than 10 years of local and international practical experience in the environmental impact assessment, management consulting and climate science fields of expertise. Lauren has compiled numerous Environmental Impact Assessment Reports in the past 10 years and she has worked in the private environmental consulting field as well as in the public sector as an environmental case officer for DEA & DP in Lauren is a member of the International Association for Impact Assessment (IAIA). SEC has extensive experience in environmental impact assessment (EIA) procedures and has completed numerous such applications in most provinces of South Africa since BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 6 of 114

8 EXECUTIVE SUMMARY OF THE BASIC ASSESSMENT REPORT: 1. Introduction & Background Minrite Pty Ltd (Minrite) is an existing mineral processing facility which has been in operation since the mid 1990 s. Minrite currently operates one mineral dryer (combustion installation). In May 2018, the West Coast District Municipality (WCDM) issued the facility with a Provisional Atmospheric Emissions License (PAEL) for its operations. Minrite proposes to increase its current production design capacity from tons to tons per month by upgrading its facilities over the next 5 years by installing three additional rotary dryers to process additional feed material. The installation of the three additional dryers and additional fuel storage has triggered the requirement for a Basic Assessment Environmental Impact Assessment (EIA) process in terms of the 2014 EIA Regulations, as amended, published under the National Environmental Management Act (NEMA) and the need to apply for a Variation of the existing PAEL in terms of the National Environmental Management Air Quality Act (NEM: AQA). 2. Project Location The site is located in Stasie Road, on the northern boundary of the town of Lutzville on the old siding and station platform owned by Transnet. Please refer to Appendix A which shows the locality of the site. Figure 1: Locality Map (red arrow points to the site) 3. Summary Description of the Proposed Upgrade Minrite currently processes an average of tons per month of mineral concentrate in its existing dryer which has a design capacity of tons per month. Minrite has entered into an agreement with Namakwa Sands to process an additional tons of mineral concentrate which will require three additional dryers to be installed over the next 5 years, each dryer with a capacity to process tons. It is therefore proposed to increase the existing design capacity from tons to tons per month and the actual production capacity from tons per month to tons per month. It is proposed to increase the current fuel storage capacity on site from 50m 3 to 96m 3, to accommodate the proposed BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 7 of 114

9 upgrade. Currently approximately 900 tons per month (50% of raw material input) of waste material (inert waste) is taken back to the Brand-se-Baai mine at Namakwa Sands for use for infill material in the mine as part of its rehabilitation phase. An additional tons of waste (33% of raw material input) is expected to be produced from the new proposed raw materials. 4. Need & Desirability for the Upgrade The opportunity has risen for Minrite to increase its production capacity and grow the business due to a new agreement with Namakwa Sands to process an additional tons per month of minerals from their existing Mineral Separation Plant (MSP), located just north of Koekenaap. Up to tons per month of minerals are available at existing stockpiles at the MSP that have been stockpiled by Namakwa Sands over many years with the aim of processing them further at some point. An additional tons of freshly produced feed material from the MSP is also available for further processing by Minrite. The upgrade is therefore needed and desired so that the existing historic stockpiles at the MSP can be further processed before the waste product is used for rehabilitation purposes at the Namakwa Sands mine at Brand-se Baai. The upgrade will not only reduce the size of the long standing stockpiles at the MSP site but it will also contribute to the rehabilitation of the open cast pit at Namakwa Sands. The expansion of the Minrite site will also add to investment in the area, support increased beneficiation of Minerals in South Africa and create additional job to the local economy. The proposed upgrade is within the existing facility s footprint which is a completely disturbed area. The upgrade is in line with the existing consent use industrial zoning of the site. There are no biodiversity impacts associated with the upgrade in terms of impacts to vegetation or water resources. The proposed upgrade is not associated with any impacts to the heritage or cultural environment. The upgrade of the facility s mineral processing infrastructure to increase the processing design capacity of the plant from tons per month to tons per month (and actual production capacity from tons per month to tons per month) is associated with increased traffic, increased air emissions (dust in particular), health, safety and noise impacts. These impacts are already occurring to some degree at the existing facility and are being managed in line with Health & Safety Operational Procedures and their existing Atmospheric Emissions License monitoring and management requirements. Minrite currently employs 31 full time employees and also make use of contract workers from time to time. The proposed upgrade is expected to provide an additional 25 full time jobs which will result in a positive socio-economic impact in terms of the provision of jobs, skills and income opportunities. Minrite will contribute towards skills development in line with the company s internal skills development plan. The majority of formally employed individuals in the Matzikama Local Municipality are low skilled labour, therefore skills development is crucial in the area. 5. Legislation The following activities in Listing Notice 1 of the 2014 EIA Regulations, as amended, published under the National Environmental Management Act (NEMA) are triggered by the proposed upgrade: Activity No. 34: The expansion or changes to existing facilities for any process or activity where such expansion or changes will result in the need for a permit or licence or an amended permit or licence in terms of national or provincial legislation governing the release of emissions or pollution. Activity No. 51: The expansion and related operation of facilities for the storage, or storage and handling, of a dangerous good, where the capacity of such storage facility will be expanded by more than 80 cubic metres. Activity No. 67: Phased activities for all activities i) Listed in this notice, which commenced on or after the effective date of this notice or BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 8 of 114

10 similarly listed in any of the previous NEMA notices, which commenced on or after the effective date of such NEMA notices, where any phase of the activity may be below a threshold but where a combination of the phases, including expansions or extensions, will exceed a specific threshold. Minrite was issued with a Provisional Atmospheric Emissions License in May 2018 to undertake the following Scheduled Process listed in Government Notice 893, published under the National Environmental Management Air Quality Act (NEM: AQA),as amended: Category 5: Mineral Processing, Storage & Handling: Subcategory 5.2: Drying: The drying of mineral solids including ore, using dedicated combustion installations. A Basic Assessment EIA Process is therefore required with the aim of receiving an Environmental Authorisation to undertake the listed activities in the 2014 EIA Regulation published under NEMA. It is also required to apply for a Variation to Minrite s existing Provisional Atmospheric Emissions License in terms of the NEM: AQA. A joint public participation process is therefore proposed to satisfy the public participation requirements of both Acts. Minrite is classified as a supervised area (CoR-150) in terms of the National Nuclear Regulatory Act, Act 47 of 1999 (NNRA). In terms of said Act the Minrite operations are audited annually and inspected bi-annually by the National Nuclear Regulator (NNR). The level of exposure to Naturally Occurring Radioactive Materials (NORM) is very low and far below the legal threshold limit. This enables Minrite to process, transport and store originating product from NORM material. 6. Alternatives The table below provides a summary of the alternatives that have been and are currently being considered / investigated during the Basic Assessment process. Table 1: Summary Table of Alternatives Considered and Reason for Discarding Type of Alternative Site location alternatives Design / Layout Alternatives (Noise Mitigation) Operational Alternatives: Separation Mineral Operational Alternatives: Fuel Type Description of Alternative None Outcome/ Comments Minrite has been in operation on the proposed site since the 1990 s. The Company proposes to increase its mineral processing capacity by installing additional infrastructure adjacent to its existing site, in the same area under their current lease agreement with Transnet. The site proposed for the expansion is within an existing disturbed footprint with no impact to the terrestrial, cultural or aquatic environment. In addition, there are no other serviced industrial sites in Lutzville. Assessing site location alternatives is therefore in this instance not deemed to be required or feasible for Minrite. Proposed Construction of a Wall on the Southern Boundary of the Development Disregarded as undesirable due the length of time it would take the landowners to approve such a structure and the cost for the structure. A more suitable option, which would also result in the noise levels being within the noise levels prescribed in the Western Cape Noise Control Regulation (2013) is therefore proposed. Only Proposed Option: Installation of Circular Dust Attenuators on the Fans The installation of circular duct attenuators on the dryer fans and the dust extraction fans is proposed. Wet Mineral Separation A large amount of potable water and a large development footprint would be required for wet magnetic separation at a higher capital cost. The availability of potable water is also not guaranteed. Wet mineral separation has therefore been considered and investigated by Minrite but determined to be unfeasible. Only Proposed Option: Dry Mineral Separation Minrite proposes to use dry mineral separation and it is for this reason that it requires an additional 3 rotary dryers as part of the upgrade. Diesel Discarded as too expensive. BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 9 of 114

11 Operational Alternatives: Separation Magnetic Technology Alternatives (Emissions Mitigation) Transport Alternatives Paraffin Discarded as not available in bulk and transport costs would be too high. Only Proposed Option: Industrial Burning Oil & Light Oil 10 Due to the high cost of diesel and the unavailability of bulk paraffin in Lutzville the proposed fuel for the upgrade is recycled oil (IBO /LO10), which is what is used in the existing rotary dryer at Minrite. Rare Earth Roll Disregarded as unfeasible because they suffer from belt wear issues which can be detrimental to both belt life and separation efficiency. Furthermore, compaction of the feed bed on the rare earth roll belt can lead to non-magnetic particles becoming held within the bed of material, leading to reduced separation efficiency. Induced Roll Magnetic Separator This type of magnetic separation is similar to the rare earth drum (described below) but it has a higher capital cost, reduced ore throughput and higher operating costs. IRMS machines generally have a lower throughput capacity and are more expensive which raise the overall capital expenditure for the project. They are also not ideally suited to the minerals to be processed and rely on electricity to product the requirement magnetic field. This raises the operating cost of the project unnecessary and increases the burden on the local electricity supply. This option was therefore also rejected by Minrite. Rare Earth Drum (Proposed Alternative) From the drier the concentrate is fed into the mineral separation plant where the valuable minerals are separated from the waste product through magnetic processes in a closed system fitted with dust filters before the product goes through a particle size grading system. The existing mineral processing uses this magnetic separation option and given the nature of the raw materials and the fact that existing infrastructure is on site already to some extent, this is the proposed option for the purpose. The capital costs and operating costs are also lower than induced roll magnetic separation. It was therefore selected as the most viable option for the new plans. Cyclone Filter: Still under investigation. Minrite can use any technology option as long at the option results in the Emissions being within the Minimum Emissions Standards published in Government Notice No. 893 of 2013, which has been published in terms of the National Environmental Management Air Quality Act (NEMAQA). Reverse Pulse Bag Filter: Still under investigation. Minrite can use any technology option as long at the option results in the Emissions being within the Minimum Emissions Standards published in Government Notice No. 893 of 2013, which has been published in terms of the National Environmental Management Air Quality Act (NEMAQA). 1. Only Proposed Option: Truck Transport 2. Rail Transport: Disregarded as unfeasible because of the allocation capacity of the line. No-Go Option Status Quo remains. Not preferred but assessed as Alternative B. Although many alternatives have been considered, many have been disregarded as unfeasible and unreasonable (for the reasons explained above) and not assessed further in this EIA Process. The proposed development as per the description of the development outlined in Section 2 below and as per the layout plan in Appendix B1, is the only alternative (labelled as Alternative A) comparatively assessed against the NO-GO Alternative (Alternative B). 7. Receiving Environment The existing Minrite processing facility is located on the old siding and station platform owned by Transnet. The site is a transformed site as the existing Minrite facility is located on the site already. There is no vegetation and no watercourses on the site. The site is characterised by a transformed sand / gravel disturbed surface with existing infrastructure. The site has no cultural or heritage significance. There are however sensitive receptors (residential areas) located south and north west of the facility that could be affected by air quality, noise and traffic impacts, if not managed appropriately. 8. Public Participation A pre-application consultation meeting took place with the West Coast District Municipality (WCDM), DEA & DP: Land Management and the DEA & DP: Waste Management Departments on the 13 th June 2018 to confirm the listed activities applicable and EIA process to follow with the two Competent Authorities. In BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 10 of 114

12 addition, a letter of motivation was sent to Heritage Western Cape to apply to be exempt from submitting a Notice of Intent. Please refer to Appendix F7 for the initial comments received from the DEA & DP Land Management & Waste Directorates and Appendix E for final comment from Heritage Western Cape. No other pre-application consultation has taken place. It is only proposed to undertake one round of public and Authority consultation (30 days), as is required in the EIA Regulations, to take place after an Application has been submitted. The following public participation is currently underway (as per Chapter 6 of GN 326): A Site Notice has been placed at the entrance to the existing minerals processing facility, advertising the availability of the Draft BAR for a 30 day public participation period; A joint public participation process is being conducted in terms of NEMA & NEM:AQA; Two newspaper advertisements have been placed, one in Die Burger and the other in Ons Kontrei advertising the availability of this Draft BAR and providing the public with the opportunity to provide SEC with their comments. A register of Interested & Affected Parties has been opened and will be updated after the 30 days commenting period. Notification Letters have been posted to 30 identified adjacent landowners and / or occupiers, inviting the adjacent landowners and occupiers to comment on the Draft BAR. Colour hardcopies of the Draft BAR Report have been posted to 6 identified Key Authorities who have been requested to provide their comments on the Draft BAR. All comments will be responded to in writing and a Comments & Responses Table which will be submitted with the Final BAR to the DEA & DP. All comments received and all responses to the comments will be included in the Final BAR submission to the DEA & DP. 9. Identification & Assessment of Impacts No biodiversity impacts to the terrestrial or freshwater environment are associated with the existing or proposed expansion of the Minrite Facility. The proposed expansion is within the existing transformed footprint area of the Minrite Facility. The proposed upgrade involves the installation of additional infrastructure to increase the existing mineral processing capacity at the plant. A summary of the assessed significance 1 of the identified impacts (after mitigation is successfully implemented) is provided in the tables below: 1 The impact assessment methodology used has been closely guided by the DEAT EIA Guideline Document 5, on the assessment of impacts and alternatives (DEAT 2006); as well as reference to the description of the criteria used for the assessment of impacts as contained in the DEA&DP Specialist Guidelines Series (2005). BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 11 of 114

