The scoping report on the proposed ferroalloys/ferrochrome smelter plant within the Musina-Makhado Special Economic Zone (MMSEZ), north of the Soutpansberg, became available last week. The document, which followed a public-participation meeting on 13 September, provides more insight into what exactly the China-based company, the Kinetic Development Group (KDG), has planned for the region.

What is planned?

Ferrochrome is a ferroalloy composed of chromium and iron. It is an important alloying agent in steelmaking, and KDG is planning to produce between 125 kilo-tonnes and 1 million tonnes per annum at the proposed smelter, to be situated on the farms Van Der Bijl 528 MS and Dreyer 526 MS. The project includes the construction of two 33,000 kVA electric furnaces and their supporting facilities.

According to the scoping report, prepared by Gudani Consulting, the appointed environmental assessment practitioners for KDG, the main facilities within the project scope include (among others) a high-carbon ferrochrome production workshop, a chromium furnace baking workshop, a raw-materials batching and feeding system, charcoal drying, a furnace gas purification and dust removal system, and more. Associated infrastructure will include access roads, diesel storage tanks, pipelines to pollution-control dams, berms to separate dirty and clean water, temporary overburden stockpiles, waste-rock dumps, topsoil storage dumps, and possibly the least intrusive aspect – offices.

The project entails several listed activities, which may not commence prior to obtaining an environmental authorisation, in terms of Section 24 of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA). As mentioned in previous articles, an application for environmental authorisation, in terms of NEMA, for listed activities has already been submitted to the Limpopo Department of Economic Development, Environment and Tourism (LEDET). In addition, an integrated water-use licence application (IWULA) will be compiled and submitted to the Department of Water and Sanitation (DWS). A comprehensive integrated water and waste-management plan for the proposed ferroalloys/ferrochrome smelter operations will also be prepared. Applications for township development have been submitted to both the Musina and Makhado Municipality as the proposed MMSEZ area falls within both municipalities' areas of jurisdiction.

On 13 September this year, a public-participation meeting with the Mulambwane CPA, Mopane community, and other interested and affected parties regarding the proposed smelter took place on the farm Lekkerlag.

A delicate balance

During the meeting, it became evident that public participation will once again involve a balance between those who approve of the project and those who oppose it. This was highlighted by Mr Aubrey Luvha’s response. As secretary of the Mulambwane CPA (which owns the land on which the MMSEZ is situated), he had already stated on 5 September that the Mulambwane CPA had no objection to the proposed project and that they needed the proposed developments “as soon as possible.”

Luvha’s positive outlook on the project is understandable, especially in a region with few employment opportunities other than farm work. The scoping report states that the development of the R255 billion MMSEZ will generate approximately 21,000 jobs in its first five years of operation. This, according to the report, will increase to 51,000 jobs in the tenth year of the MMSEZ’s operation. The proposed ferrochrome smelter will see an initial capital investment of R1.23 billion, but will employ only 235 people. The reason for this, as stated in the scoping report, is that the process equipment for the project has a relatively high degree of automation, which requires technical personnel and production workers with relatively high levels of education and professional expertise. This raises the question of how many local residents will actually benefit from the proposed smelter.

“We are selling our heritage and land away”

Not everyone shared Luvha’s positive sentiment, particularly conservationists and other landowners who do not want the Bushveld’s beautiful skyline to resemble industrial areas like Vereeniging and Krugersdorp. “We are selling our beautiful heritage and land away. This will destroy our natural environment,” remarked one objector. The objections were included in a combined list of grievances received from 29 landowners and interested parties.

The Herd Nature Reserve, the Centre for Applied Legal Studies, and Living Limpopo also listed their objections to the proposed smelter. For them, the numbers did not add up. “[A] 10 million tonnes per annum coal washery – that’s 10 million tonnes a year to be mined locally by Kinetic and supplied to the smelter over 30 years (which actually exceeds the economically recoverable fraction of the 10 billion tonnes of hard coking and thermal resources of the coalfield),” the three organisations stated.

The Centre for Environmental Rights NPC raised concerns about the processes followed by KDG and Gudani Consulting. “The process is not an integrated process (in terms of NEMA), but rather there will be three separate processes (for the EIA, the Atmospheric Emissions Licence, and the WULA), as referenced in the 13 September 2024 notice. The 60 days referred to in the 13 September 2024 notice is the time period for registering as Interested and Affected Parties (I&APs), and further information will follow after registration,” stated the NPC.

Water remains a big problem

One key finding of the scoping report is the scarcity of water in the area. According to Notice 538 of 2016, published in Government Gazette No. 26187 on 2 September 2016, the permissible surface water abstraction volumes for all eight properties (8 x 2,000m³) that form the MMSEZ equals 16,000m³ per year at 1 litre per second. The permissible groundwater abstraction volumes for all eight properties (8 x 45m³) equal 360,585m³ per year at 1 litre per second. This means that the total permissible surface and groundwater abstraction volumes available for the MMSEZ southern site are estimated at 0.377 million cubic metres. However, the MMSEZ southern site requires a total of 123 million cubic metres of water for its operation. The proposed ferrochrome smelter will require approximately 150,000 to 200,000 cubic metres of water per year for Phase 1 (125 Ktpa).

There is still no clear answer as to where the required water will come from. Boreholes are currently being considered, although the developers continue to pin their hopes on piping in water from Zimbabwe, though it remains to be seen whether this option is feasible.

Other environmental and technical challenges identified for further investigation include the potential loss of soils in an area where soil resources are already scarce. The negative impact on local ecology, protected animal and plant species, and the region’s cultural heritage will also be examined.

Regarding water, the report also points out that the smelter may affect surface water flows and potentially lead to contamination if runoff, drainage, and potential spills are poorly managed. There is also a risk of infiltration of contaminated water from the smelter and waste dumps into the underground water system.

Air quality is another concern. The report states that ferrochrome smelting emits carbon dioxide, smoke, and dust. These primary pollutants are released directly into the atmosphere and contribute to greenhouse effects. Dust and smoke emissions could also blow onto surrounding properties, potentially causing a nuisance and affecting people, livestock, and plants if not managed properly. In terms of visual impact, the smelter infrastructure, particularly the ferrochrome plant and waste disposal dumps, may be visually intrusive.

On a more positive note, the report states that the proposed ferrochrome smelter will likely have a significant social and economic impact in the area and should contribute to the local, regional, and national economy.

What is next?

The proposed project is currently in the scoping phase of the Integrated Environmental Management (IEM) process, as per the Environment Impact Assessment (EIA) regulations. The scoping phase primarily concerns the identification of anticipated impacts from the proposed ferroalloys/ferrochrome activities, considering prevailing or baseline conditions. The EIA/EMP (Environmental Management Report) phase will then assess these impacts, and specialist investigations will be integrated as part of the assessment. Impacts will be evaluated using standard impact assessment criteria, which will help determine their significance.

The complete report will be made available with the online publication of this article. It is already available to interested and affected parties, who will have until 20 October to review it.