Presented by Steve Kalule Director/Environmental Engineer USK Waste & Environmental Engineering

1. FEASIBILITY STUDY FOR DEVELOPMENT OF A HAZARDOUS WASTE REMEDIATION /WASTE DISPOSAL SITE AND RECYCLING FACILITY AT KOEDOESPOORT STATION PROJECT NUMBER: TRE12-KLP-091-0399 Presented by Steve Kalule Director/Environmental Engineer USK Waste & Environmental Engineering

2. Report Overview • Problem Statement • Field Investigations& Findings • Engineering and Design Options • Financial Implications • Consultations with Authorities • Conclusions • Recommendations

3. Problem Statement Previous Studies • In April 2012, Transnet Engineering identified the need to conduct scientific investigation to confirm the extent and severity of pollution at Koedoespoort Centre Identified Asbestos buried sites. • The scope the above study included: • Identifying Asbestos contamination at Five (5) sites within the Koedoespoort station main facility; • Soil Analysis for Asbestos Presence and Laboratory chemical analysis for the heavy metals in the soil samples from the 5 sites. • The study concluded by ranking the 5 sites according to an assigned risk profile, where site 5 was flagged as the highest risk site. • The study then recommended, that site five be investigated as a potential site for remediation site and for use as a disposal facility for low-grade hazardous waste.

4. The Feasibility Study • As recommended by previous investigation, TE commissioned a feasibility study to investigate the potential for using site 5 to develop an integrated waste management center which involves the a • hazardous waste disposal site, • a contaminated site remediation site and • a recycling facility for all other waste materials from the Koedoespoort Station. • The feasibility Study covered the following criteria: • Environmentalcriteria: Environmental impacts, fatal flaws, risk and opportunities. • Engineeringcriteria: Civil engineering aspects and factors. • Socialcriteria: Potential Social Impact / Public Acceptance. • Legal criteria: Consultations with authorities on legality of project. • Financial criteria: The Cost Implications of the project.

5. Landfill Engineering Design • The primary objective of the hazardous disposal (landfill) site design is to provide effective control measures to prevent or reduce as far as possible negative effects on the environment, in particular the pollution of surface water, groundwater, soil and air, as well as the resulting risks to human health arising from landfilling of waste. • The design concept for a landfill depends on the ground conditions, the geology and hydrogeology of the site, the potential environmental impacts and the location of the landfill. • The investigations for a landfill should provide sufficient information to enable the formulation of a site-specific design.

6. Design Parameters/ considerations

7. Proposed Infrastructure

8. Financial Implications

10. Financial Forecasting of Waste Management Costs at KDS

13. Remediation Cost Projections • TE spent approximately 23 Million Rand to remediate asbestos contamination at the Scrap Bank Site with an of 12 Hectares. • In comparison, this feasibility was based on remediation of a total area of 29 Hectares, this could potential more than double the cost to an estimate of 60 Million Rand. • Further based on high level of contamination Sites 1, 4 and 5, it is likely that these sites could yield significantly higher volumes of contaminated soil to be removed compared to the Scrap Bank site, which is likely to further escalate the cost of remediation to a private commercial landfill site to in excess of 80 -100 Million Rand. • By comparison, the estimated potential cost of remediation to a commercial landfill is likely to be higher than the estimated capital expenditure on a TE Owned Hazardous waste disposal site

14. Waste Cost Projections Accepting Waste from other TE Regions can result in Cost Recovery thereby lowering operating costs in the own site scenario. • Note: 1. Germiston Region spend approximately 3 Million on Disposal alone per year • Note: 2. Bloemfontein Region spend approximately 1.5 Million on Disposal alone per year • Note: 3. Estimated Annual Operating Cost for this size of landfill is 200,000 per month (outsourced)

15. Benefits of the Project • By comparison, the estimated potential cost of remediation to a commercial landfill is likely to be higher than the estimated capital expenditure on a TE Owned Hazardous waste disposal site. • The proposed project can serve TE current and future needs for a minimum period of 20 years (Projected Lifespan). • If TE uses its own landfill, there is potential saving on waste management costs by almost 30% and over the long run this is significant as shown in the projections below. • The project will immediately solve the risk/liability posed by the contaminated land. • This approach is currently used by ESKOM who own their Hazardous waste disposal sites and has proved as a much more cost effective option compared commercial waste disposal sites.