13 CONSTRUCTION PHASE IMPACTS IMPACT SIGNIFICANCE (after mitigation) IMPACT Alternative A: The Proposed Development Alternative B: No- Go Alternative Air Quality Impacts: Dust Associated with Construction & Traffic Low (-) None Fire, Health & Safety Risk Associated with fuel delivery, storage and dispensing of flammable liquids Low (-) None Noise Impacts: Associated with Construction Machinery Low (-) None Traffic and Safety Impacts: Associated with Delivery of Construction Materials Visual Impact: Associated with Poor Housekeeping During Construction Activities Soil & Groundwater Contamination: Associated with Poor Waste Management Activities, Fuel Spills and /or Cement Batching during Construction Activities Low (-) Low (-) Low (-) None None None Socio-economic: Creation of Temporary Jobs Medium (+) Medium (-) OPERATIONAL PHASE IMPACTS IMPACT SIGNIFICANCE (after mitigation) IMPACT Alternative A: The Proposed Development Alternative B: No- Go Alternative (Status Quo) Air Quality Impacts (including dust): Associated with Emissions from the Stack (Particulate Matter, S02 and NOX) Health & Safety Impacts: Associated with Low-Level Radioactive Material Handling Fire, Health & Safety Risk Associated with fuel delivery, storage and dispensing of flammable liquids Noise Impacts: Associated with the Dryer Fans and Dust Extraction Fans Traffic & Safety Impact: Associated with the increase in truck trips and staff trip in and out the plant. *Low Medium (-) *Low Medium (-) Low (-) Low (-) Low (-) Low (-) Low (-) Low-Medium (-) Low (-) Low (-) Visual Impact: Associated with Additional Infrastructure Low Medium (-) Low Medium (-) Socio-Economic: Creation of Permanent Jobs High (+) High (-) *Assuming the Minimum Emission Standards are met with the installation of abatement equipment 10. Specialist Input Summary A Noise Impact Assessment, Traffic Impact Assessment and an Air Dispersion Modelling Report have been undertaken to inform the findings of this Environmental Impact Assessment. Please note the following Key Findings & Recommendations in each specialist report: 10.1 Noise Impact Assessment The main findings & recommendations of the noise impact assessment are as follows: The Minrite processing facility is considered an industrial area. The nearest sensitive receptors are residential and business premises to the South-West of the site. The main noise sources identified are the dryer fans and the dust extraction fans. The existing plant operations do not exceed the maximum applicable limit of 77.0 dba during the BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 12 of 114

14 day-time. The existing plant operations exceed the maximum applicable limit of 67.0 dba during the nighttime at MR07 by 3.5 dba. The proposed plant operations will not exceed the maximum applicable limit of 77.0 dba (as per the limits defined in the Western Cape Noise Control Regulations, 2013) during the day-time. The proposed plant operations will however exceed the maximum applicable limit of 67.0 dba (as per the limits defined in the Western Cape Noise Control Regulations, 2013) during the night-time at the property plot boundary by at least 5 dba. Additional noise mitigation is therefore necessary to reduce night time noise levels from the proposed plant expansion to acceptable levels. It is recommended that Minrite install circular duct attenuators on the dryer fans and the dust extraction fans during the upgrade. The recommended circular duct attenuators to be installed must provide the following minimum attenuation requirements: Table 1: Minimum attenuation specification for Minrite processing facility fans. 63 Hz 125 Hz 250 Hz 500 Hz 1 khz 2 khz 4 khz 8 khz 4 db 6 db 9 db 14 db 21 db 19 db 16 db 13 db The overall conclusion of the investigation undertaken by Mackenzie Hoy Consulting Engineers is that the Minrite processing facility expansion would only be acceptable in terms of the Western Cape Noise Control Regulations, 2013 provided the following: o The layout of the proposed plant expansion as specified in the noise report is unchanged. o The summarised recommendations specified in this Noise Impact Assessment are implemented. o The assumptions stated in the noise impact report are accepted as true and correct Traffic Impact Assessment The main findings & recommendations of the traffic impact assessment are as follows: All generated waste product from the existing and upgrade activities at Minrite is proposed to be taken to Namakwa Sands in Brand-se-Baai (approximately 70km north). The final product as part of the expansions is aimed at the export market and will be transported to Cape Town via the N7/N1. All haul routes used are public surfaced roads, were observed to be in good condition and are suitable for the purpose of transporting materials to and from the proposed plant via payload trucks (30 ton capacity trucks). The total future peak hour trip generation of 23 trips during both peak hours is considered an insignificant traffic impact regardless of the distribution over the local road network. In addition, some of the trucks transporting raw concentrate to Minrite will transport waste material back to Namakwa Sands (Brand-se-Baai) on their return trips thereby minimizing the number of empty trips as far as possible and decreasing the traffic impact. The estimated trip generation is therefore considered to be a conservative number. The parking provision proposed is deemed sufficient. The shoulder sight distances at all access points and affected intersections were observed to be sufficient. It is recommended that flagmen should regulate the traffic at the main gate during morning and afternoon peak hours to minimise the potential conflict between trucks and private/ public transport vehicles. The following road signage must be implemented: Table 2: Road Signage Schedule Required to be Implemented BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 13 of 114

15 10.3 Air Dispersion Modelling Report The main findings & recommendations of the air dispersion modelling report are as follows: WKC Group (2017) explain in the report that the following emissions were considered in the assessment due to their known impact on human health and their potential to be released to the atmosphere: o Oxides of Nitrogen (NOx): Predominantly comprising NO2 and nitric oxide (NO). NO2 is toxic at relatively low concentrations, and can be readily formed by the oxidation of NO in the presence of atmospheric oxidants; o Sulphur Dioxide (SO2): Anthropogenic emissions of SO2 originate from the combustion of sulphur containing fuels. SO2 in the ambient environment is linked with increased rates of respiratory illness including asthma; and, o Particulate Matter (PM) with an aerodynamic diameter of 2.5 µm (PM2.5) and 10 µm (PM10) poses a health risk as the particles can penetrate deep into the lungs and may even enter into the bloodstream. Exposure to such particles can affect both the lungs and heart and should be avoided where possible. Sensitive receptors were identified (6 clusters of residential developments) and included in the model. The plume dispersion of emissions is largely transported in the direction of the wind. WKC Group (2017) found that there is a high occurrence of low-medium wind from the west and a low occurrence of low-medium wind from the east (there are no residents east of the facility so these are favourable wind conditions as dust is transported east with westerly winds). Stack testing of emission concentrations was conducted in The results of the stack testing indicated that the NO2 and SO2 concentrations were compliant with the Minimum Emissions Standards regulated in Section 21 of NEM: AQA. SO2 concentrations were considered negligible. This is because ambient air is added to the drying drum during the drying process which results in dilution of SO2 in the exhaust. The PM results from the stack testing at the existing stack however exceeded the Minimum Emissions Standards. In order to quantify the atmospheric emissions from the four dryers an inventory was prepared. The emissions inventory was prepared using the actual measured stack concentrations of SO2 and NO2. For emissions of PM, it was assumed that all dryers will meet the new minimum emissions standard for PM (50mg/Nm 3 ) once commissioned. Three scenarios were considered using a combination emissions data provided by Minrite, national regulated emission standards and internationally-recognised emission factors. Modelled concentrations were compared against the NAAQS. The modelling assessment predicted that the operation of facility is not anticipated to cause noncompliance of the relevant NO2, SO2, PM10 and PM2.5 NAAQS under normal operating conditions. For Scenarios 1 3 considered, there are no predicted exceedances of any of the relevant National Ambient Air Quality Standards (NAAQS) at the project boundary or beyond (assuming that PM BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 14 of 114

16 emissions will be within the MES). In summary, the modelling assessment predicts that the operation of the facility under normal and maximum operating conditions is not likely to result in significant in impacts to ambient air quality and community health. The Minimum Emissions Standards (MES) applicable to the project are shown in the table below. These standards are regulated under sub-category 5.2 of the NEM: AQA. Therefore new dryers proposed to be installed must meet the new standard of 50mg/Nm 3. The existing dryer must meet the new standard by April Table 3: Minimum Emissions Standards that must be met by April 2020 Subcategory 5.2 Drying Description: The drying of mineral solids including ore, using dedicated combustion installations. Application: Facilities with a capacity of more than 100 tons/month product Substance or mixture of substances Common Name Chemical Symbol Plant Status mg/nm 3 under normal conditions of 273 Kelvin and kpa Particulate matter PM New 50 Existing 100 New 1,000 Sulphur dioxide SO 2 Existing 1,000 Oxides of nitrogen NO X expressed as NO 2 New 500 Existing 1,200 Minrite must ensure that the new dryers are designed on the basis of a vendor guarantee to meet the emission limit for PM (50mg/Nm 3 ). This will require the installation of abatement technology (such as bag house filters) in order to guarantee compliance with the Minimum Emission Standards for PM. The facility should ensure that the new dryers have the same emission performance as the current dryer in terms of NO2 and SO2. The facility should conduct stack testing annually on all four dryers to measure stack concentrations of PM, NO2 and SO2. To mitigate dust from fugitive emissions (material handling) the following is recommended: o Continuation of dust fallout monitoring programmes (through the use of fallout gauges); o Incorporation of dust suppression and other proactive site management practices. Visual inspection should be undertaken where operational activities cause visible dust beyond the plant boundary (for example in times of prolonged dry periods or high wind speeds). In this case, the activity in question should be halted or alternatively wet suppression any other applicable dust control measure should be applied as necessary. o Road watering on haul routes to minimise dust emissions from vehicle movements on-site. 11. Conclusions & Recommendations of the EAP No biodiversity impacts to the terrestrial or freshwater environment are associated with the existing or proposed expansion of the Minrite facility. The proposed expansion is within the existing transformed footprint area of the Minrite facility. The proposed upgrade involves the installation of additional infrastructure to increase the existing mineral processing capacity at the plant. Therefore the impacts associated with the proposed upgrade are already occurring at the existing facility to some extent and being managed by Minrite (in line with their existing Atmospheric Emissions License) and approvals from the National Nuclear Regulator (handling of low level radioactive materials). BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 15 of 114

17 The predominant winds in the area are westerly winds. There are no residential sensitive receptors located west of the site. Easterly winds do also occur but the nearest residence east of the site are approximately 300m away (Uitkyk suburb). Due to the expected increase in impacts that are already occurring (noise, traffic, health & safety and air emissions) as a result of the upgrade, mitigation measures have been recommended by the specialists and the Environmental Assessment Practitioner and included in the Environmental Management Programme (Appendix H). If the mitigation measures listed by the noise, traffic and air quality specialists (listed above) are implemented by Minrite, and if the mitigation measures listed in the EMP are implemented all impacts identified to occur during the construction phase (typical impacts associated with most construction sites in terms of noise, traffic and waste management) are expected to be of a low level of impact significance given the site specific extent of the proposed upgrade. The NO-GO Alternative, assumes the continuation of the status quo. The status quo is associated with noise, visual and air quality impacts 2 of a Low-Medium level of impact significance. The status quo is also associated with traffic, safety and health impacts (handling of low level radioactive materials) of a low level of impact significance. If the mitigation measures listed by the noise, traffic and air quality specialists (listed above) are implemented by Minrite, and if the mitigation measures listed in the EMP are implemented visual and air quality impacts identified to occur during the operational phase are expected to be of a Low-Medium level of impact significance (same significance as the status quo). Noise impacts are expected to be reduced with the proposed upgrade as a result of the installation of circular duct attenuators to the existing and proposed dryer fans and the dust extraction fans. Health impacts and traffic and safety impacts are expected to have the same impact significance as the status quo (low negative impact significance), with the implementation of mitigation. In conclusion, if the new dryers are designed on the basis of a vendor guarantee to meet the emission limit for PM (50mg/Nm 3 ) and abatement is also installed on the existing dryer to reduce its current emissions (as per the existing PAEL condition of approval required by November this year) the proposed upgrade is recommended by the EAP to be approved under these conditions of approval. This will require the installation of abatement technology (such as bag house filters) in order to guarantee compliance with the Minimum Emission Standards for PM. 2 The status quo of the existing PM emissions at the existing dryer is that the Minimum Emissions Standards are exceeded (double the MES). A condition of the Provisional Atmospheric Emissions License is that abatement needs to be installed and commissioned by November 2018 to bring the PM emissions in line with the MES. The status quo (NO-GO Alternative) assessment of air quality impacts has therefore assumed that the abatement at the existing dryer will be installed as this is a condition of the license. BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 16 of 114

18 SECTION A: PROJECT INFORMATION 1. ACTIVITY LOCATION Location of all proposed sites: Stasie Road, Lutzville Farm / Erf name(s) and number(s) (including Portions thereof) for each proposed Remainder Erf 405 site: Property size(s) in m 2 for each proposed site: The remainder of Erf 405 = m 2 Development footprint size(s) in m 2 : Surveyor General (SG) 21 digit code for each proposed site: Please refer to Table 1 in the development description below. The proposed development footprint of the existing and new infrastructure (excluding roads and parking) is proposed to be m 2. C PROJECT DESCRIPTION (a) Is the project a new development? If NO, explain: The project is a proposed upgrade to an existing Mineral Processing Facility, to increase the processing capacity of the existing facility. YES NO (b) Provide a detailed description of the scope of the proposed development (project). 1. Introduction & Description of Existing Development Minrite has an existing mineral processing facility that has been in operation since the mid 1990 s when minerals sands raw concentrate became available from Namakwa Sands mine, located 70km north of Lutzville. The existing plant currently processes on average 1800 tons per month of raw material mineral concentrate. The mineral concentrate is dried in a rotary drum dryer. The existing plant has a design capacity to process tons of mineral concentrate in its one existing rotary dryer. The existing facility produces various grades of dried garnet, garnet-ilmenite mix, and ilmenite for use in industrial applications such as sandblasting, water jet cutting and non-slip surfacing. The activities at Minrite include mineral processing, drying, packaging and warehousing. The waste product (approximately 900 tons per month) once the garnet and ilmenite have been extracted by the process of magnetic separation, is returned to the Namakwa Sand mine at Brand se Baai and used as fill material for the rehabilitation of the open cast pit (under the Namakwa Sands mining license). The existing Minrite processing facility processes, transports and stores material that contains Naturally Occurring Radioactive Materials (NORM). Therefore the facility is classified as a supervised area in terms of the National Nuclear Regulatory Act (NNRA). The facility is therefore audited annually by the National Nuclear Regulator (NNR). According to the site manager, the levels of exposure to the NORM s have been shown to be very low and far below the legal threshold limit. A key stage in the mineral separation process is the drying of the minerals by means of a rotary dryer. Minrite has one existing rotary dryer on its existing premises. The rotary dryer is fuelled by a mixture of Industrial Burning Oil (IBO) and Light Oil 10, a low sulphur alternative to illuminating paraffin and diesel. The average fuel consumption of the dryer is litres per month. Minrite currently has a cyclone filter (abatement / control equipment to reduce emissions) installed at the dryer. There are two X litre above ground fuel storage tanks on site. There is also a litre paraffin storage tank and a litre diesel storage tank on the site. Existing storage of dangerous goods is therefore litres (50m 3 ). Minrite is currently leasing the site from Transnet. The site is located at the old siding and train station platform of Lutzville. The site is zoned for Transport, however Minrite applies every 5 years to the Local Municipality for a Temporary Departure / Consent Use to renew the consent use to undertake an industrial BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 17 of 114

19 activity on the site because Transnet does not permit the rezoning of land owned by Transnet away from Transport. The drying of mineral solids using combustion installations (for facilities that have a capacity of >100 tons per month) is a Listed Activity published in terms of section 21 of the National Air Quality Management Act (NEM: AQA). Authorisation is therefore required in the form of an Atmospheric Emissions License. A Provisional Atmospheric Emissions License (PAEL) was issued to Minrite, for its existing facility (one rotary dryer), on the 14th May Minrite now proposes to apply for a Variation to their existing Provisional Atmospheric Emissions License and this also triggers the need to undertake a Basic Assessment EIA in terms of the 2014 EIA Regulations published under the National Environmental Management Act (NEMA). 2. The Proposed Upgrade 2.1 The Proposed Upgrade & Mineral Separation Process Minrite has entered into an agreement with Namakwa Sands to process and additional tons per month of mineral concentrate. The company proposes to upgrade its existing facilities over the next 5 years by installing three additional rotary drum dryers, each with a processing capacity of tons per onth. It is proposed to increase the current design capacity of the mineral processing facility from tons per month to tons per month at maximum design capacity. However, the facility is expected to receive an average of 19,800 tpm of feed material, less than the maximum design capacity, once upgraded. Currently approximately 900 tons per month (50% of raw material input) of waste material (inert waste) is taken back to the Brand-se-Baai mine at Namakwa Sands for use for infill material in the mine as part of their rehabilitation phase. An additional tons of inert waste (33% of raw material input) is expected to be produced from the new proposed raw materials. The existing dryer will continue using the existing stack and the three proposed new dryers will be connected to one new common stack to be installed, including associated infrastructure and abatement equipment to control the emissions. In summary, the following infrastructure is proposed (please refer to corresponding proposed site layout plan below which shows the existing garnet production plant and the proposed new mineral separation plant): Ablution facilities; Offices; Change house and laundry; Conveyors; Feed hopper loading area; Feed hoppers; Greenroom; Mechanical Workshop; Laboratory and Packaging; MSP Salvage Yard; MLB Salvage Yard; MSP and storage shed; Product coolers; Waste bunkers (2.5m height); Surge bins; Three additional rotary drum dryers, new 7.5m high stack & new abatement equipment; Additional fuel storage area; and Parking & internal roads BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 18 of 114

20 All processing for the upgrade will take place in an enclosed facility warehouse (approximately 8m in height). It is proposed to provide 10 staff parking bays and 3 visitor parking bays. Trucks are proposed to park in designated areas. Figure 2: Existing and Proposed New Mineral Separation Plant The existing development footprint (green area in image above with associated co-ordinates) is approximately 380m 2. The proposed upgrade final development footprint (red area and green area in figure above with associated co-ordinates) is proposed to be approximately 580m 2. It is therefore proposed to expand the current development footprint by approximately 200m 2, all of which is in an already disturbed area where Minrite already has existing operational areas / salvage yards etc as can be seen from the image above. A simplified process flow diagram for the facility is shown in the figure below. BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 19 of 114

21 Figure 3: Simplified Process Flow Diagram The Air Quality Impact Assessment undertaken by the WKC Group (2017) explains that the upgrade will consist of the following steps: The feed material concentrate is transported to Minrite via payload trucks and offloaded into feed bins via the loading ramps. The feed material is offloaded into feed bins for processing. The feed material is dried to remove all excess moisture. The dryers will be fuelled with a mixture of IBO and L010 oils. The hydrocarbon fuels are stored in tanks and placed in a bunded facility adjacent to the dryer. After drying is completed the material is fed into the mineral separation plant where the valuable minerals are separated from the waste product through electrostatic and magnetic processes in a closed system fitted with dust filters. Thereafter, the product goes through a grading system. The graded product is packaged in sealed double lined bulk bags. Waste from the processing facility is stored in a bunker on-site before being transported back to the Namakwa Sand Mine for disposal. The final product is stored in the onsite warehouse. Bagged product is loaded from the warehouses onto the covered transporter trucks via a forklift. No products are stored outside of the warehouse as it is imperative that the products stay dry. Sub-contractor transporters are used for the delivery of the products to customers situated in Germiston (Gauteng Province) and Cape Town port for export (Western Cape). 2.1 Raw Material Input A description of the quantity and type of feed material is as follows: 1,800 tpm of mineral concentrate (existing throughput). The concentrate comprises the minerals garnet (non-magnetic) and also magnetic minerals (ilmenite). The raw concentrate has a moisture content of between 2% and 4%. 3,000 tpm of freshly produced feed material (referred to as current arisings). As per the design information, the current arisings will be a dry, clean feed material with minimal contamination; and, 15,000 tons per month of historic feed material from Namakwa Sands stockpiles. The historic feed BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 20 of 114

22 material has been stockpiled over a period of many years for re-processing and will therefore have traces of dust and other contaminants. 2.2 Fuel Usage The fuel used is a mixture of Light Oil (LO10 and Industrial Burning Oil (IBO). Approximately litres of fuel are currently being used per month at the existing dryer (approximately tons input of raw materials). Given that the existing dryer input capacity is proposed to increase to approximately tons it is expected that the existing dryer s fuel usage will increase to a maximum of litres per month. For the three additional dryers, approximately 8 litres of fuel will be required to dry one ton of mineral concentrate. Therefore, the upgraded three dryers are expected to use approximately litres per month. The maximum fuel input expected for all four dryers per month is therefore litres per month (171m 3 ). The current facility currently comprises of a fuel storage capacity of litres of Industrial Burning Oil and Light Oil 10 (2 X litre tanks) as well as litres of diesel and litres of paraffin stored in above ground tanks. The current fuel storage capacity is therefore litres (50m 3 ). It is proposed to install the following additional above ground fuel storage tanks: 2 X litre capacity (23m 3 ) above ground tanks to store L010/ IBO. It is proposed to increase the current fuel storage capacity on site from 50m 3 to 96m Outputs Approximately two thirds of all input material is proposed to be sold off as product. The intended products from the new source materials are garnet, ilmenite, a non-magnetic concentrate that may include rutile, zircon, and possibly other heavy minerals. It is proposed that a portion of the waste from the new processing facility (400tons/month for phase 1 and increasing to about tons at full production) will be put through the existing dryer to extract material such as garnet. Approximately 33% of all input material is proposed to be a waste product which will be transported to Namakwa Sands mine and used for the rehabilitation of the pit. Four new waste bunkers are proposed to be constructed to store the waste product from the upgraded facility. The existing facility produces approximately tons of product and discards approximately 800 tons of waste product. The proposed upgrade is expected to produce approximately 12,900 tpm of product, with approximately 6,900 tpm of waste product returned to the mine for disposal. After final processing in the new plant the final product will be packed into 1 ton or 2-ton sealed bulk bags with liners. Processing in the existing plant (separation and grading) will continue as currently, the products being packaged in 25kg bags and then into 1-ton or 2-ton sealed bulk bags with liner. All final products originating from the new processing plant will be stored in a separate storage facility on site. Please note: This description must relate to the listed and specified activities in paragraph (d) below. (c) Please indicate the following periods that are recommended for inclusion in the environmental authorisation: BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 21 of 114

23 (i) (ii) (iii) (iv) the period within which commencement must occur, the period for which the environmental authorisation should be granted and the date by which the activity must have been concluded, where the environmental authorisation does not include operational aspects; the period that should be granted for the non-operational aspects of the environmental authorisation; and the period that should be granted for the operational aspects of the environmental authorisation. 5 years N/A The operational phase is permanent. 10 years The Operational Phase will be permanent. Please note: The Department must specify the abovementioned periods, where applicable, in an environmental authorisation. In terms of the period within which commencement must occur, the period must not exceed 10 years and must not be extended beyond such 10 year period, unless the process to amend the environmental authorisation contemplated in regulation 32 is followed. (d) List all the listed activities triggered and being applied for. Please note: The onus is on the applicant to ensure that all the applicable listed activities are applied for and assessed as part of the EIA process. Please refer to paragraph (b) above. EIA Regulations Listing Notices 1 and 3 of 2014 (as amended): Listed Activity No(s): Describe the relevant Basic Assessment Activity(ies) in writing as per Listing Notice 1 (GN No. R. 327) Listing Notice 1 51 The expansion and related operation of facilities for the storage, or storage and handling, of a dangerous good, where the capacity of such storage facility will be expanded by more than 80 cubic metres. Describe the portion of the development that relates to the applicable listed activity as per the project description. The current facility currently comprises of a fuel storage capacity of litres of Industrial Burning Oil and Light Oil 10 (2 X litre tanks) as well as litres of diesel and litres of paraffin stored in above ground tanks. The current storage capacity of dangerous good is therefore litres (50m 3 ). Identify if the activity is development / development and operational / decommissioning / expansion / expansion and operational. Expansion & Operational 67 Phased activities for all activities i) Listed in this notice, which commenced on or after the effective date of this notice or similarly listed in any of the previous NEMA notices, which commenced on or after the effective date of such NEMA notices, where any phase of It is proposed to install the following additional above ground fuel storage tanks: 2 X lire capacity (23m3) above ground tanks to store L010/ IBO. It is proposed to increase the current fuel storage capacity on site from 50m 3 to 96m 3. The current facility currently comprises of a fuel storage capacity of litres of Industrial Burning Oil and Light Oil 10 (2 X litre tanks) as well as 2000 litres of diesel and 2000 litres of paraffin stored in above ground tanks. The current storage capacity of dangerous good is therefore litres (50m 3 ). It is proposed to install the following additional above ground fuel storage tanks: 2 X lire capacity Expansion & Operational BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 22 of 114