16. Consultations with Authorities • DEA & DWA confirmed that Site 5 has never been licensed as waste disposal site. • Any new or continued waste disposal at this Site would have to be licensed under the current regime of waste licensing or authorizations in terms of the National Environmental Management Waste Act. • There are some risks involved in the current use of site 5 as an unlicensed waste disposal site especially containing asbestos and it remaining un remediated. It is necessary for Transnet to address this issue and DEA welcomes the approach to the possibility of usage of site 5 for a Remediation and Disposal Facility. • The DEA has no objection to establishment of a disposal facility and remediation site for hazardous waste at site 5, however Transnet must make sure that all measures to minimize the potential risks are implemented. • Transnet Engineering should use this opportunity to establish a facility that can be utilized to remediate all other Transnet sites, which are contaminated with Asbestos

17. Consultations with DEA/DWA • The due process for authorization must be a combined application for waste license and remediation, which shall be followed by a Scoping and Full Environmental Impact Assessment in Terms of the NEMA EIA Regulations, 2010. • He stated all the listed activities triggered must be highlighted and combined into an integrated single application submitted to the Authorization Directorate and copied to the Directorate for Contaminated Lands. •  The DEA will be prepared to accept an integrated single application submitted to the Authorization Directorate and copied to the Directorate for Contaminated Lands. • The proposed landfill site must be designed in accordance with the draft guidelines for landfill liners otherwise the Department of Water Affairs will not accept any other design for landfill liners.

18. Legal Requirements • The project is likely to trigger both Category A and B Listed Activities in Terms of NEM: Waste Act. • Listed Activities triggered by the project: • Disposal of Hazardous Waste (Category B, Activity 9) • Disposal of Waste on land in excess of 200m2(Category B, Activity 10) • Construction of the Landfill Site and other Infrastructure (Category B, Activity 11) • Temporary Storage of General Waste in excess of 100m3 (Category A, Activity 1) • Temporary Storage of Hazardous Waste in excess of 35m3 (Category A, Activity 2) • Recovery of General Waste in excess of 1 ton / day (Category A, Activity 5) • Remediation of Contaminated Land (Category A, Activity 12) • Hence it will require a Waste License Application supported by a Full Scoping and Environmental Impact Assessment.

19. Conclusions Conclusions • The technical investigative studies conducted indicate that the site is generally a low risk site and hence suitable for the project. • The few identified potential risks can be mitigated by appropriate engineering design and proper operation. • A conceptual Engineering Design for a Hazardous Waste Disposal and a Recycling Facility has been prepared. • The competent authorities have no objection to submission of an application for the above proposed facilities and development. • The initial capital expenditure on the project is estimated at ~R 40M as compared to an estimated R80 – 100 M on remediation costs without any tangible infrastructure investment. • The project is likely to have significant savings on Waste Management in the Medium - long term.

20. Recommendations • TE needs to address the issue of Risk posed by the contaminated site. • TE needs to develop a detailed business plan for the project. • TE needs to commission a combined Scoping/EIA for the remediation and the proposed project. • TE could take the option of looking at either the Hazardous site in isolation to the Recycling facility and commission the disposal as stage 1 thereby even further reducing the initial capital expenditure while achieving the immediate objective (remediation of the sites at a far less cost). • TE then needs to do a detailed business plan for developing the recycling facility as Stage 2 and only commission it should it be deemed feasible.

21. Thank you for your attention!