24 the activity may be below a threshold but where a combination of the phases, including expansions or extensions, will exceed a specific threshold. 34 The expansion or changes to existing facilities for any process or activity where such expansion or changes will result in the need for a permit or licence or an amended permit or licence in terms of national or provincial legislation governing the release of emissions or pollution. (23m3) above ground tanks to store L010/ IBO. It is proposed to increase the current fuel storage capacity on site from 50m 3 to 96m 3. The drying of mineral solids using combustion installations (for facilities that have a capacity of >100 tons per month) is a Listed Activity published in terms of section 21 of the National Air Quality Management Act (NEM: AQA). Authorisation is therefore required in the form of an Atmospheric Emissions License. A Provisional Atmospheric Emissions License (PAEL) was issued to Minrite, for its existing facility (one rotary dryer), on the 14th May Minrite now proposes to apply for a Variation to its existing Provisional Atmospheric Emissions License and this also triggers Activity 34 in Listing Notice 1. Expansion & Operational Waste management activities in terms of the NEM: WA (GN No. 921): Category A Describe the relevant Category A waste management Listed activity in writing as per GN No. 921 Activity No(s): Not Applicable - see Appendix F7 Describe the portion of the development that relates to the applicable listed activity as per the project description Note: If any waste management activities are applicable, the Listed Waste Management Activities Additional Information Annexure must be completed and attached to this Basic Assessment Report as Appendix I. Atmospheric emission activities in terms of the NEM: AQA (GN No. 893): Listed Activity Describe the relevant atmospheric emission activity in No(s): writing as per GN No. 893 Subcategory Drying Description: The drying of mineral solids including ore, using dedicated combustion installations Application: Facilities with a capacity of more than 100 tons/month product Describe the portion of the development that relates to the applicable listed activity as per the project description. Minrite has an existing dryer (combustion installation), which currently dries approximately tons per month. Minrite therefore has an existing Provisional Atmospheric Emissions License. It is proposed to apply to vary their existing license. Minrite is already authorised to undertake this activity. (e) Provide details of all components (including associated structures and infrastructure) of the proposed development and attach diagrams (e.g., architectural drawings or perspectives, engineering drawings, process flowcharts, etc.). Buildings Provide brief description below: YES NO The proposed upgrade will comprise of an 8m high new warehouse structure (similar to the existing warehouse structure) to be built to house the mineral processing infrastructure as described above. Infrastructure (e.g., roads, power and water supply/ storage) Provide brief description below: YES NO BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 23 of 114

25 Two new salvage yards are proposed in the western end of the site to store equipment, vehicles, etc. Conveyors, feed hopper loading area, feed hopper, product cooler, waste bunkers, three additional rotary drum dryers, new 7.5m high stack (one common stack for the three additional dryers) & new abatement equipment are proposed. Processing activities (e.g., manufacturing, storage, distribution) Provide brief description below: YES NO The proposed upgrade is to upgrade the existing mineral processing facility, as per the description of development outlined above. Storage facilities for raw materials and products (e.g., volume and substances to be stored) Provide brief description below: YES NO The raw material storage area (enclosed bunkers) for the proposed upgrade will have a storage capacity of approximately 400 tons of raw mineral concentrate material. Four new small indoor waste bunkers are proposed to be constructed, each with a storage capacity of approximately 25 tons of waste material. Total waste storage capacity for the upgrade is therefore expected to be approximately 100 tons. It is also proposed to construct an additional fuel storage area with the capacity to store an additional litres of fuel. Storage and treatment facilities for effluent, wastewater or sewage: Provide brief description below: YES NO It is proposed to have the new ablutions connected to the municipal sewage system. Storage and treatment of solid waste Provide brief description below: YES NO Solid waste (inert waste/ mineral sands) is proposed to be stored in the existing waste silo on site and four additional waste bins to be constructed indoors, each with the capacity to store 25 tons of mineral sands. Facilities associated with the release of emissions or pollution. Provide brief description below: YES NO Minrite has one existing rotary dryer (combustion installation). Emissions are released via stack. The proposed upgrade is to install three additional rotary dryers that will release emissions via a new proposed common stack (7.5m height). Fugitive emissions are expected to occur as a result of material handling via truck transport as a result of the unpaved roads. The entire processing facility, including the waste bins, is proposed within an enclosed warehouse structure. Other activities (e.g., water abstraction activities, crop planting activities) Provide brief description below: N/A YES NO 3. PHYSICAL SIZE OF THE PROPOSED DEVELOPMENT (a) Property size(s): Indicate the size of all the properties (cadastral units) on which the development proposal is to be undertaken The remainder of Erf 405 = m m 2 Site Size (as per Transnet Lease agreement) is m m 2 BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 24 of 114

26 (c) Development footprint: Indicate the area that will be physically altered as a result of undertaking any development proposal (i.e., the physical size of the development together with all its associated structures and infrastructure) The existing development footprint (green area in Site Layout Plan with associated coordinates) is approximately 380m 2. The proposed upgrade final development footprint (red area and green area in the Site Layout Plan with associated co-ordinates) is proposed to be approximately 580m 2. It is therefore proposed to expand the current development footprint by approximately 200m m 2 (d) Size of the activity: Indicate the physical size (footprint) of the development proposal 200 m 2 (e) For linear development proposals: Indicate the length (L) and width (W) of the development proposal (L) (W) m m (f) For storage facilities: Indicate the volume of the storage facility N/A m 3 (g) For sewage/effluent treatment facilities: Indicate the volume of the facility (Note: the maximum design capacity must be indicated N/A m 3 4. SITE ACCESS (a) Is there an existing access road? YES NO (b) If no, what is the distance in (m) over which a new access road will be built? N/Am (c) Describe the type of access road planned: The site is located at the end of the existing Stasie Road. No road upgrades were recommended in the Traffic Impact Assessment as all roads proposed to be used are in relatively good condition. Please note: The position of the proposed access road must be indicated on the site plan. 5. DESCRIPTION OF THE PROPERTY(IES) ON WHICH THE LISTED ACTIVITY(IES) ARE TO BE UNDERTAKEN AND THE LOCATION OF THE LISTED ACTIVITY(IES) ON THE PROPERTY 5.1 Provide a description of the property on which the listed activity(ies) is/are to be undertaken and the location of the listed activity(ies) on the property, as well as of all alternative properties and locations (duplicate section below as required). The listed activities are proposed to take place on the remainder of Erf 405, Lutzville. Please refer to the topo-cadastral image below and the Google Earth Satellite Image. The site is located in Stasie Road, on the northern boundary of the town of Lutzville on the old siding and station platform owned by Transnet. The property is zoned for Transport (Transnet do not rezone their land) but Minrite has a consent use to undertake industrial activities on the site. Minrite has been in operation on this site since the 1990 s. As can be seen in the image below, the site is located directly below the railway line. The site is a 100% transformed site as the existing Minrite facility is located on the site already. There is no vegetation and no watercourses on the site. The site is characterised by a transformed sand / gravel disturbed surface with existing infrastructure. BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 25 of 114

27 Figure 4: Topo-cadastral Map. The red arrow indicates the location of the site (blue boundary). RESIDENTIAL INDUSTRIAL RESIDENTIAL INDUSTRIAL INDUSTRIAL Figure 5: Google Satellite image shows the completely transformed nature of the existing Mineral Processing Facility (green boundary) and the area also leased by Minrite proposed for the expansion (red area). BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 26 of 114

28 Coordinates of all the proposed activities on the property or properties (sites): Latitude (S): (deg.; min.; sec) Longitude (E): (deg.; min.; sec.) " o o o o o o Note: For land where the property has not been defined, the coordinates of the area within which the development is proposed must be provided in an addendum to this report. 5.2 Provide a description of the area where the aquatic or ocean-based activity(ies) is/are to be undertaken and the location of the activity(ies) and alternative sites (if applicable). Not Applicable. Coordinates of the boundary /perimeter of all proposed aquatic or ocean-based activities (sites) (if applicable): Latitude (S): (deg.; min.; sec) Longitude (E): (deg.; min.; sec) ' " o ' " ' " o ' " ' " o ' " ' " o ' " 5.3 For a linear development proposal, please provide a description and coordinates of the corridor in which the proposed development will be undertaken (if applicable). Not Applicable Note: For linear development proposals longer than 1000m, please provide an addendum with co-ordinates taken every 250m along the route. All important waypoints must be indicated and the GIS shape file provided digitally. 5.4 Provide a location map (see below) as Appendix A to this report that shows the location of the proposed development and associated structures and infrastructure on the property; as well as a detailed site development plan / site map (see below) as Appendix B to this report; and if applicable, all alternative properties and locations. The GIS shape files (.shp) for maps / site development plans must be included in the electronic copy of the report submitted to the competent authority. Locality Map: The scale of the locality map must be at least 1: For linear development proposals of more than 25 kilometres, a smaller scale e.g., 1: can be used. The scale must be indicated on the map. The map must indicate the following: an accurate indication of the project site position as well as the positions of the alternative sites, if any; road names or numbers of all the major roads as well as the roads that provide access to the site(s) a north arrow; a legend; a linear scale; the prevailing wind direction (during November to April and during May to October); and GPS co-ordinates (to 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 should be in degrees and decimal minutes. The minutes should have at least three decimals to ensure adequate accuracy. The projection that must be used in all cases is the WGS84 spheroid in a national or local projection). For an ocean-based or aquatic activity, the coordinates must be provided within which the activity is to be undertaken and a map at an appropriate scale clearly indicating the area within which the activity is to be undertaken. Coordinates must be provided in degrees, minutes and seconds using the Hartebeesthoek94; WGS84 co-ordinate system. Detailed site development plan(s) must be prepared for each alternative site or alternative activity. The site plans must contain or conform to the following: The detailed site plan must preferably be at a scale of 1:500 or at an appropriate scale. The scale must be Site Plan: indicated on the plan, preferably together with a linear scale. The property boundaries and numbers of all the properties within 50m of the site must be indicated on the site plan. The current land use (not zoning) as well as the land use zoning of each of the adjoining properties must be BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 27 of 114

29 indicated on the site plan. The position of each element of the application as well as any other structures on the site must be indicated on the site plan. Services, including electricity supply cables (indicate aboveground or underground), water supply pipelines, boreholes, sewage pipelines, storm water infrastructure and access roads that will form part of the development must be indicated on the site plan. Servitudes and an indication of the purpose of each servitude must be indicated on the site plan. Sensitive environmental elements within 100m of the site must be included on the site plan, including (but not limited to): o Watercourses / Rivers / Wetlands - including the 32 meter set back line from the edge of the bank of a river/stream/wetland; o Flood lines (i.e., 1:100 year, 1:50 year and 1:10 year where applicable; o Ridges; o Cultural and historical features; o Areas with indigenous vegetation (even if degraded or infested with alien species). Whenever the slope of the site exceeds 1:10, a contour map of the site must be submitted. North arrow A map/site plan must also be provided at an appropriate scale, which superimposes the proposed development and its associated structures and infrastructure on the environmental sensitivities of the preferred and alternative sites indicating any areas that should be avoided, including buffer areas. The GIS shape file for the site development plan(s) must be submitted digitally. 6. SITE PHOTOGRAPHS Colour photographs of the site and its surroundings (taken on the site and taken from outside the site) with a description of each photograph. 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 a recent aerial photograph. Photographs must be attached as Appendix C to this report. The aerial photograph(s) should be supplemented with additional photographs of relevant features on the site. Date of photographs must be included. Please note that the above requirements must be duplicated for all alternative sites. BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 28 of 114

30 SECTION B: DESCRIPTION OF THE RECEIVING ENVIRONMENT Site/Area Description For linear development proposals (pipelines, etc.) as well as development proposals 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 B and indicate the area that is covered by each copy on the Site Plan. 1. GRADIENT OF THE SITE Indicate the general gradient of the sites (highlight the appropriate box). Flat Flatter than 1:10 1:10 1:4 Steeper than 1:4 2. LOCATION IN LANDSCAPE (a) Indicate the landform(s) that best describes the site (highlight the appropriate box(es). Ridgeline Plateau Side slope of hill / mountain Closed valley Open valley Plain Undulating plain/low hills Dune Sea-front (b) Provide a description of the location in the landscape. The figure below shows the site in the context of the landscape. Figure 6: The site in the context of the landscape. The site is located where the point for Lutzville is shown The site is located on the northern boundary of the town of Lutzville. The surrounding environment north of the site is a natural undisturbed landscape. The Olifants River is located approximately 2.5km south west of the site. The site is located approximately 25km from the west coast of the Western Cape Province. BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 29 of 114

31 3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE (a) Is the site(s) located on or near any of the following (highlight 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 An area adjacent to or above an aquifer. YES NO UNSURE An area within 100m of a source of surface water YES NO UNSURE An area within 500m of a wetland YES NO UNSURE An area within the 1:50 year flood zone YES NO UNSURE A water source subject to tidal influence YES NO UNSURE (b) If any of the answers to the above is 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. The 1: scale Regional Geotechnical Maps prepared by Geological Survey may also be used). (c) Indicate the type of geological formation underlying the site. Granite Shale Sandstone Quartzite Dolomite Dolorite Other (describe) Provide a description. The Environmental Potential Atlas of South Africa (ENPAT) describes the geology as alluvium, sand and calcrete of Quaternary origin and the soils to be red-yellow apedal, freely drained soils; red, high base status, > 300 mm deep. Clay content is <15% 4. SURFACE WATER (a) Indicate the surface water present on and or adjacent to the site and alternative sites (highlight 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 / Lagoon YES NO UNSURE (b) Provide a description. There are no watercourses on the site or within a 500m radius of the site. The nearest wetland is approximately 1km away. 5. THE SEAFRONT / SEA (a) Is the site(s) located within any of the following areas? (highlight the appropriate boxes). If the site or alternative site is closer than 100m to such an area, please provide the approximate distance in (m). AREA YES NO UNSURE An area within 100m of the high water mark of the sea YES NO UNSURE An area within 100m of the high water mark of an estuary/lagoon YES NO UNSURE If YES : Distance to nearest area (m) BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 30 of 114

32 An area within the littoral active zone YES NO UNSURE An area in the coastal public property YES NO UNSURE Major anthropogenic structures YES NO UNSURE An area within a Coastal Protection Zone YES NO UNSURE An area seaward of the coastal management line YES NO UNSURE An area within the high risk zone (20 years) YES NO UNSURE An area within the medium risk zone (50 years) YES NO UNSURE An area within the low risk zone (100 years) YES NO UNSURE An area below the 5m contour YES NO UNSURE An area within 1km from the high water mark of the sea YES NO UNSURE A rocky beach YES NO UNSURE A sandy beach YES NO UNSURE (b) If any of the answers to the above is YES or UNSURE, specialist input may be requested by the Department. (The 1: scale Regional Geotechnical Maps prepared by Geological Survey may also be used). 6. BIODIVERSITY Note: The Department may request specialist input/studies depending on the nature of the biodiversity occurring on the site and potential impact(s) of the proposed development. To assist with the identification of the biodiversity occurring on site and the ecosystem status, consult or BGIShelp@sanbi.org. Information is also available on compact disc ( cd ) from the Biodiversity-GIS Unit, Tel.: (021) 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. A map of the relevant biodiversity information (including an indication of the habitat conditions as per (b) below) must be provided as an overlay map on the property/site plan as Appendix D to this report. Please refer to the Biodiversity Overlay Map shown in the figure below. Figure 7: Biodiversity Overlay Map (Source: Cape Farm Mapper WCSBP 2017 spatial data). BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 31 of 114

33 (a) Highlight the applicable biodiversity planning categories of all areas on preferred and alternative sites and indicate the reason(s) provided in the biodiversity plan for the selection of the specific area as part of the specific category. Also describe the prevailing level of protection of the Critical Biodiversity Area ( CBA ) and Ecological Support Area ( ESA ) (how many hectares / what percentages are formally protected). Systematic Biodiversity Planning Category CBA ESA Other Natural Area ( ONA ) No Natural Area Remaining ( NNR ) There are no mapped Critical Biodiversity Areas on the site or adjacent to the site. The Western extent of the site has been mapped in the Western Cape Biodiversity Spatial Plan (2017) to be an aquatic Ecological Support Area. This mapping is assumed to be incorrect as there is no watercourse on the site or adjacent to the site in these areas. If CBA or ESA, indicate the reason(s) for its selection in biodiversity plan and the conservation management objectives ESA1 Aquatic Areas are areas that are not essential for meeting biodiversity targets, but that play an important role in supporting the functioning of Protected Areas or CBAs, and are often vital for delivering ecosystem services. There are however no protected areas or CBA1 Aquatic areas on or adjacent to the site. The management of ESA1 Areas is to maintain in a functional, nearnatural state. Some habitat loss is acceptable, provided the underlying biodiversity objectives and ecological functioning are not compromised. Describe the site s CBA/ESA quantitative values (hectares/percentage) in relation to the prevailing level of protection of CBA and ESA (how many hectares / what percentages are formally protected locally and in the province) The proposed upgrade is within the existing already fully disturbed area of Minrite where salvage yards and storage areas are located. There are no watercourses on the site. N/A see above (b) Highlight and describe the habitat condition on site. Habitat Condition Percentage of habitat condition class (adding up to 100%) and area of each in square metre (m 2 ) Natural % m 2 Description and additional comments and observations (including additional insight into condition, e.g. poor land management practises, presence of quarries, grazing/harvesting regimes, etc.) 0% Near Natural (includes areas with low to moderate level of alien invasive plants) Degraded (includes areas heavily invaded by alien plants) Transformed (includes cultivation, dams, urban, plantation, roads, etc.) % m 2 % m 2 % m 2 0% 0% 100% The site is completely transformed. The ground cover is sand and gravel. Existing infrastructure, salvage yard and storage areas are located on the site proposed to be upgraded. (c) Complete the table to indicate: (i) the type of vegetation present on the site, including its ecosystem status; and (ii) whether an aquatic ecosystem is present on/or adjacent to the site. Terrestrial Ecosystems Description of Ecosystem, Vegetation Type, Original Extent, Threshold BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 32 of 114

34 (ha, %), Ecosystem Status Critically Ecosystem threat status as per the National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) Endangered Vulnerable Least Threatened The site is mapped in the WCSBP (2017) to comprise of Namaqualand Strandveld, which has an ecosystem status of Least Threatened. There is however no remaining vegetation on this site. Aquatic Ecosystems Wetland (including rivers, depressions, channelled and unchannelled wetlands, flats, seeps pans, and artificial wetlands) Estuary Coastline YES NO UNSURE YES NO YES NO (d) Provide a description of the vegetation type and/or aquatic ecosystem present on the site, including any important biodiversity features/information identified on the site (e.g. threatened species and special habitats). Clearly describe the biodiversity targets and management objectives in this regard. There is no vegetation or aquatic ecosystem on site. The original extent of the vegetation on the site, which is still located in the surrounding areas, in Namaqualand Strandveld. Namaqualand Strandveld is an extremely widespread vegetation type. Approximately ha of this vegetation type remains in the Matzikamma Municipal area. 7. LAND USE OF THE SITE Note: The Department may request specialist input/studies depending on the nature of the land use character of the area and potential impact(s) of the proposed development. Untransformed area Low density residential Medium density residential High density residential Informal residential Retail Power station Commercial & warehousing Office/consulting room Light industrial Medium industrial Heavy industrial Military or police base/station/compound Open cast mine Underground mine Spoil heap or slimes dam Hospital/medical centre Sewage treatment plant Casino/entertainment complex Quarry, sand or borrow pit Tourism and Hospitality facility Dam or reservoir School Tertiary education facility Church Old age home Train station or shunting yard Railway line Major road (4 lanes and more) Airport Harbour Sport facilities Golf course Polo fields Filling station Landfill or waste treatment site Mountain, koppie or ridge Other land uses (describe): (a) Provide a description. Plantation Agriculture River, stream or wetland Museum Historical building Graveyard Nature conservation area Archaeological site BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 33 of 114

35 The figure below (drone footage of the existing site overlaid onto Google earth) shows the existing land use of the site and immediate surrounds: RESIDENTIAL INDUSTRIAL EXISTING MINRITE PROCESSING FACILITY RESIDENTIAL INDUSTRIAL INDUSTRIAL Figure 8: Drone footage overlaid on Google Earth showing the existing Minrite Processing Facility and adjacent land uses. Minrite (Pty) Ltd is currently leasing the site from Transnet. The site is located at the old siding and train station platform of Lutzville. The site is zoned for Transport, however Minrite applies every 5 years to the Local Municipality for a Temporary Departure / Consent Use to renew the consent use to undertake an industrial activity on the site because Transnet does not rezone their land. Minrite has an existing mineral processing facility that has been in operation since the mid 1990 s when minerals sands raw concentrate became available from Namakwa Sands mine, located 70km north of Lutzville. The existing facility produces various grades of dried garnet, garnet-ilmenite mix, and ilmenite for use in industrial applications such as sandblasting, water jet cutting and non-slip surfacing. The activities at Minrite include mineral processing, drying, packaging and warehousing. The following infrastructure exists on the site: Warehouse and Workshop Existing MSP and packing Loading ramps Fuel storage (diesel and oil and paraffin) Rotary Dryer with Cyclone filter Security Office Offices and ablutions 8. LAND USE CHARACTER OF THE SURROUNDING AREA BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 34 of 114

36 (a) Highlight the current land uses and/or prominent features that occur within +/- 500m radius of the site and neighbouring properties if these are located beyond 500m of the site. Note: The Department may request specialist input/studies depending on the nature of the land use character of the area and potential impact(s) of the proposed development. Untransformed area Retail Power station Low density residential Commercial & warehousing Office/consulting room Medium density residential High density residential Informal residential Light industrial Medium industrial Heavy industrial Military or police base/station/compound Open cast mine Underground mine Spoil heap or slimes dam Hospital/medical centre Sewage treatment plant Casino/entertainment complex Quarry, sand or borrow pit Tourism and Hospitality facility Dam or reservoir School Tertiary education facility Church Old age home Train station or shunting yard Railway line Major road (4 lanes and more) Airport Harbour Sport facilities Golf course Polo fields Filling station Landfill or waste treatment site Mountain, koppie or ridge Other land uses (describe): Plantation Agriculture River, stream or wetland Museum Historical building Graveyard Nature conservation area Archaeological site (b) Provide a description, including the distance and direction to the nearest residential area, industrial area, agri-industrial area. With reference to Figure 8 above the following land uses are located adjacent to the existing Mineral Processing Plant: A railway line borders the site on the northern boundary. The area north and north west of the site is untransformed Namaqualand Strandveld; A Fuel depot (industrial area) is located 80m east of the existing facility. Five residential erven are located immediately south of the site, within a 200m radius of site. The nearest erf is approximately 50m south. Eight residential erven are located within a 200m radius of the proposed area for the upgrade, north west of the site. The residential suburb of Uitkyk is located approximately 300m west of the site. Commercial, warehousing and industrial activities are located south of the site. 9. SOCIO-ECONOMIC ASPECTS a) Describe the existing social and economic characteristics of the community in the vicinity of the proposed site, in order to provide baseline information (for example, population characteristics/demographics, level of education, the level of employment and unemployment in the area, available work force, seasonal migration patterns, major economic activities in the local municipality, gender aspects that might be of relevance to this project, etc.). BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 35 of 114

37 According to the Matzikamma Municipalities Draft Integrated Development Plan ( ), the current total population number in the municipality is persons. There are households in the municipal area. The geographical area of the municipality is approximately km2. The municipality comprises of approximately 18 towns and / or villages. These towns and villages include Doring Bay, Strandfontein, Papendorp, Ebenaeser, Lutzville-West, Lutzville, Koekenaap, Vredendal, Klawer, Vanrhynsdorp, Nuwerus, Bitterfontein, Kliprand, Put-se-Kloof, Rietpoort, Molsvlei and Stofkraal. Matzikama is characterized by an arid environment but is served by a life-giving arterial namely the Olifants River. The river with its associated canal systems supports a flourishing agricultural sector that is mainly built on viniculture. Apart from the previously district-municipality managed area to the north as well as the towns of Doring Bay, Strandfontein and Vanrhynsdorp the rest of the population is concentrated along the river and canal system. Vredendal is by far the largest town in the area and it is also centrally located rendering it the logical economic and administrative centre of the municipal area The Western Cape Government Provincial Treasury Department compiled a Socio-Economic Profile of the Matzikamma Municipality, dated The Working Paper explains the following: Gross Domestic Profit (GDP) Growth in the municipality grew by 1% during Matzikama contributed 15 per cent to the District s GDPR (or R2.9 billion of the District s R18.7 billion GVA) in 2013, making it the 3rd largest economy in the District behind Saldanha and Swartland. The Municipality experienced average year-on-year growth of 1.0 per cent from , which is significantly below the Province s growth rate of 3.6 over this period. Matzikama s construction sector experienced a healthy growth rate of 7.5 per cent per annum for the period it is the Municipality s fastest growing sector and grew faster than the construction sectors in both Saldanha Bay and Swartland. The only other sectors in Matzikama to experience positive growth was the commercial services sector which grew at 2.6 per cent per annum (the slowest in the District), and the general government and community, social and personal (CSP) services sectors which grew at 2.3 per cent per annum. Growth of the agriculture and manufacturing sectors contracted by 0.3 and 0.2 per cent per annum respectively. Employment Growth decreased by 2.1% between There has been a reduction in labour demand in all three categories of formal employment in Matzikama. While the demand for highly skilled labour remained relatively stable, labour demand in the semi- and unskilled sector (which employs 44 per cent of the total working population in the Municipality) decreased by 4.7 per cent. 88.5% of the households have access to electricity. 96.5% of the households have access to water. 69.8% of the households have access to sanitation. Approximately households in the municipal area earn less than R400 a month. The largest three sectors in the region are the Agriculture, Forestry & Fishing Sector (19.2%), Manufacturing (18.9%) and Transport, Storage & Communication (16.8%). Per capita income in Matzikama was below the District average in 2011, 2012 and Furthermore, per capita income in Matzikama decreased from R in 2012 to R in The Municipality therefore needs to make significant progress if it is to achieve the 2030 NDP target of R per person, per annum. A relatively large portion (78.0 per cent) of the Municipality s households resided in a house or brick structure on a separate stand, whilst 5.9 per cent of households resided in a town/cluster/semidetached house. In addition, 2.2 per cent of households occupied a flat in a block of flats and 1.6 per cent stayed in a house, flat or room in a backyard. A total of 87.7 per cent of households therefore had access to adequate housing within the Matzikama Municipality. There is however a concern that a total of 7.0 per cent reside in informal dwellings in an informal/squatter camp and 2.9 per cent reside in an informal dwelling/shack in the backyard. The figure below shows the sectoral composition of the Municipality. BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 36 of 114

38 Figure 9: Sectoral composition of the Matzikamma Municipality 10. HISTORICAL AND CULTURAL ASPECTS (a) Please be advised that if section 38 of the NHRA is applicable to your proposed development, you are requested to furnish this Department with written comment from Heritage Western Cape as part of your public participation process. Heritage Western Cape must be given an opportunity, together with the rest of the I&APs, to comment on any Pre-application BAR, a Draft BAR, and Revised BAR. Section 38 of the NHRA states the following: 38. (1) Subject to the provisions of subsections (7), (8) and (9), any person who intends to undertake a development categorised as- (a) the construction of a road, wall, power line, pipeline, canal or other similar form of linear development or barrier exceeding 300m in length; (b) the construction of a bridge or similar structure exceeding 50m in length; (c) any development or other activity which will change the character of a site- (i) exceeding 5 000m 2 in extent; or (ii) involving three or more existing erven or subdivisions thereof; or (iii) involving three or more erven or divisions thereof which have been consolidated within the past five years; or (iv) the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources authority; (d) the re-zoning of a site exceeding m 2 in extent; or (e) any other category of development provided for in regulations by SAHRA or a provincial heritage resources authority, must at the very earliest stages of initiating such a development, notify the responsible heritage resources authority and furnish it with details regarding the location, nature and extent of the proposed development. (b) The impact on any national estate referred to in section 3(2), excluding the national estate contemplated in section 3(2)(i)(vi) and (vii), of the NHRA, must also be investigated, assessed and evaluated. Section 3(2) states the following: 3(2) Without limiting the generality of subsection (1), the national estate may include (a) places, buildings, structures and equipment of cultural significance; (b) places to which oral traditions are attached or which are associated with living heritage; (c) historical settlements and townscapes; (d) landscapes and natural features of cultural significance; (e) geological sites of scientific or cultural importance; (f) archaeological and palaeontological sites; (g) graves and burial grounds, including (i) ancestral graves; (ii) royal graves and graves of traditional leaders; (iii) graves of victims of conflict; (iv) graves of individuals designated by the Minister by notice in the Gazette; (v) historical graves and cemeteries; and (vi) other human remains which are not covered in terms of the Human Tissue Act, 1983 (Act No. 65 of 1983); (h) sites of significance relating to the history of slavery in South Africa; (i) movable objects, including (i) objects recovered from the soil or waters of South Africa, including archaeological and paleontological objects and material, meteorites and rare geological specimens; (ii) objects to which oral traditions are attached or which are associated with living heritage; BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 37 of 114

39 (iii) ethnographic art and objects; (iv) military objects; (v) objects of decorative or fine art; (vi) objects of scientific or technological interest; and (vii) books, records, documents, photographic positives and negatives, graphic, film or video material or sound recordings, excluding those that are public records as defined in section 1(xiv) of the National Archives of South Africa Act, 1996 (Act No. 43 of 1996). Is Section 38 of the NHRA applicable to the proposed development? YES NO UNCERTAIN If YES or UNCERTAIN, explain: N/A Please refer to comment we received from HWC is Appendix E. Will the development impact on any national estate referred to in Section 3(2) of the NHRA? YES NO UNCERTAIN If YES or UNCERTAIN, explain: N/A Will any building or structure older than 60 years be affected in any way? YES NO UNCERTAIN If YES or UNCERTAIN, explain: N/A Are there any signs of culturally or historically significant elements, as defined in section 2 of the NHRA, including Archaeological or paleontological sites, on or close (within 20m) to the site? YES NO UNCERTAIN If YES or UNCERTAIN, explain: N/A Note: If uncertain, the Department may request that specialist input be provided and Heritage Western Cape must provide comment on this aspect of the proposal. (Please note that a copy of the comments obtained from the Heritage Resources Authority must be appended to this report as Appendix E1). BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 38 of 114

40 11. APPLICABLE LEGISLATION, POLICIES, CIRCULARS AND/OR GUIDELINES (a) Identify all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks, and instruments that are applicable to the development proposal and associated listed activity(ies) being applied for and that have been considered in the preparation of the BAR. LEGISLATION, POLICIES, PLANS, GUIDELINES, SPATIAL TOOLS, MUNICIPAL DEVELOPMENT PLANNING FRAMEWORKS, AND INSTRUMENTS ADMINISTERING AUTHORITY and how it is relevant to this application TYPE Permit/license/authorisation/comment / relevant consideration (e.g. rezoning or consent use, building plan approval, Water Use License and/or General Authorisation, License in terms of the SAHRA and CARA, coastal discharge permit, etc.) DATE (if already obtained): National Environmental Management Act, Act No. 107 of 1998, as amended DEA&DP Environmental Authorisation: being applied for with this Basic Assessment Report Pending National Nuclear Regulatory Act, Act 47 of 1999 (NNRA) National Nuclear Regulator (NNR). This enables Minrite to process, transport and store originating product from Naturally Occurring Radioactive Materials (NORM) material. 19 th June 2018 National Environmental Management Air Quality Act (NEM:AQA), Act No 39 of 2004 West Coast District Municipality A Variation to Minrite s existing Provisional AEL is required Pending National Environmental Management Waste Act of 2008 (Act No 59 of 2008) DEA&DP This Act was considered in terms of if a waste license is required or not. DEA & DP Waste Department was engaged with and they provided their comment (see Appendix F7) No Waste License is required. Comment obtained see Appendix F7 Western Cape Noise Regulations (2013) The noise impact assessment lists the findings for the proposed Minrite Lutzville Plant Expansion and provides recommendations for the site to comply with the Western Cape Noise Control Regulations, NEMA EIA Regulations contained in GN No s, R326, R327, R325 and R324 of 2014, as amended DEA&DP Environmental Authorisation: being applied for with this Basic Assessment Report Pending The National Heritage Resources Act, Act No. 25 of 1999 HWC This legislation was taken into account in considering whether the proposed activity with trigger the need to undertake an assessment of the proposed development in terms of possible impacts on heritage components at the site. Please refer to the final comment (Appendix E) by HWC section 38 is not applicable Final Comment Obtained see Appendix E The National Water Act, Act No. 36 of 1998 DWS This legislation was taken into account in considering whether the proposed activity triggers the need to apply for a Water Use Licence. No water use license is required. N/A DEA&DP Guideline Document: Guideline on Alternatives, March DEA&DP This guideline document was taken into account in the compilation of BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 39 of 114

41 2013 the environmental application for consideration by the Competent Authority. This Guideline was used to guide the EAP as to the correct interpretation and application of any alternatives identified and investigated. DEA&DP Guideline Document: Guideline on Public Participation, March 2013 DEA&DP Guideline for involving a Specialist in an EIA Process The Western Cape Provincial Spatial Development Framework, 2014 Cape Farm Mapper Western Cape Spatial Biodiversity Plan (2017) Integrated Development Framework for the Matzikamma Local Municipality ( ) DEA&DP DEA&DP DEA&DP Department of Agriculture SANBI Matzikamma local Municipality This guideline document was taken into account in the compilation of the environmental application for consideration by the Competent Authority. This Guideline was used to guide the applicant as to the correct procedures to follow for public participation. This guideline document was taken into account in the compilation of the environmental application for consideration by the Competent Authority. This Guideline was used to guide the EAP as to the extent of specialist involvement in the application process. This guideline document was taken into account in the compilation of the environmental application for consideration by the Competent Authority. This guideline was used to guide the EAP as to the correct interpretation of the PSDF and the impact of this in the proposed development. This GIS spatial tool was used to compile biodiversity mapping. This GIS dataset was utilised to show the desktop sensitivity of the site as mapped by SANBI. The IDP was used to source socioeconomic information in terms of municipal statistics. (b) Describe how the proposed development complies with and responds to the legislation and policy context, plans, guidelines, spatial tools, municipal development planning frameworks and instruments. LEGISLATION, POLICIES, PLANS, GUIDELINES, SPATIAL TOOLS, MUNICIPAL DEVELOPMENT PLANNING FRAMEWORKS, AND INSTRUMENTS The National Environmental Management Act, Act 107 of 1998, as amended. National Nuclear Regulatory Act, Act 47 of 1999 (NNRA). Describe how the proposed development complies with and responds: The National Environmental Management Principles contained in Chapter 1 of the Act are the principles against which the need and desirability of the proposed upgrade have been investigated. Minrite is classified as a supervised area (CoR-150) in terms of the National Nuclear Regulatory Act, Act 47 of 1999 (NNRA). In terms of said Act the Minrite operations are audited annually and inspected bi-annually by the National Nuclear Regulator (NNR). The level of exposure to Naturally Occurring Radioactive Materials (NORM) is very low and far below the legal threshold limit. This enables Minrite to process, transport and store originating product from NORM material. BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 40 of 114

42 National Health Act, Act No. 61 of 2003 National Environmental Management Air Quality Act (NEM:AQA), Act No 39 of 2004 Western Cape Noise Regulations (2013) DEA Integrated Environmental Management Guideline Series, Guideline 5: Assessment of Alternatives and Impacts in support of the Environmental Impact Assessment Regulations, 2006 DEA&DP Guideline Document: Guideline on Public Participation, 2013 DEADP Guideline Document: Guideline on Alternatives, 2013 DEA&DP Guideline Document: Guideline on Need and Desirability, 2013 DEA&DP Guideline for determining the scope of specialist involvement in the EIA process, June 2005 DEA&DP Guideline for the review of specialist input in the EIA process, June 2005 The Provincial Urban Edge Guideline, December 2005 The Western Cape Provincial Spatial Development Framework (PSDF), 2009 DEA (2010) Companion to the EIA Regulations 2010, Integrated Environmental Management Guideline Series 5, Department of Environmental Affairs People are entitled to an environment that is not harmful to their health and wellbeing. Therefore the propose upgrade will be designed and operated so that the Minimum Emission Standards are met and so that those handling low level radioactive materials are at low risk of exposure The existing Minrite facility and proposed upgrade trigger Category 5: Mineral Processing, Storage & Handling: Subcategory 5.2: Drying: The drying of mineral solids including ore, using dedicated combustion installations in the list of activities and associated minimum emissions standards contained in Government Notice No. 893 of 2013, which has been published in terms of the National Environmental Management Air Quality Act (NEMAQA), and which activities require an Atmospheric Emissions Licence prior to commencement. Therefore, it has been recommended by the air quality specialist and the EAP, that as a condition of the Environmental Authorisation & Atmospheric Emissions License that the Minimum Emission Standards are met under subcategory 5.2 and therefore appropriate abatement equipment to reduce the PM emissions will be required. The noise impact assessment lists the findings for the proposed Minrite facility and provides recommendations for the site to comply with the Western Cape Noise Control Regulations, This guideline was consulted during the impact assessment phase of the Basic Assessment and guided the impact assessment criteria and methodology used. The public participation requirements contained in Chapter 6 of the NEMA EIA Regulations were interpreted in conjunction with the recommendations contained in this guideline. The investigation and / or assessment of alternatives, including the No-Go Option, was guided by this guideline. The investigation into the Need and Desirability of the facility was closely guided by this guideline. This guideline was used in determining which specialists were required for this Basic Assessment process. All specialist inputs were reviewed and summarized by the EAP, with the guidance of this document. The investigation into the appropriateness of the development given the receiving environment was guided by this document. The principles governing development in the Western Cape, which are contained in the PSDF, were referred to in the investigation of the Need and Desirability of the waste facility. The NEMA EIA Regulations relevant to this application were interpreted with the assistance of this guideline document. Note: Copies of any comments, permit(s) or licences received from any other Organ of State must be attached to this report as Appendix E. BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 41 of 114

43 Section C: PUBLIC PARTICIPATION The PPP must fulfil the requirements outlined in the NEMA, the EIA Regulations, 2014 (as amended) and if applicable, the NEM: WA and/or the NEM: AQA. This Department s Circular EADP 0028/2014 (dated 9 December 2014) on the One Environmental Management System and the EIA Regulations, any subsequent Circulars, and guidelines must also be taken into account. 1. Please highlight the appropriate box to indicate whether the specific requirement was undertaken or whether there was an exemption applied for. In terms of Regulation 41 of the EIA Regulations, 2014 (as amended) - (a) fixing a notice board at a place conspicuous to and accessible by the public at the boundary, on the fence or along the corridor of - (i) the site where the activity to which the application relates, is or is to be undertaken; and YES EXEMPTION (ii) any alternative site YES EXEMPTION N/A (b) giving written notice, in any manner provided for in Section 47D of the NEMA, to (i) the occupiers of the site and, if the applicant is not the owner or person in control of the site on which the activity is to be undertaken, the owner or person in control of the site where the activity is or is to be undertaken or to any alternative site where the activity is to be YES EXEMPTION N/A undertaken; (ii) owners, persons in control of, and occupiers of land adjacent to the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken; YES EXEMPTION (iii) the municipal councillor of the ward in which the site or alternative site is situated and any organisation of ratepayers that represent the community in the area; YES EXEMPTION (iv) the municipality (Local and District Municipality) which has jurisdiction in the area; YES EXEMPTION (v) any organ of state having jurisdiction in respect of any aspect of the activity; and YES EXEMPTION (vi) any other party as required by the Department; YES EXEMPTION N/A (c) placing an advertisement in - (i) one local newspaper; or YES EXEMPTION (ii) any official Gazette that is published specifically for the purpose of providing public notice of applications or other submissions made in terms of these Regulations; YES EXEMPTION N/A (d) placing an advertisement in at least one provincial newspaper or national newspaper, if the activity has or may have an impact that extends beyond the boundaries of the YES EXEMPTION N/A metropolitan or district municipality in which it is or will be undertaken (e) using reasonable alternative methods, as agreed to by the Department, in those instances where a person is desirous of but unable to participate in the process due to (i) illiteracy; (ii) disability; or (iii) any other disadvantage. YES EXEMPTION N/A If you have indicated that EXEMPTION is applicable to any of the above, proof of the exemption decision must be appended to this report. Please note that for the NEM: WA and NEM: AQA, a notice must be placed in at least two newspapers circulating in the area where the activity applied for is proposed. If applicable, has/will an advertisement be placed in at least two newspapers? YES NO If NO, then proof of the exemption decision must be appended to this report. 2. Provide a list of all the State Departments and Organs of State that were consulted: Please note that there has been no pre-application consultation process on the Draft BAR & EMP as this is not a legislative requirement according to the EIA Regulations. However, there has been some level of preapplication consultation where the Authorities listed below have been consulted with (via a pre-application meeting and official comment received). State Department / Organ of State Date request Support / not in support Date comment received: was sent: DEA & DP: Land Management Date of NOI 4/06/2018 Support Receipt 28 th May 2018 DEA & DP: Waste Directorate Date of NOI 24/ Support Receipt 28 th May 2018 West Coast District Municipality Pre-Application Pending Support Meeting Heritage Western Cape 19/07/ /07/2018 Support BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 42 of 114

44 3. Provide a summary of the issues raised by I&APs and an indication of the manner in which the issues were incorporated, or the reasons for not including them. (The detailed outcomes of this process, including copies of the supporting documents and inputs must be included in a Comments and Response Report to be attached to the BAR (see note below) as Appendix F). There has been no pre-application consultation process on the Draft BAR & EMP as this is not a legislative requirement according to the EIA Regulations. However, there has been some level of pre-application consultation where the Authorities listed above have been consulted with (via a pre-application meeting and official comment received). A pre-application consultation meeting took place with the West Coast District Municipality (WCDM), DEA &DP: Land Management and the DEA&DP: Waste Management Departments on the 13 th June 2018 to confirm the listed activities applicable and EIA process to follow with the two Competent Authorities. In addition, a letter of motivation was sent to Heritage Western Cape to apply to be exempt from submitting a Notice of Intent. Please refer to Appendix F7 for the initial comments received from the DEA & DP Land Management & Waste Directorates and Appendix E for final comment from Heritage Western Cape. No other pre-application consultation has taken place. It is only proposed to undertake one round of public and Authority consultation (30 days), as is required in the EIA Regulations, to take place after an Application has been submitted. The following public participation is currently underway (as per Chapter 6 of GN 326): A Site Notice has been placed at the entrance to the existing minerals processing facility, advertising the availability of the Draft BAR for a 30 days public participation period; A joint public participation process is being conducted in terms of NEMA & NEM:AQA; Two newspaper advertisements have been placed, one in Die Burger and the other in Ons Kontrei advertising the availability of this Draft BAR and providing the public with the opportunity to provide SEC with their comments. A register of Interested & Affected Parties has been opened and will be updated after the 30 days commenting period. Notification Letters have been posted to 30 identified adjacent landowners and / or occupiers, inviting the adjacent landowners and occupiers to comment on the Draft BAR. Colour hardcopies of the Draft BAR Report have been posted to 6 identified Key Authorities who have been requested to provide their comments on the Draft BAR. All comments will be responded to in writing and a Comments & Responses Table which will be submitted with the Final BAR to the DEA&DP. All comments received and all responses to the comments will be included in the Final BAR submission to the DEA&DP. No issues have therefore yet been raised by I & AP s. This section will be updated after the legislative 30 day public participation process after the application form has been submitted, and included with the Final BAR submission. 4. Provide a summary of any conditional aspects identified / highlighted by any Organs of State, which have jurisdiction in respect of any aspect of the relevant activity. There has been no pre-application consultation process on the Draft BAR & EMP. No conditional aspects have yet been highlighted by any Organs of State. This section will however be updated after the legislative 30 day public participation process after the application form has been submitted, and included with the Final BAR submission. Note: BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 43 of 114

45 Even if pre-application public participation is undertaken as allowed for by Regulation 40(3), it must be undertaken in accordance with the requirements set out in Regulations 3(3), 3(4), 3(8), 7(2), 7(5), 19, 40, 41, 42, 43 and 44. If the exemption option is selected above and no proof of the exemption decision is attached to this BAR, the application will be refused. A list of all the potential I&APs, including the Organs of State, notified and a list of all the registered I&APs must be submitted with the BAR. The list of registered I&APs must be opened, maintained and made available to any person requesting access to the register in writing. The BAR must be submitted to the Department when being made available to I&APs, including the relevant Organs of State and State Departments which have jurisdiction with regard to any aspect of the activity, for a commenting period of at least 30 days. Unless agreement to the contrary has been reached between the Competent Authority and the EAP, the EAP will be responsible for the consultation with the relevant State Departments in terms of Section 24O and Regulation 7(2) which consultation must happen simultaneously with the consultation with the I&APs and other Organs of State. All the comments received from I&APs on the BAR must be recorded, responded to and included in the Comments and Responses Report included as Appendix F of the BAR. If necessary, any amendments made in response to comments received must be effected in the BAR itself. The Comments and Responses Report must also include a description of the PPP followed. The minutes of any meetings held by the EAP with I&APs and other role players wherein the views of the participants are recorded, must also be submitted as part of the public participation information to be attached to the final BAR as Appendix F. Proof of all the notices given as indicated, as well as notice to I&APs of the availability of the Pre-Application BAR (if applicable), Draft BAR, and Revised BAR (if applicable) must be submitted as part of the public participation information to be attached to the BAR as Appendix F. In terms of the required proof the following must be submitted to the Department: a site map showing where the site notice was displayed, a dated photographs showing the notice displayed on site and a copy of the text displayed on the notice; in terms of the written notices given, a copy of the written notice sent, as well as: o if registered mail was sent, a list of the registered mail sent (showing the registered mail number, the name of the person the mail was sent to, the address of the person and the date the registered mail was sent); o if normal mail was sent, a list of the mail sent (showing the name of the person the mail was sent to, the address of the person, the date the mail was sent, and the signature of the post office worker or the post office stamp indicating that the letter was sent); o if a facsimile was sent, a copy of the facsimile report; o if an electronic mail was sent, a copy of the electronic mail sent; and o if a mail drop was done, a signed register of mail drops received (showing the name of the person the notice was handed to, the address of the person, the date, and the signature of the person); and a copy of the newspaper advertisement ( newspaper clipping ) that was placed, indicating the name of the newspaper and date of publication (of such quality that the wording in the advertisement is legible). BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 44 of 114

46 SECTION D: NEED AND DESIRABILITY Note: Before completing this section, first consult this Department s Circular EADP 0028/2014 (dated 9 December 2014) on the One Environmental Management System and the EIA Regulations, 2014 (as amended), any subsequent Circulars, and guidelines available on the Department s website: In this regard, it must be noted that the Guideline on Need and Desirability in terms of the Environmental Impact Assessment (EIA) Regulations, 2010 published by the national Department of Environmental Affairs on 20 October 2014 (GN No. 891 on Government Gazette No refers) (available at: pdf) also applied to EIAs in terms of the EIA Regulations, 2014 (as amended). 1. Is the development permitted in terms of the property s existing land use rights? YES NO Please explain The site is located on the Transnet-owned old siding and station platform, zoned for Transportation. Minrite has however leased the site from Transnet. Minrite re-applies for consent use every 5 years. The upgrade is therefore in line with the existing consent use industrial zoning of the site. 2. Will the development be in line with the following? (a) Provincial Spatial Development Framework ( PSDF ). YES NO Please explain The upgrade is in line with the existing consent use industrial zoning of the site. The Provincial SDF encourages industrial activities to supply job opportunities. (b) Urban edge / edge of built environment for the area. YES NO Please explain The upgraded facility is an expansion of the existing mineral processing facility and within the edge of the built environment of Lutzville. (c) Integrated Development Plan and Spatial Development Framework of the Local Municipality (e.g., would the approval of this application compromise the integrity of the existing approved and credible municipal IDP and SDF?). YES NO Please explain The latest IDP for the Matzikamma Municipality is the Draft 4th Generation IDP ( ). The IDP explains that the Matzikamma Municipality has a need to create job opportunities. The proposed upgraded facility intends to supply an additional 25 jobs to the already existing 31 staff on site. The proposed facility will therefore supply 56 permanent jobs in total. Please refer to the current SDF in the figure below. The existing and proposed upgraded mineral processing facility represented by the red Asterix in Figure 10 below, is located within the existing urban edge boundary and within an area zoned for transport. Minrite has a consent use to undertake industrial activities on an area zoned for Transport, which it renews every 5 years. The site is surrounded by mostly industrial and business areas but also residential areas. BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 45 of 114

47 Figure 10 The existing and proposed upgraded mineral processing facility represented by the red asterix in the figure above, is located within the existing urban edge boundary and within an area zoned for transport. Minrite has a consent use to undertake industrial activities on an area zoned for Transport. (d) An Environmental Management Framework ( EMF ) adopted by this Department. (e.g., Would the approval of this application compromise the integrity of the existing environmental management priorities for the area and if so, can it be justified in terms of sustainability considerations?) YES NO Please explain Not Applicable. There is no EMF. (e) Any other Plans (e.g., Integrated Waste Management Plan (for waste management activities), etc.)). YES NO Please explain Not Applicable. 3. Is the land use (associated with the project being applied for) considered within the timeframe intended by the existing approved SDF agreed to by the relevant environmental authority (in other words, is the proposed development in line with the projects and programmes identified as priorities within the credible IDP)? YES NO Please explain The latest IDP for the Matzikamma Municipality is the Draft 4th Generation IDP ( ). The IDP explains that the Matzikamma Municipality has a need to create job opportunities. The proposed upgraded facility intends to supply an additional 25 jobs to the already existing 31 staff on site. The proposed facility will therefore supply 56 permanent jobs in total. 4. Should development, or if applicable, expansion of the town/area concerned in terms of this land use (associated with the activity being applied for) occur on the proposed site at this point in time? YES NO Please explain This is an ideal site for the proposed upgrade. The proposed upgrade is within the existing facility s footprint which is a completely disturbed area. The upgrade is in line with the existing consent use industrial zoning of the site. There are no biodiversity impacts associated with the upgrade in terms of impacts to vegetation or water resources. The proposed upgrade is not associated with any impacts to the heritage or cultural BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 46 of 114

48 environment. The upgrade of the facility s mineral processing infrastructure to increase the processing design capacity of the plant from tons to tons (and actual production capacity from tons per month to tons per month) is associated with increased traffic, increased air emissions (dust in particular), health, safety and noise impacts. These impacts are already occurring to some degree at the existing facility and are being managed in line with Health & Safety Operational Procedures and their existing Atmospheric Emissions License monitoring and management requirements. 5. Does the community/area need the project and the associated land use concerned (is it a societal priority)? (This refers to the strategic as well as local level (e.g., development is a National Priority, but within a specific local context it could be inappropriate.) YES NO Please explain The proposed development is proposed to service the community in terms job provision, income provision and skills development. The opportunity has risen for Minrite to increase its production capacity and grow the business due to a new agreement with Namakwa Sands to process an additional tons per month of minerals from its existing Mineral Separation Plant (MSP), located just north of Koekenaap. Up to tons per month of minerals are available in existing stockpiles at the MSP that have been stockpiled by Namakwa Sands over many years with the aim of processing them further at some point. An additional tons per month of freshly produced feed material from the MSP is also available for further processing by Minrite. The upgrade is therefore needed and desired so that the existing historic stockpiles at the MSP can be further processed before the waste product is used for rehabilitation purposes at the Namakwa Sands mine at Brand-se Baai. The upgrade will not only reduce the size of the long standing stockpiles at the MSP site but it will also contribute to the rehabilitation of the open cast pit at Namakwa Sands. 6. Are the necessary services available together with adequate unallocated municipal capacity (at the time of application), or must additional capacity be created to cater for the project? (Confirmation by the relevant municipality in this regard must be attached to the BAR as Appendix E.) YES NO Please explain The service infrastructure is already all in place as the existing facility has been in operation since the 1990 s. 7. Is this project provided for in the infrastructure planning of the municipality and if not, what will the implication be on the infrastructure planning of the municipality (priority and placement of services and opportunity costs)? (Comment by the relevant municipality in this regard must be attached to the BAR as Appendix E.) YES NO Please explain The service infrastructure is already all in place as the existing facility has been in operation since the 1990 s. There will be no implication on the infrastructure planning of the municipality. The traffic specialist has confirmed that no upgrades to road infrastructure are required as the roads proposed to be used are in good condition. 8. Is this project part of a national programme to address an issue of national concern or importance? YES NO Please explain N/A 9. Do location factors favour this land use (associated with the development proposal and associated listed activity(ies) applied for) at this place? (This relates to the contextualisation of the proposed land use on the proposed site within its broader context.) YES NO Please explain This is an ideal site for the proposed upgrade. The proposed upgrade is within the existing facilities footprint which is a completely disturbed area. The upgrade is in line with the existing consent use industrial zoning of the site. 10. Will the development proposal or the land use associated with the development proposal applied for, impact on sensitive natural and cultural areas (built and rural/natural environment)? YES NO Please explain There are no biodiversity impacts associated with the upgrade in terms of impacts to vegetation or water resources. The proposed upgrade is not associated with any impacts to the heritage or cultural BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 47 of 114

49 environment. The upgrade of the facilities mineral processing infrastructure to increase the processing design capacity of the plant from tons per month to tons per month (and actual production capacity from tons per month to tons per month) is associated with increased traffic, increased air emissions (dust in particular), health, safety and noise impacts. These impacts are already occurring to some degree at the existing facility and are being managed in line with Health & Safety Operational Procedures and their existing Atmospheric Emissions License monitoring and management requirements. 11. Will the development impact on people s health and well-being (e.g., in terms of noise, odours, visual character and sense of place, etc.)? YES NO Please explain Yes, the proposed upgrade is associated with increased traffic, increased air emissions (dust in particular), health, safety and noise impacts. These impacts are already occurring to some degree at the existing facility and are being managed in line with Health & Safety Operational Procedures and their existing Atmospheric Emissions License monitoring and management requirements. 12. Will the proposed development or the land use associated with the proposed development applied for, result in unacceptable opportunity costs? YES NO Please explain None identified. 13. What will the cumulative impacts (positive and negative) of the proposed land use associated with the development proposal and associated listed activity(ies) applied for, be? All impacts identified are cumulative in nature as it is proposed to increase the existing mineral processing capacity at an existing mineral processing facility. Cumulative impacts identified are as follows: Air Quality Impacts (including dust): Associated with Emissions from the Stack (Particulate Matter, S02 and NOX) Health Impacts: Associated with Low-Level Radioactive Material Handling Noise Impacts: Associated with the Dryer Fans and Dust Extraction Fans Traffic & Safety Impact: Associated with the increase in truck trips and staff trips in and out the plant. Visual Impact: Associated with Additional Infrastructure Socio-Economic: Creation of Permanent Jobs 14. Is the development the best practicable environmental option for this land/site? YES NO Please explain As per above. 15. What will the benefits be to society in general and to the local communities? Please explain Minrite currently employs 31 full time employees and also make use of contract workers from time to time. The proposed upgrade is expected to provide an additional 25 full time jobs which will result in a positive socio-economic impact in terms of the provision of jobs, skills and income opportunities. Minrite will contribute towards skills development in line with its internal skills development plan. The majority of formally employed individuals in the Matzikama Local Municipality are low skilled labour, therefore skills development is crucial in the area. 16. Any other need and desirability considerations related to the proposed development? Please explain No. 17. Describe how the general objectives of Integrated Environmental Management as set out in Section 23 of the NEMA have been taken into account: The manner in which these objectives have been taken into account is as follows: Compliance with and integration of the principles of environmental management is addressed in the following section (Section 18 below). All the actual and potential impacts on the environment, socio-economic conditions and cultural BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 48 of 114

50 heritage, the risks and consequences and alternatives and options for mitigation of activities, with a view to minimizing negative impacts, maximizing benefits have been identified, predicted and evaluated (see Section F). Public participation will be adequate and an appropriate opportunity will be afforded for public participation in decisions that may affect the environment. The local community and Organs of State having jurisdiction over the proposed upgrade of the mineral processing facility will be given an opportunity to participate (see Appendix F for details). 18 Describe how the principles of environmental management as set out in Section 2 of the NEMA have been taken into account: All relevant environmental, social and economic aspects of the proposed development have been identified, described, assessed and any residual impacts mitigated where applicable. The disadvantages and benefits have been considered in this process. This integrated approach has led to the identification of the Best Practicable Environmental Option for the development. The direct and indirect impacts and cumulative impacts associated with the proposed development on the surrounding environment have been assessed in this report and mitigated against in the conditions of the EMPr. With the protection of environmental resources ensured by the proposed location, layout and design, people s environmental rights and their access to environmental resources (such as uncontaminated water) are not restricted by the proposed development. In addition, the EMPr ensures that responsibility for management of any risks associated with the development, including the costs for remediation of any environmental damage that could occur, rests with the applicant. Appropriate specialist input has been obtained into the suitability of the current site. The proposal is therefore suitably located and suitably designed to ensure minimal impact on any sensitive environmental aspects on site and in the surrounding area. The regional planning context of the proposed activity has guided the development planning in order to ensure that the development is not in conflict with the planning imperatives for the area. The NEMA EIA Regulations (2014) and the DEA&DP s Guideline on Public Participation (2013) have been consulted for this application process. The relevant Organs of State with jurisdiction over the proposed development have been provided with an opportunity to review and comment on the Basic Assessment Report. Thus there is an opportunity for environmental considerations to be included in decision-making by these Organs of State. In addition, all reports compiled during this Basic Assessment process will be made accessible to the public, thus ensuring an open and transparent process and allowing the interests, needs and values of the public to be considered during the assessment process where possible. No particular community is more at risk than another in terms of possible impacts associated with the development. The development includes measures to minimise all associated impacts so that any and all nearby receptors are protected and environmental justice is served. There are no biodiversity impacts associated with the upgrade in terms of impacts to vegetation or water resources. The proposed upgrade is not associated with any impacts to the heritage or cultural environment. The upgrade of the facilities mineral processing infrastructure to increase the processing design capacity of the plant from tons to tons (and actual production capacity from tons to tons) is associated with increased traffic, increased air emissions (dust in particular), health, safety and noise impacts. These impacts are already occurring to some degree at the existing facility and are being managed in line with Health & Safety Operational Procedures and their existing Atmospheric Emissions License monitoring and management requirements. BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 49 of 114

51 SECTION E: DETAILS OF ALL THE ALTERNATIVES CONSIDERED Note: Before completing this section, first consult this Department s Circular EADP 0028/2014 (dated 9 December 2014) on the One Environmental Management System and the EIA Regulations, 2014 (as amended), any subsequent Circulars, and guidelines available on the Department s website The EIA Regulations, 2014 (as amended) defines alternatives as in relation to a proposed activity, means different means of fulfilling the general purpose and requirements of the activity, which may include alternatives to the (a) property on which or location where the activity is proposed to be undertaken; (b) type of activity to be undertaken; (c) design or layout of the activity; (d) technology to be used in the activity; or (e) operational aspects of the activity; (f) and includes the option of not implementing the activity; The NEMA (section 24(4)(a) and (b) of the NEMA, refers) prescribes that the procedures for the investigation, assessment and communication of the potential consequences or impacts of activities on the environment must, inter alia, with respect to every application for environmental authorisation ensure that the general objectives of integrated environmental management laid down in the NEMA and the National Environmental Management Principles set out in the NEMA are taken into account; and include an investigation of the potential consequences or impacts of the alternatives to the activity on the environment and assessment of the significance of those potential consequences or impacts, including the option of not implementing the activity. The general objective of integrated environmental management (section 23 of NEMA, refers) is, inter alia, to identify, predict and evaluate the actual and potential impact on the environment, socio-economic conditions and cultural heritage, the risks and consequences and alternatives and options for mitigation of activities, with a view to minimising negative impacts, maximising benefits, and promoting compliance with the principles of environmental management set out in the NEMA. The identification, evaluation, consideration and comparative assessment of alternatives directly relate to the management of impacts. Related to every identified impact, alternatives, modifications or changes to the activity must be identified, evaluated, considered and comparatively considered to: in terms of negative impacts, firstly avoid a negative impact altogether, or if avoidance is not possible alternatives to better mitigate, manage and remediate a negative impact and to compensate for/offset any impacts that remain after mitigation and remediation; and in terms of positive impacts, maximise impacts. 1. DETAILS OF THE IDENTIFIED AND CONSIDERED ALTERNATIVES AND INDICATE THOSE ALTERNATIVES THAT WERE FOUND TO BE FEASIBLE AND REASONABLE Note: A full description of the investigation of alternatives must be provided and motivation if no reasonable or feasible alternatives exists. (a) Property and location/site alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist: No alternative site locations were assessed because Minrite already has an operational mineral processing facility on the site which is already zoned for industrial purposes (consent use). The company proposes to upgrade its existing infrastructure to increase their processing capacity. Therefore only a Variation to their existing Atmospheric Emissions License is required. In addition, there are no other serviced industrial sites in Lutzville. Assessing site location alternatives is therefore in this instance not deemed to be required or feasible for Minrite. (b) Activity alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist: The objective of the proposed upgrade is to increase the mineral processing capacity. There are no other activity alternatives, beside the current proposal to upgrade the facilities infrastructure, that would meet this objective. BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 50 of 114

52 (c) Design or layout alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist: Two options were considered to reduce the modelled noise impacts that the existing and proposed upgrade would have to the residents and industrial area south of the site (on each side of the entrance Stasie road). Minrite considered constructing a wall south of the existing rotary dryer and the proposed future rotary dryers to reduce the noise impacts to the sensitive receptors identified. However this option was deemed to be unfeasible due the length of time it would take Transnet, the landowners, to approve such a structure, and the cost for the structure. A more suitable option, which would also result in the noise levels being within the noise levels prescribed in the Western Cape Noise Control Regulation (2013) is therefore proposed. The installation of circular duct attenuators on the dryer fans and the dust extraction fans is proposed to reduce the anticipated noise generated. (d) Technology alternatives (e.g., to reduce resource demand and increase resource use efficiency) to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist: The following technology alternatives (abatement equipment) are currently being investigated by Minrite to reduce the Particulate Matter Emissions from the existing rotary dryer and the proposed additional three rotary dryers: Cyclone Filter There is a cyclone filter installed on the existing rotary dryer. It is also an option currently being investigated by Minrite, to install a second cyclone filter at the proposed new common stack, to reduce Particulate Matter emissions. It is however not yet known if the existing or an additional cyclone filter would reliably reduce the PM emissions, this is currently under investigation. In a cyclone, particle-laden flue gas enters tangentially and creates a strong vortex in the body of the cyclone. This vortex forces the gas to flow in a downward spiral towards the apex of the cyclone. Due to inertia and centrifugal force, the particles in the gas move radially towards the wall and then slide downwards towards the apex of the cyclone where they are collected. Near the apex, the clean gas reverses its downward spiral and moves upwards in a second, smaller spiral before it exits from the top of the cyclone. Please refer to the figures below (Yellow Tree, 2017). Figure 11: Operating Principle of a Cyclone (left), Cyclone at Minrite(right) (Source: Yellow Tree Stack Emissions Report, 2017) BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 51 of 114

53 Reverse Pulse Bag House Filter Yellow Tree (2017) explain in the Stack Emissions Monitoring Report conducted on the existing stack in 2017 that inside reverse pulse bag filters, the filter bag forms a sleeve supported by a cylindrical frame. Gas containing high concentrations of PM flows into the main housing on the lower side of the tube sheet. PM is collected on the outside of the filter bag while the clean air passes through the filter bags and exits above the tube sheet. When sufficient PM has collected on the bags so that the pressure drop across the bags exceeds a set point, bag cleaning takes place. Bag cleaning is performed by jets of compressed air which dislodge PM caked on the outside of the bags. Jets are of a sufficiently high pressure that gas flowing into the bag filter unit does not have to be stopped during cleaning. Considering that it is the particles which are smaller than 10 μm and especially the particles which are smaller than 2.5 μm (PM10 and PM2.5) which are most harmful to human health, bag filters represent a significant health improvement as they arrest PM as small as 0.2 μm in size. Bag filters will reliably reduce PM emissions to a level which is below 50 mg/nm 3. A diagram of a reverse pulse bag filter is shown in the figure below. Figure 12: Diagram of Reverse Pulse Bag Filter It is however not required that the Environmental Authorisation or Atmospheric Emissions License specifies which technology to use and therefore they have not been comparatively assessed. Minrite can use any technology option as long at the option results in the Emissions being within the Minimum Emissions Standards published in Government Notice No. 893 of 2013, which has been published in terms of the National Environmental Management Air Quality Act (NEMAQA). (e) Operational alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist: BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) October 2017 Page 52 of 114